Dover District Council Thanet District Council

From: April.Newing@kent.gov.uk To: Richborough Cc: [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Subject: Richborough Connection Project Deadline 2 - PINS Reference: EN020017 Joint Councils Local Impact Report Submission (14 July 2016) Date: 14 July 2016 16:24:08 Attachments: JOINT COUNCIL LOCAL IMPACT REPORT (14 July 2016).pdf Importance: High

Dear Sir/Madam,

Further to the Rule 8 letter dated 16 June 2016 received from the Planning Inspectorate (as the Examining Authority) regarding the Richborough Connection project, please find attached the Joint Councils Local Impact Report (14 July 2016).

Please note that this document has been submitted on behalf of the following Local Planning Authorities: · Kent County Council · Canterbury City Council · Dover District Council · Thanet District Council

If you have any questions concerning the attached document, please do not hesitate to contact me.

Kindest regards,

P Please consider the environment before printing this email

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Proposed National Grid (Richborough Connection Project) Development Consent Order

PINS Reference: EN020017

Joint Councils Local Impact Report

Thursday 14th July 2016

CONTENTS

Abbreviations ...... 2 1. Introduction ...... 3 1.1. Site Description and Surroundings ...... 3 1.2. Summary of the Proposed Development ...... 5 1.3. Proposed Pylon Route Options ...... 6 1.4. Detailed Design ...... 6 2. Consenting Regime – Nationally Significant Infrastructure Project ...... 7 2.1. Assessment of the NSIP ...... 7 3. Pre-application process ...... 8 3.1. Statement of Common Ground ...... 8 3.2. Assessment of Cumulative Effects of Other Projects ...... 8 4. Policy Context ...... 9 4.1. National Planning Policy Framework/Planning Practice Guidance ...... 9 4.2. Statutory Development Plans ...... 9 5. Relevant Development Proposals ...... 10 5.1. Dover District Council ...... 10 5.2. Thanet District Council ...... 12 5.3. Canterbury City Council ...... 13 6. Needs and Benefits ...... 13 7. The Likely Significant Effects of the Proposed Development ...... 14 7.1. Landscape and Visual Impacts ...... 15 7.2. Historic Environment ...... 15 7.3. Archaeology ...... 15 7.4. Biodiversity ...... 16 7.5. Highway Impacts ...... 17 7.6. Public Rights of Way ...... 18 7.7. Noise and Vibration ...... 19 7.8. Air Quality ...... 20 7.9. Water Environment ...... 20 7.10. Waste Management ...... 21 7.11. Geology, Soils and agricultural land ...... 21 7.12. Socio-economic Impacts ...... 21 7.13. Cumulative Impacts...... 22 8. Conclusion ...... 22 1

Abbreviations

Abbreviation Term CCC Canterbury City Council CEMP Construction Environmental Management Plan CTMP Construction Traffic Management Plan DCLG Department for Communities and Local Government DCO Development Consent Order DDC Dover District Council EA Environment Agency EIA Environment Impact Assessment ES Environmental Statement GW Gigawatt HVDC High Voltage Direct Current KCC Kent County Council km Kilometre kV Kilovolt LIR Local Impact Report MW Megawatt m Metre NG National Grid NPPF National Planning Policy Framework NPS National Policy Statement NSIP Nationally Significant Infrastructure Project NVMP Noise and Vibration Management Plan PINS Planning Inspectorate PPG Planning Practice Guidance PROW Public Rights of Way SEW South East Water SoCG Statement of Common Ground SSSI Site of Special Scientific Interest TDC Thanet District Council WHS World Heritage Site WRMP Water Resources Management Plan

1. Introduction

1.0.1. This is a Joint Council Local Impact Report (LIR) that has been prepared by Kent County Council (KCC), Canterbury City Council (CCC), Dover District Council (DDC) and Thanet District Council (TDC) - “the Joint Councils” to the Planning Inspectorate (PINS) regarding National Grid’s application for a Development Consent Order (DCO) in relation to the Richborough Connection project.

1.0.2. The Joint Councils are “interested parties” under the Planning Act 2008 with respect to the project and are planning authorities in relation to the proposed works. Additionally, the Joint Councils have a number of other statutory responsibilities concerning housing and environmental health, and discretionary powers regarding well-being. The Joint Councils will also be responsible for Discharging Requirements and become the Enforcement authorities for the scheme.

