Representation by South Downs National Park Authority (South Downs National Park Authority)
- Date submitted
- 12 February 2020
- Submitted by
- Local authorities
The South Downs National Park borders the proposed location of the Convertor Station on three sides and in places it is just 200-300m from the National Park boundary. We would wish to participate in the examination process and will be making a detailed representation at the appropriate time. However, at this stage our main issues are as follows: • National Grid is a Statutory Undertaker and therefore, as per section 62 of the Environment Act 1995, they are required to have regard to the purposes of the National Park in their decision making. It is not clear whether the assessment of alternatives (set out in the Environmental Statement Chapter 2: Consideration of Alternatives) by National Grid when preparing the NGET feasibility study in 2014 took into account the impact of the various options on the National Park. There is only limited information on how that duty has been met and the SDNPA will be seeking further information on this from National Grid. This is a matter that has been raised with the applicant throughout the process. • The location and scale of the Convertor Station causes significant harm to landscape character and impacts on the setting of the National Park as evidenced in the Environmental Statement Chapter 15: Landscape and Visual Amenity study. There are no comparable structures within this predominantly rural landscape. • The lengthy access track (1.2km) will widen the extent of the land impacted on by the development beyond the immediate confines of the site itself. It will cut across historic field boundaries; negatively affect the character of Broadway Lane and run through the centre of fields, contrary to their rural character. • We are currently assessing the landscaping proposals and will wish to raise detailed points at the relevant stage. The proposals rely on a combination of existing woodland, groups of trees and hedgerows supplemented by additional planting. The Arboricultural Survey is not comprehensive and no account appears to have been taken of the likely loss of ash trees from the landscape. Ash forms a large part of the existing tree cover in the location and its loss may have significant impacts on the visibility of the proposed convertor station in the long term. We will be seeking a proposal which adds value and is worthy of a nationally significant infrastructure project located adjacent to a National Park. • Although the SDNPA has raised concerns in relation to landscape impact and the proposed mitigation we are broadly content with the design parameters of the Convertor Station itself. However, we would like to question what steps have been taken to reduce the embodied carbon of the construction.