Representation by Burstall Parish Council (Burstall Parish Council)
- Date submitted
- 17 July 2023
- Submitted by
- Parish councils
The Bramford substation, its connected infrastructure and other related developments are within the Bramford and Burstall parish boundaries. This infrastructure complex is also visible from parts of the parish of Chattisham and Hintlesham. The residual impact of proposed additional infrastructure, including NGET’s Bramford to Twinstead reinforcement, would be substantial and would directly affect individuals and communities within these parishes, as well as others using the area. The Parish Councils of Bramford, Burstall, Chattisham and Hintlesham accept the need for the proposed reinforcement and are broadly in agreement with the Statement of Common Ground agreed with the Local Authorities (Document 7.3.1). This document indicates a small but significant number of Matters not Agreed. Of these, cumulative impact is relevant to the comments below. In addition, the Parish Councils wish to argue that – in accord with the mitigation hierarchy as cited in draft NPS EN5 (defined in the Glossary to EN1) – and as NGET appears to accept the scale of residual harm, it should ensure there is an adequate mechanism for appropriate mitigation and/or compensation. Such provision should be incorporated within the DCO. This argument is summarised in the points below: • NGET accepts (1) there is high potential for an additional transmission line to give rise to significant adverse effects and that the landscape may have reached capacity to accommodate the scale of new infrastructure proposed. • Following the last stage of formal consultation for the Bramford to Twinstead reinforcement, new draft NPS have been published which gives added importance to the mitigation hierarchy, including mitigation and compensation where other options (avoid and reduce) are not available. • In meetings and correspondence with parish representatives, NGET has stated that some of the most harmful effects of the line, such as overhead towers and cables close to both sides of a cluster of properties, cannot be avoided if overhead lines are the only option. In the same areas the resultant wirescape would breach Holford Rules. • The mitigation hierarchy indicates improved mitigation as the obvious alternative. Adequate mitigation requires undergrounding the new line from the Bramford sub station to a point west of the Hintlesham woods. • Mitigation claimed for the new line in the form of removal of existing lower voltage UKPN electricity distribution lines does not apply in this area as these lines begin on the opposite side of Burstall village. The section round the village is already in the form of underground cables. • High residual visual impact would also result in Hintlesham where the new line would pass close to Grade 1 listed Hintlesham Hall and in the setting of the Hall would not be aligned with the existing towers. NGET recognize this issue and have considered mitigation, including oversailing the RSPB woodland. The application does not include any form of effective mitigation. • NGET has recognised this issue in other areas, such as the Lawford spur of the proposed Norwich to Tilbury 400v line where undergrounding to a new substation is planned. • If undergrounding from the Bramford substation is not possible, compensation above and beyond that offered as community benefit is required. • Cumulative impact created by numerous other approved and potential projects in the area, including large solar and battery storage developments and two further overhead 400v lines, should also be taken into consideration and given higher priority than is currently the case. • Resolving these issues requires a commitment to continue to work with local communities in Participatory Placemaking (2) should a DCO be granted. This should be embedded in a Section 106 agreement or similar within the DCO. Community involvement in the discharge of requirements would thus be ensured. (1)There is high potential for the development of a 400kV OHL within this section to give rise to significant adverse effects on local landscape character in combination with the existing NG and DNO assets that converge at Bramford substation. This is because it is possible that this landscape has reached its capacity to accommodate such infrastructure. – NGET Norwich to Tilbury (formerly East Anglia Green) CPRSS Bramford to East Anglia Connection Topic Baseline Overviews page B3 (Landscape Section A North) (2) Suffolk County Council’s response to the 2023 ESNZ consultation on Community Benefits for Electricity Transmission Network Infrastructure includes a section on Social Licence and Participatory Placemaking (Appendix B). Research and practical examples of Participatory Placemaking are provided in Acquiring Social Licence for Electricity Transmission, August 2022 – Australian Energy Grid Alliance