Representation by Vattenfall Wind Power Ltd (Vattenfall Wind Power Ltd)
- Date submitted
- 17 June 2021
- Submitted by
- Members of the public/businesses
Vattenfall Wind Power Limited (VWPL) welcomes the chance to respond to Highways England’s (HE) A47 North Tuddenham to Easton application. VWPL is currently developing the Norfolk Vanguard and Norfolk Boreas offshore windfarm projects. Each project has been subject to a separate DCO examination and both are currently awaiting the outcome of separate determination processes, expected toward the end of 2021. This response reflects the position of both projects (collectively referred to as the Norfolk Projects). The Norfolk Projects rely on the A47 corridor for the transport of materials and personnel to the landfall, onshore cable route, onshore substations and National Grid extension works. Construction is anticipated to commence in 2022 for Norfolk Vanguard. The most intense construction activity is forecast to occur between 2022 and the end of 2023, during this period, the project’s A47 traffic demand would peak at 693 daily movements of which 312 would be HGVs. Construction is anticipated to commence in 2023 for Norfolk Boreas (Scenario 2 - should Norfolk Vanguard not proceed) or 2027 (Scenario 1 – should Norfolk Vanguard proceed). The most intense construction activity is forecast to occur between 2023 (or 2026 for Scenario 1) and the end of 2024 (or 2027 for Scenario 1), during this period, the project’s A47 traffic demand would peak at 691 (or 181 for Scenario 1) daily movements, of which 291 (or 70 for Scenario 1) would be HGVs The North Tuddenham to Easton scheme has a construction duration of 23 months, which (assuming construction commencement 2022/23) has the potential for cumulative impacts with the Norfolk Projects associated with HE’s proposed temporary traffic management proposals and construction traffic demand. VWPL has regularly engaged with HE during the development of the Norfolk Projects culminating with agreement on the approach to managing cumulative impacts as follows: “To manage potential cumulative traffic impacts, it has been agreed with HE that the management of the potential cumulative impacts can be addressed in the final submitted Traffic Management Plan (post consent) when there is greater certainty with regard to RIS scheme construction traffic data. VWPL commits to engage with HE to establish opportunities to co-ordinate activities and avoid significant impacts resulting from cumulative peak traffic is captured in the OCoCP (document reference 8.1) through the development of a Communication Plan.” VWPL would expect this regular engagement to continue with HE throughout the development and implementation lifecycle of the A47 North Tuddenham to Easton scheme, and be secured within the respective parties’ communication plans. VWPL has reviewed the application documents and draw attention to the following specific matters: 6.1 Environmental Statement Chapter 15 – Cumulative Effects Assessment (APP- 054) Section 15.5 identifies The Norfolk Projects and contains an assessment of cumulative effects. With regard to traffic and transport and the assessment concludes: “Due to the temporary nature of the construction impacts and implementation of traffic management for both the Proposed Scheme and different projects, the potential cumulative effects identified on traffic and transport are not considered to be significant.” VWPL agrees with this statement in principle but would suggest that the implementation of communication plans that maximise opportunities to co-ordinate roadworks and manage peak construction traffic demand be committed to. No other potential cumulative impacts are identified, which aligns with VWPL’s assessments. 7.5 Outline Traffic Management Plan (APP – 144) The Outline Traffic Management Plan identifies that “Full carriageway closures will be used during the duration of the project from early works up to completion”. This could potentially lead to significant delays to the A47 corridor, which could be exacerbated by the Norfolk Projects’ construction traffic. In addition, the requirement for full overnight closures are identified (between 20:00 – 06:00) the majority of which would be carried out during the period from July 2024 to November 2024. Whilst it is noted that the majority of closures fall outside of the peak traffic demand for the Norfolk Projects, and the timings would only affect early arrivals to site, nevertheless, there is the potential for disruption to construction traffic associated with the Norfolk Projects being diverted off the A47, potentially inducing delays of over an hour in journey time. There is also the need to consider additional management processes to ensure diverted construction traffic does not utilise inappropriate alternative local routes. However, VWPL consider that any potential cumulative impacts between the A47 North Tuddenham to Easton scheme and the Norfolk Projects would be mitigated by regular engagement and alignment of the respective traffic management plans. VWPL seek formal engagement with HE to gain a better understanding of the A47 North Tuddenham to Easton roadworks proposals and to jointly formulate traffic management plans to minimise disruption to the travelling public, local communities and the respective project’s construction programmes. VWPL would seek to capture an agreed position on these items through a Statement of Common Ground.