1.0.3. The Joint Councils have considered the purpose of LIRs as set out in Section 60(3) of the Planning Act 2008 (as amended), DCLG’s Guidance for the examination of applications for development consent and PINS Advice Note One, Local Impact Reports, in preparing this LIR. Therefore, this document sets out details of the likely impacts of the proposed development on the local authorities’ administrative areas. PINS advises that local authorities should cover any topics they consider relevant to the impact of the proposed development and should be used to fully and robustly report their existing local knowledge and evidence on local issues. It is recommended that the LIR draws on existing local knowledge and experience. Examples may include local evidence of flooding; local social or economic issues; and local knowledge of travel patterns to community facilities. Additionally, as recommended by guidance, this LIR includes a statement of positive, neutral and negative local impacts however does not contain a balancing exercise between positives and negatives.

1.0.4. Unless otherwise expressed, views in this report reflect the views of the Joint Councils. Written Representations have been separately prepared and individually submitted by each relevant authority, and where necessary have been cross- referenced to this Local Impact Report.

1.1. Site Description and Surroundings

1.1.1. Within the administration boundaries of DDC, CCC and TDC the land uses that are in, and adjacent to the Order limits, comprise predominantly of rural land in agricultural use, with marsh land towards the eastern end of the route near Richborough. The only urban areas present are at the western end of the route, which is located on the north eastern outskirts of the administration area of CCC. At Richborough there are several industrial and commercial land uses present in the wider area including solar farms, Sewage Treatment Works (STW) and a household waste recycling centre. Residential development in the surrounding area includes Canterbury, Broad Oak, Sturry, Westbere, Hersden, Hoath, Upstreet, Chislet, (falling within CCC’s administrative area) and Sarre, Monkton and Minster (falling within TDC’s administrative area).

1.1.2. Major access routes within and around the Order limits include the A28, which provides access between Canterbury and Margate (and is crossed by both the proposed 400kV and the existing 132kV PX route). The A253, which is located to the north and provides access between Ramsgate and the A28 at Sarre. To the east is the A256, which provides access between Ramsgate and Sandwich.

1.1.3. Both the proposed 400kV and existing 132kV PX route cross the A291 at the western end of the route, which provides access between the A299 to the north and the A28 to the south. Several more minor roads are located within and around the Order limits. The Canterbury-Ramsgate railway runs broadly parallel to the proposed 400kV overhead line.

1.1.4. The only national environmental designation that falls within the Order limits is West Blean and Thornden Woods Site of Special Scientific Interest (SSSI) (known as Lynne Wood – only part of this SSSI falls within the Order limits). There are also several areas of ancient woodland within the Order limits (Shelford/Beecham Woods (this is Lynne Wood), Den Grove Wood and Kemberland Wood and Park Rough).

1.1.5. In the wider area outside the Order limits there are several internationally important statutory nature conservation designations: Thanet Coast and Sandwich Bay Ramsar and Special Protection Area (SPA) (approximately 0.18km north east of the Order limits); Sandwich Bay Special Area of Conservation (SAC) (approximately 0.18km north east of the Order limits); Stodmarsh Ramsar, SPA and SAC (approximately 0.45km south of the Order limits); and Blean Complex SAC (approximately 0.54km north of the Order limits), all of which also contain National Nature Reserves.

1.1.6. There are also several areas designated as SSSIs within the wider area which are nationally important nature conservation designations. These include Chequers Wood and Old Park SSSI (approximately 0.76km south the Order limits); West Blean and Thornden Woods SSSI (to the west of and north of Broad Oak) part of which (Lynne Wood) falls within the Order limits; East Blean Woods SSSI (approximately 0.15km north of the Order limits part of which is also within Blean Complex SAC); Stodmarsh SSSI (which falls within Stodmarsh SAC, SPA and Ramsar and is approximately 0.45km south of the Order limits); and Sandwich Bay and Hacklinge Marshes SSSI (approximately 0.01km north east of the Order limits), part of which also falls within Sandwich Bay SAC, SPA and Ramsar.

1.1.7. In terms of the historic environment, the nearest scheduled monuments are an Anglo- Saxon cemetery at Sarre (approximately 260m north of the Order limits) and a Saxon shore fort, Roman port and other remains at Richborough (approximately 900m south of the Order limits). There are also scheduled monuments at Minster (approximately 1.4km north) and Monkton (approximately 1.3km north) and several within Canterbury City Centre. In addition, Canterbury also contains a World Heritage Site (WHS) (Canterbury Cathedral, St Augustine’s Abbey and St Michaels Church approximately 840m south of the Order limits at the closest point). The WHS includes heritage assets which are also protected under other designations including a number of listed buildings and scheduled monuments.

