PLANNING ACT 2008 (AS AMENDED) INFRASTRUCTURE PLANNING (EXAMINATION PROCEDURE) RULES 2010 (AS AMENDED) SUBJECT: TRITON KNOLL ELECTRICAL SYSTEM APPLICANT: TRITON KNOLL OFFSHORE WIND FARM LTD LOCATION: ANDERBY CREEK TO BICKER FEN SUMMARY OF WRITTEN REPRESENTATIONS INTERESTED PARTY: EAST LINDSEY DISTRICT COUNCIL (ELDC) TEDDER HALL MANBY PARK MANBY, LOUTH LINCOLNSHIRE LN11 8UP PLANNING INSPECTORATE REF:- EN020019 OUR REF: TRIT-0009 DATE: 21st SEPTEMBER 2015 1 1.0 INTRODUCTION 1.1 Set out below are the written representations of East Lindsey District Council. Where appropriate, reference is made to the Local Impact Report and to avoid a lengthy statement, there are appendices. The appendices comprise the relevant policies (A4,A5 and C15) of the extant Local Plan together with explanatory paragraphs, extracts from the Council’s Draft Core Strategy which contains policies relating to Landscape, Heritage and Renewable Energy, and extracts from the Council’s Landscape Character Assessment produced by Messrs Ecus and which has been adopted as guidance in the decision making process. The route passes through 5 character areas, namely K1, J1, I1, B1 and A1. 1.2 National Policy Statements EN1 and EN3 are particularly relevant, but also material to this proposal is the NPPF and the suite of Policy Guidance. Underpinning East Lindsey’s concerns is paragraph 5.9.18 of EN1. 1.3 In terms of the NPPF, East Lindsey draw the Panel’s attention in particular to paragraphs 17 (Core Principles), 109, 114, 116, and 123. 1.4 In the Council’s LIR it was made clear that these written representations would concentrate on four issues. They are; a) Landscape impact (including background to site selection) b) Tourism impact c) Project specific impact i) Coastal grazing marsh project ii) Country Park d) Sibsey Northside Memorial 1.9 Following on from these points, reference will be made to the Viking Link, a (relatively) recent addition to the equation, being an interconnector between Denmark and the UK. 2.0 LANDSCAPE IMPACT 2 2.1 East Lindsey values its landscape character and appearance very highly. 2.2 The cable route itself passes through a considerable part of the central and southern part of the district, and crosses 5 landscape character areas. Whilst there will be harmful impacts during construction, from both the physical line itself and the trappings of construction (compounds, haul roads, hedge removal etc) it is felt that the long term impacts of the scheme in Landscape terms would rest with those permanent features created as part of the development. Landfall site at Anderby Creek 2.3 Whilst in landscape terms works at the landfall site will have no significant harmful impact once completed, the construction period will present issues. The quality of the landscape character and appearance is what draws people to Anderby Creek. Its sense of isolation and ‘getting away from it all’. It lies within the area categorised as K1 – Donna Nook to Gibralter Point Naturalistic Coast. 2.4 In the main statement I have highlighted one or two sentences within the section on Landscape Sensitivity which are particularly apposite for this site. The timescale for the works is indicated as being 13.5 months. There is the potential for noise, artificial lighting, traffic and general activity in an area noted, indeed prized, as part of its high sensitivity to change, for its tranquillity. 2.5 East Lindsey District Council would ask that the Panel seek assurances from the applicants that the 13.5 month indication is a maximum and that due care and empathy be shown during construction to both those who live near to and those who visit the Anderby Creek area. Intermediate Electrical Compound at Marsh Lane Orby 2.6 The electrical compound will have a permanently harmful impact upon the landscape character and appearance of this area. It introduces an alien, industrial feature into an otherwise rural setting. 3 2.7 It lies within the area categorised as J1 – Tetney Lock to Skegness Coastal Outmarsh in the LCA. In the main proof I quote from the section on Landscape sensitivity in the Council’s LCA, and highlight matters of particular relevance. 2.8 When the applicants were first searching for a site for the intermediate compound (IEC), the Orby area was on their short list. At that time, East Lindsey objected to the chosen sites as they comprised large alien structures in isolated rural locations, that, because of the terrain, were open to view from distance, thus magnifying the adverse impact. 2.9 The applicants came back with a proposal to locate the IEC on an allocated industrial site that was dormant on Wainfleet Road in Skegness (The Brown Zone). I explain why the site was dismissed in the main statement.. 