Representation by Investin Portsmouth Ltd (Investin Portsmouth Ltd)
- Date submitted
- 18 February 2020
- Submitted by
- Non-statutory organisations
We have reviewed the information provided in relation to the Aquind Interconnector Proposal (Planning Inspectorate Reference EN020022). At this time, we propose that a HOLDING OBJECTION is made until the points below can be formally responded on. This recommendation is based on the premise that N&R are leading on the development of the Fraser Range site and that these works are in close proximity and indeed based on the legal drawings are seeking an easement across land controlled by N&R for the development (predominantly a section of the beach). Given that the application on the Fraser Range Site is still with Portsmouth City Council and yet to be determined and that the Aquind Proposals cross the proposed off site works proposed as part of the Fraser Range development, new access road, redefined car park and access and enhanced SINC. To minimise risk to the Fraser Range project we recommend that the following questions are asked, and suitable responses sought from the Aquind Project Team, given the possible overlap of the developments in terms of works and programme. Key Issues The following highlight the key issues to be addressed: 1. The proposed works require an area of land (easement on the beach) which is in the control of Fraser Range. 2. The new cable crosses the current road/access to Fraser Range which is due to be widened and upgraded with a new footpath/cycle way, which would overlap with the Aquind Compound. 3. The car park area being used for the compound is being altered in terms of access as part of the new road works. 4. The SINC (nature area) next to the car park is due to be enhanced by the Fraser Range proposals as such will be impacted by the compound and operations. Summary of Questions Given these key points we would seek clarification on the following 1 Timing: Can you please confirm the works programme for all aspects, so this can be compared to the Fraser Range Development, given both projects will need to use the same road to service their sites and routes to and from as to be agreed with PCC? 2 Coverage of Compound: The area shown utilises the car park as currently on site. There is concern that additional land may be required and such it could impact the SINC and any works that are being undertaken in support of the Fraser Range project. In addition, the new road, will reduce the current width of the car park and the access junction and boundary fences and could clash with the Aquind works? 3 Vibration: Both projects will inure earth works, boring, piling and open cut, possibly in close proximity to each other, as such is there any risk of vibration impacting the neighbouring sites. Clarification on exact methodology and timing should be requested? 4 Access Road: This is a key point in that subject to the timeline of both projects, the Aquind proposal cross the new road. Even if boring at depth there needs to a coordination of works, as Fraser Range has to widen this road and will also be introducing new utilities along this road at depth. There is a need to make sure works are not conflicted, given the road works will be traditional cut and fill. If for any reason the Aquind works need to break ground prior to the car park, that could impact on access to the site, again this programme and methodology related and requires clarity? 5 Legal Status: We need clarity on future legal status of the easement area on the beach as Fraser Range needs to retain access to the beach and has to tie in the new sea wall with the current arrangements to the west of the site, as such works will need to be carried out in the easement area. As such either before or after the works can Structure/landscaping/drainage etc be considered in that area.? 6 Access to beach: The easement area has to retain public access to the beach, will this be the case? 7 Shape of Easement: Why does easement flare given cable line is at 90 degrees to shore, clarification is required? 8 Method and Delivery of Mitigation: We have an agreement with Natural England and PCC the works required in the SINC and on site, what have Aquind agreed, is it in line with the Fraser Range proposals. From discussions it is suggested that nothing has been discussed or agreed, if this is the case it could delay of the Fraser Range application? 9 Cumulative Assessment: Has the Aquind Project team engaged with Natural England in terms of cumulative effect of their works with ours? This is offered as a high-level list for clarification by the Aquind Tram, it is not exhaustive, but these key issues that need to be considered and agreed prior to removing the holding objection. Indeed, it may be prudent to meet with the Aquind team and discuss the above and any other aspect of their proposals including any legal contracts, this may be a more productive approach than simply exchange of data via emails. We have provided this letter “without prejudice” as a high-level review of the possible impact of the Aquind proposals on the Fraser Range development proposals. As stated, we suggest that you submit a “Holding Objection” to the works until the above can be discussed, agreed or clarified. As with any development there is scope to mitigate impact and reduce abortive works, but this will require liaison with the Aquind project team.