Representation by East Hampshire District Council (East Hampshire District Council)
- Date submitted
- 19 February 2020
- Submitted by
- Local authorities
East Hampshire District Council (EHDC) is a host Authority for part of the project (access and track to the converter building from Broadway Lane) but also has an interest in works relating to the converter station and the impacts on the local environment and residents and through impacts arising during construction. This response sets out a summary of current observations/concerns from a review of the submitted documents to assist the Examining Authority. Detailed comments will emerge through the Council's Local Impact Report and involvement throughout the examination process. The Council has undertaken to work with Aquind to develop a Statement of Common Ground, however, at the time of this Representation, no draft has been seen by the Council. Site selection EHDC has consistently raised its concern at the site selection process for the converter building. If, accepting Lovedean as the connection point in the south of England over Chickerell and Bramley substations, the converter station search area and the initial five options were all in the immediate vicinity of Lovedean and thus, immediately adjacent to the South Downs National Park. There is no evidence that environmental considerations were weighed in this step of the site selection process, which was instead led by technical and commercial issues surrounding transmission losses and wider easements associated with AC cables. There is therefore a step missing in the site selection process between the chosen strategic connection at Lovedean and the 'fine tuning' of the converter building in the immediate vicinity of Lovedean substation, which may have yielded a site away from a nationally designated landscape and which better relates to development / landscape forms. Landscape impacts and design (converter building) The proposed access track from Boundary Lane would dissect fields and is poorly related to landscape features to the detriment of the landscape and setting of a public footpath. It is imperative that a landscaping maintenance and management plan is agreed as part of the DCO Requirements to secure long-term landscaping features. Notwithstanding existing infrastructure at Lovedean substation and associated pylons, the scale, massing and industrial form of the converter station would have a significant harmful impact on the rural landscape character. The design parameters have been the subject of discussions with the Council, however there remains a concern that the buildings would be of a utilitarian design that would not respond positively to landscape context or mitigate or enhance its appearance other than through the use of coloured cladding. No indication of cooling systems to be installed on the exterior together with concern with indicated external staircases and lighting columns / lightning masts. Onshore ecology (specifically Work Areas 1 and 2) It is imperative that sufficient working practices and forward mitigation are in place ahead of all preliminary works. The scheme puts forward minimal biodiversity enhancements. An ecological maintenance and management plan should form part of the DCO Requirements to secure biodiversity enhancements. Noise impacts (converter station) There should be certainty that noise mitigation will achieve the desired effect. It is important noise mitigation measures are incorporated and secured through the DCO Requirements including a mechanism by which noise levels are monitored and further noise mitigation measures incorporated if necessary. Construction Transport Management Plan Residential properties are not listed as ‘sensitive receptors’ – given the nature and type of traffic movements, including reference to night time / abnormal load activity, many dwellings along the construction route are deemed to be sensitive to impacts. It will be imperative that there is effective pro-active communication with the local community in the Lovedean area in respect of work programmes, advance notice of any anticipated issues e.g. road closures and abnormal load deliveries and monitoring/active response to issues raised locally and secured through the Stakeholder Communication Plan. Simon Jenkins Director of Regeneration and Place