Representation by Robin Jefferies (Robin Jefferies)
- Date submitted
- 17 February 2020
- Submitted by
- Members of the public/businesses
This Relevant Representation is submitted on behalf of Robin Jefferies who wishes to be registered as an Interested Party for the forthcoming examination of the AQUIND Interconnector Development Consent Order ("the DCO") application submitted by AQUIND Limited ("AQUIND"). Mr Jefferies is the freehold owner of Mill View Farm, The Farm is located on the proposed site of the Converter Station (Section 1) and our client opposes the DCO on the following grounds: 1. Compulsory Acquisition The compulsory acquisition element of the DCO will affect a total area measuring 12,633 square metres. 9,495 square metres are to be compulsorily purchased (Plot 1-29) and 3,138 square metres will be subject to permanent landscaping rights (Plots 1-26 and 1-30). The 8 acre field in Plot 1-29 ("the Field") will be reduced by 2.5 acres, a reduction of over 30%. This will significantly interfere with our client's activities on this land. The Field is used in connection with stabling and is let out to a tenant who runs horse livery stable. With the loss of over 30% the remaining size of the Field will be too small to enable his tenant to continue to run the livery business there and will need to vacate, thus denying our client with a source of income. The Field will essentially become sterilised as it would be too small to rent out for any other form of agricultural use. Any residential development potential would also be negated due to the close proximity of the Convertor Station and the direct views that any such properties would have over it. The screening proposed on Plot 1-29 will not mature for many years and in any event would not completely screen the 26 metre high building. AQUIND have also failed to demonstrate that the extent of the compulsory acquisition is necessary and proportionate, taking only what is required. AQUIND have failed to justify the need for permanent landscaping rights over the hedgerows in Plots 1-26 and 1-30, when such hedgerows run perpendicular to the Convertor Station and offer no screening value. AQUIND have failed to demonstrate that all reasonable alternatives to compulsory acquisition have been explored. The disproportionate harm and loss to our client's interests significantly outweighs any public benefit. Accordingly, AQUIND's proposed interference with our client's rights is not justified having regard to Article 1 of the First Protocol to the ECHR and does not meet the tests for compulsory acquisition. Our client is still willing to work with AQUIND to achieve agreement on reasonable terms to the satisfaction of both parties. However, if agreement is not reached Mr Jefferies wishes to maintain his objection. Our client reserves the right to make further detailed representations during the Examination stage of the DCO application.