Representation by Philip James Morgan
- Date submitted
- 24 June 2024
- Submitted by
- Members of the public/businesses
Morecambe and Morgan Off Shore Wind Farms Transmission Route and Substations We are writing to you to outline the impact of the proposed transmission route and substations for the proposed Morecambe and Morgan Off Shore Wind Farm. We would like to outline the proposals, the flawed engagement process, the impact of the proposals and outline what we would like you to do. The proposals The Wind Farm proposals will see wind turbines in the Irish Sea with the resulting transmission route coming ashore at Blackpool South Shore, crossing the Fylde and joining the National Grid at Penwortham. The cable route will be 110 metres wide along a 25km corridor and there will be two substations, covering 45 acres, with a further 45 acres lost during construction, and 20 metres high at sites between Newton and Freckleton. I attach a map showing the route, proposed substations and local communities. The engagement process The non-statutory consultation was flawed. Despite requests from Newton with Clifton Parish Council no consultation event was held in the village nor was one held in Freckleton. Postcards, which were not consistently delivered, were so vague and unspecific that local people did not understand the impact. The one opportunity for local engagement that was provided was by the insistence of Newton with Clifton Parish Council. No attempt was made to respond to any of the points raised making the process meaningless. That meant the first local opportunity for people in those two affected communities to understand and comment upon the project was after the route and sites for the substations had been decided. Flaws continued into the statutory consultation process. There were no viewpoints for the 20-metre-high substations from homes in the affected communities, despite being requested by Newton with Clifton Parish Council. There were no detailed maps provided at the consultation event, despite being made available to landowners, and no 3-D representations to allow local people to understand the visual impact. The route from the substations to Penwortham was only published to landowners a week after the close of the consultation window. Further gaps in information include noise levels, the design of the substations and impact on house prices. NO attempt was made to engage with the local schools close to the route and substations. Those events that did take place did not have people able to engage about the proposals, merely to explain them. The feedback form was not in plain English and was overly complex, putting off many people from responding, and for those who did persevere the on-line version was liable to failure. Overall we do not believe that the consultation to date is sufficient, nor does it meet the requirements of Section 42 of the Planning Act 2008, nor regulation 12(2) of he Infrastructure Planning (Environmental Assessment) Regulations 2017. It does not meet the NE-5, Horlock Rules nor Rochdale envelope case. There should be no issuing of a Adequacy of Consultation notice. Our concerns about the route and its impact The scheme simply decided there was only one end point for the transmission route to join the National Grid at Penwortham. It would be useful to have an independent assessment of alternatives such as Heysham and Stannah. Likewise the choice for a single route was simply decided, without engagement, as being across the heart of the Fylde, without consideration of alternative routes. The National Grids Holistic Network Design Map shows a route to Penwortham to the south of the Ribble. It would be useful to have an independent assessment of alternatives along and south of the Ribble. Again there was a decision to only allow for four areas for the substations search area, which conveniently came to a single decision for location between Newton and Freckleton. This location include the Green Belt, and the Area of Separation between Newton and Kirkham, which are meant to be protected. The criteria for the choice of substation siting was not agreed nor consulted upon. No weighting was used. Important factors such as the impact on residents, preferred use of brownfield sites, impact on food security and impact on heritage assets were ignored. There was no ornithology survey for Zone 1 and feedback from local residents, and previous evidence of a range of rare bird and other species was not considered. Evidence of pink footed geese was ignored for Zone 1 but used to support avoiding other zones. Three of the four proposed sites were known to fail the set criteria making the end decision a fixed one, rather than one for engagement. The choice of an 8km search zone was not explained and previous schemes (Norfolk Vanguard) only had a 3km zone. The proposed substation sites are conveniently on the edge of the 8km search zone. We note that other countries with off shore wind are not allowing onshore substations. The Newton and Freckleton locations adjoin another proposed site for a solar farm and no attempt was made to identify cumulative impact of multiple schemes in the locality (which now also include a proposed solar farm in Clifton adjoining the transmission route). We understand the transmission route is avoiding the proposed solar farm, taking the route closer to Clifton. There is an inconsistency between avoiding a proposed use for land, but not avoiding existing farming use. The impact on the local environment and economy will be profound. Local farmers have indicated their concerns about the future viability of their farms. Local flooding, with additional run off and already the subject of a Fylde BC review , will be exacerbated. There will be 5 years of construction, with over 5 times the current level of HGV traffic, assuming the substations can be built concurrently, rather than consecutively. No detail is provided about the net biodiversity gain for the substations. As far as we are aware no substations of such scale have ever been built so close to residential properties, nor so close to local schools (Strike Lane and Carr Hill). Noise impacts are not yet known, nor any screening or the resulting visual impact.