Representation by East Anglia Three Limited c/o ScottishPower Renewables (East Anglia Three Limited c/o ScottishPower Renewables)
- Date submitted
- 6 July 2023
- Submitted by
- Members of the public/businesses
East Anglia Three Limited's (EATL) is wholly owned by ScottishPower Renewables and is in the process of discharging requirements for the East Anglia THREE offshore wind farm (EA3). EA3 is a Nationally Significant Infrastructure Project for which development consent was granted on 7 August 2017 pursuant to the East Anglia THREE Offshore Wind Farm Order 2017 (EA3 Order). By virtue of Article 30 of the EA3 Order, EATL is a statutory undertaker for the purposes of this project and the land within the Order Limits should be treated as operational land required in connection with its statutory undertaking. Proposed works in Section AB - Bramford Substation to Hintlesham - is located within the Order Limit of the onshore connection works for EA3, namely the proposed removal of existing 400kV pylons and replacement with a new 400kV pylon at Bramford Substation. As such, EATL have a significant interest as statutory undertaker whose operational land is affected. EATL recognise the importance of the proposed reinforcement works, however it is imperative that the works do not compromise the construction and operation of EA3 which will deliver substantial renewable energy benefits towards meeting the national need for renewable energy identified in the National Policy Statement for Renewable Energy (EN-3). Following on from our initial letter in response to the consultation in January 2022, alongside meetings between SPR and National Grid, the changes to the design at Bramford have been reviewed and it is appreciated that a number of our previous comments have been taken into consideration. Any outstanding comments are described below. Works within EA3 Order limits The proposed removal of two 400kV pylons and the construction of a new 400kV pylon at Bramford Substation, are within the EA3 Order Limits, on land owned by ScottishPower Renewables. It is imperative that the reinforcement works around Bramford Substation are designed to ensure there is no impact on any EA3 land required to mitigate or operate the EA3 project. Access to the EA3 substation by EATL must also be maintained at all times during both the construction and operational phases of the proposed works. Additionally, consideration is needed to ensure that any additional planting does not undermine the EA3 Landscape Master Plan requirements contained within the DCO and landscape management strategies. The requirement for any variation or consents as part of these works resulting for EA3 would be the responsibility of National Grid in consultation with EA3. Cumulative effects Given the requirement to assess cumulative effects in paragraph 5(e) of Schedule 4 to the Town and Country Planning (Environmental Impact Assessment) Regulations 2017, we trust that a full cumulative environmental assessment with the EA3 project will be undertaken. As the proposed works are likely to coincide with the construction phase of EA3, we believe the following topics require consideration, some of which are already noted in the preliminary cumulative assessment in the PEIR: • Traffic and transport: Cumulative impacts from construction traffic associated with the proposed works and the EA3 Convertor Station and cable route should be assessed. Additionally, the impact on Public Rights of Way (PRoW) amenity along the bridleway at Bullen Lane, which coincides with the vehicular access along Bullen Lane, should be considered. • Landscape, ecology and water resources: There is the potential for cumulative impacts in relation to landscape, water resources and ecology. This is associated with the potential for impacts on existing landscape planting around the EA3 substations and on the SuDS pond due the proximity of the works. This could have subsequent impacts on local fauna, including Great Crested Newts in the SuDS pond. • Noise: The potential noise impacts from concurrent construction activities should be considered in the assessment and mitigated accordingly. It should be noted that piling activities are expected at the EA3 Converter Station. Information on the number, type and timing of these works will become available in Q3 of 2023. SPR recognises the importance of the proposed works and the contribution both projects have in meeting the national need for renewable energy. We are keen to continue working with National Grid and welcome further meetings to discuss the issues noted above and any other items, including if National Grid would still like to arrange a Statement of Common Ground following these design updates. SPR are committed to Mid Suffolk District Council’s strategic cumulative group in the Bramford area and are happy to provide appropriate information on the EA3 site as required. It is requested that National Grid liaise with us through Marta Menchi (redacted). Please do not hesitate to contact us for further discussion or information requests.