2.10 The applicants moved their search away from the Brown Zone and returned to their originally preferred search area, Marsh Lane, Orby. 2.11 The IEC will contain Above Ground Electrical Infrastructure (AGEI) including a building housing switchgear, busbars, capacitors, reactors, reactive power compensation equipment, filters, cooling equipment, control and welfare buildings and lightning protection rods (if required). A permanent security fence will surround the compound. 2.12 The AGEI will have a total area of up to up to 1.7 ha (4.1 acres) with a.maximum building height of up to 13 m. This maximum height does not include raising for flood protection. Equipment within the compound will be raised by up to 2.1 m to ensure adequate flood protection. This means a total height above existing ground level in the region of 15m. 2.13 There will be a landscaping buffer around the AGEI with an anticipated width of up to 40 m. 2.14 There were 2 particular areas of concern in relation to the IEC. 4 Traffic at Orby 2.15 The applicants have acknowledged that traffic if routed through Orby village would cause harm. As a result, the development proposes using a haul road from the A158 to the south, thus avoiding the village. Landscape and visual impact of IEC 2.16 There is no doubt that the IEC will make a major change to the current rural scene. 2.17 The key aspect of the Intermediate Electrical Compound which has the potential to give rise to landscape effects is the presence and height of relatively complex electrical infrastructure. 2.18 Bearing in mind that there is little that can be done to mitigate the scale of the equipment or the raising of the ground level, the principal mitigation works constitute landscaping. This raises 2 issues. The first is that this is a very open landscape with little tree cover. That which there is, tends to be that which either has been left to act as wind break or that which has been planted to screen development. In so doing it has the tendency to draw the eye and draw attention to what is being screened. The second point, and this is acknowledged by the applicants, is that any mitigation planting will take 15 years to become fully effective. The life of the wind farm is 25 years. 3.0 TOURISM IMPACT 3.1 East Lindsey District Council is extremely concerned that there should be no interference with the tourism industry which is the life blood of the coastal communities. 3.2 Reference has already been made to impacts of the construction phase on the Coastal Conservation Area, Coastal Country Park, the attractiveness of Anderby Creek and the Coastal Grazing Marsh Project. Those elements are re-emphasised in any consideration of overall tourism impact. 5 3.3 East Lindsey are pleased that the developers have listened to traffic concerns. These aspects need to be spelt out in the documentation and the phasing plan agreed. 4.0 PROJECT SPECIFIC IMPACT (CABLE ROUTE) Coastal Grazing Marsh Project and Country Park 4.1 East Lindsey District as part of its commitment to the local economy and its objective to both broaden visitor appeal and extend the visitor season, supports the aims and objectives of both the Country Park and the Coastal Grazing Marsh Project. Whilst East Lindsey District is not the prime mover in either of these initiatives, they wish to lend their weight to concerns that have been expressed at pre-meetings and in writing. The Country Park is lent policy support by virtue of Policy C15 of the extant East Lindsey Local Plan 4.2 In the same way that the landfall site is affected, there will be significant visual effects along the whole of the cable route for the whole of the construction period. The cable route passes through the Coastal Country Park and the areas that have been flagged for the Coastal Grazing Marsh Project. Again, ELDC will require reassurance and guarantees that adequate mitigation is contained within the scheme to ensure that the purposes of the Country Park and the aims, aspirations and objectives of the Grazing Marsh Project are not prejudiced or diminished. 5.0 SIBSEY NORTHSIDE MEMORIAL 5.1 It came to our attention, quite late in the day, the circumstances of the crash which is marked by the Sibsey Northside Memorial. It is hoped that representatives of the Memorial Trust will be able to attend the Panel Hearing and/or make written representations. 6 5.2 What is explained in the main statement can only be a snapshot of their concerns, but is set down for the Panel to ensure that they are cognisant of the issue and of East Lindsey’s support for the Trust’s position. 5.3 East Lindsey is of the view that a section of the cable route should be diligently searched, with the County archaeologist in attendance, prior to any major trenching works being undertaken.