1.1.8. There are numerous Listed Buildings in the vicinity of the Order limits, the closest comprising the Grade II listed Rushbourne Manor which is 30m from the Order limits 4

(maintenance access). The Grade II listed Tile Lodge Farmhouse and Chislet Park are 35m, and 40m respectively from the Order limits, as well as several other listed buildings at a greater distance than this from the Order limits.

1.1.9. There are no national landscape designations within the Order limits or in the immediate vicinity. The nearest such designation is the Kent Downs AONB approximately 5km south of the southernmost end of the Order limits.

1.2. Summary of the Proposed Development

1.2.1. National Grid Electricity Transmission plc (“National Grid”) has submitted an application to the Secretary of State for a DCO for the Richborough Connection project proposing a new high voltage electricity connection between Richborough and Canterbury. The proposed development would authorise works to the national electricity transmission system between Richborough and Canterbury and is required to provide sufficient transmission capacity to enable the connection of the new electricity project in the region known as Nemo Link®.

1.2.2. The Nemo Link® was subject to duplicate planning applications submitted to both TDC and DDC, due to its cross boundary siting. The application comprised a hybrid application which granted full planning permission for the installation of 3.1km underground high voltage direct current (HVDC) cable from Pegwell Bay to former Richborough Power Station, being part of a 130km HVDC electrical interconnector with an approximate capacity of 1000 megawatts (MW) extending from Zebrugge (Belgium) to the former Richborough Power Station site and outline consent planning consent for the erection of converter station building (max height 30.8m), substation building (max height 15m) outdoor electrical equipment for substation (max height 12.7m) and for converter station (max height 11.8m), underground cables from substation and converter station and construction of internal roads, including access and landscaping, together with associated temporary construction compounds, approved on 19th December 2013 by DDC and by TDC on 19th December 2013.

1.2.3. The proposed development falls within the administrative boundaries of CCC, DDC, KCC and TDC and consists of the following principal components:

 A new 400kV overhead line between Richborough and Canterbury North Substations (to be known as the PC route). This would be approximately 20km long and would be built using 45 standard lattice pylons and 15 low height lattice pylons (60 pylons in total).

 A permanent diversion of an existing lower voltage (132kV) overhead line (known as the PY route) to enable the new 400kV overhead line to be constructed above the existing lower voltage overhead line. This would be done by building 6 new pylons, 4 of which are of a different height so the new 400kV overhead line can then be built.

 Three temporary diversions of another existing lower voltage (132kV) overhead line (known as the PX route). The PX route has to remain in operation (energised) whilst the new 400kV overhead line is being built, so in order to maintain local electricity supplies, three temporary diversions of the existing PX 5

route would be needed where the new 400kV overhead line crosses over it. This would be done by transferring the PX route onto wooden poles so that the new 400kV overhead line can be built.

 The removal of 20.6km (77 pylons) of existing lower voltage (132kV) overhead line, the PX route (and its temporary diversions) which runs between Richborough 132kV Substation and Canterbury South 132kV Substation.

 Other works, for example, temporary access roads to reach pylon construction and demolition areas, bridge structures, highway works, construction compounds, protective scaffold structures, pylon work sites and ancillary works.

1.3. Proposed Pylon Route Options

1.3.1. In June 2013 National Grid published a Strategic Options Report for consultation which considered 6 routes options to provide a high voltage (400kV) connection from Richborough Substation to the existing high voltage electricity network at different substations in the region. In terms of the onshore connections, the Canterbury North option was the shortest of 3 options and was considered to have the least environmental, landscape and visual effect and costs and was therefore deemed the preferred option.

1.3.2. Additionally, National Grid consulted on a Route Corridor Study (June 2013) which considered a north and south corridor between Richborough and Canterbury. As part of this, the environmental appraisal identified that the north corridor, combined with the removal of the exiting lower voltage overhead line (Scenario 2) was likely to have the least environmental effects.

1.3.3. In November 2014 National Grid announced that its decision to take forward the north corridor option with Sub Option B as its preferred option and confirmed the removal of the existing lower voltage overhead line within the corridor in order to provide a connection between Richborough and Canterbury.

1.4. Detailed Design

1.4.1. Following a public consultation on the Connection Options Report (Document 7.7 [APP-133]) in May 2014, changes regarding the draft route and design were raised, specifically in relation to the overhead line route, individual pylon locations and access routes. A separate pylon study was undertaken reviewing the following three types of pylons: the standard lattice pylon, an alternative low height lattice pylon and the newer T-pylon. This approach considered the technical, cost and environmental factors for each pylon type within each section of the route.

1.4.2. A standard lattice pylon is the preferred option from PC1 to PC42 and a low height lattice pylon from PC43 to PC61. The final pylon (PC62), before the overhead line reaches Richborough Substation is proposed to be a standard lattice pylon.

1.4.3. Standard lattice pylons are typically 46.5m in height and approximately 17m at their widest point (cross arms). Low height lattice pylons are typically 35m in height with a width of approximately 29m. For the Richborough Connection project, the average 6

height of the standard lattice pylons is approximately 50m compared with 41m for the low height lattice.

2. Consenting Regime – Nationally Significant Infrastructure Project

2.0.1. The project is a Nationally Significant Infrastructure Project (NSIP), as defined by the Planning Act 2008 (the Act) and the Planning Act 2008 (Nationally Significant Infrastructure Projects) (Electric Lines) Order 2013, as it involves the installation of an electric line above ground of more than 2km, which will operate at 400kV. As a NSIP it requires the grant of development consent by the making of a DCO under the Act.

2.0.2. National Grid submitted an application under section 37 of the Planning Act 2008 to PINS for an order granting development consent for the Richborough Connection project to the Planning Inspectorate on 14 January 2016.

2.0.3. PINS is responsible for operating the planning process for NSIPs and as an Examining Authority, will examine the application and make a recommendation to the Secretary of State. The Secretary of State will then determine whether the application is in accordance with any relevant national policy statement unless, and among other matters, whether the adverse impact of the development would outweigh its benefits.

2.1. Assessment of the NSIP

2.1.1. In terms of assessing the application for the NSIP, this has to be determined in accordance with the decision-making framework as set out in the Planning Act 2008, relevant national policy statements for major infrastructure, as well as any other matters that are considered both important and relevant (which may include the National Planning Policy Framework (NPPF)). National Policy Statements (NPS) form part of the overall framework of national planning policy, and are material considerations in decisions on planning applications.

2.1.2. In this case, the relevant NPSs are the Overarching National Policy Statement for Energy (EN-1) and the National Policy Statement for Electricity Networks Infrastructure (EN-5). EN-1 sets out national policy for energy infrastructure and is relevant to the proposed development.

2.1.3. EN-1 states that it is critical that the UK continues to have secure and reliable supplies of electricity as it makes the transition to a low carbon economy. EN-5 is the technology-specific NPS for electricity networks and overhead lines, and sets out that PINS should start its assessment of applications for DCOs covered by EN-5 on the basis that need has been demonstrated.

2.1.4. The Richborough Connection project is supported by the Overarching National Policy Statement for Energy (EN-1) and the National Policy Statement for Electricity Networks Infrastructure (EN-5) and the principle of development is therefore considered to be acceptable.

2.1.5. As a NSIP, PINS advises that “a necessary and proportionate degree of flexibility often needs to be incorporated into the design of proposed development so that 7

unforeseen issues, that are encountered after a development has been consented, can be dealt with”.

2.1.6. Owing to the fact that the Richborough Connection project is a ‘Project of Common Interest’ due to its role in providing a connection between the permitted Nemo Link and the existing UK National electricity transmission network it also need to be assessed against TEN-E Regulation (guidelines for trans-European energy infrastructure EU 347/2013).

3. Pre-application process

3.0.1. The Joint Councils have engaged constructively with National Grid throughout the development of the project via a Planning Performance Agreement. The Joint Councils have fully responded to previous consultation as part of the formal consultation process and have been involved in meetings with National Grid to discuss and agree the Statement of Common Ground (SoCG, Document 8.4.6) and narrow down a list of outstanding matters. National Grid has made positive efforts throughout the process to endeavour to address any concerns raised by the Joint Councils and this has greatly assisted with reducing the residual impacts that would need to be addressed in order to make the proposal acceptable in planning terms. Where there are any issues that are still outstanding, they have been identified in the Council’s Written Representations.

3.1. Statement of Common Ground

3.1.1. The extent of agreement reached between the Joint Councils and National Grid on the impacts of the proposed development is set out in SoCG submitted on the same day as this LIR. In this LIR, the Joint Councils have sought to constructively identify where further information and proposals are needed, to ensure that the adverse local impacts of Richborough Connection project are adequately mitigated. The Joint Councils will continue to actively engage with National Grid prior to and during the examination process.

3.2. Assessment of Cumulative Effects of Other Projects

3.2.1. The Joint Councils have discussed and agreed with National Grid a list of major projects in the vicinity of the Richborough Connection project. The landscape cumulative impact of the Richborough Connection project and other projects has been assessed by National Grid in Table 16.2 (page 1038) of the Environmental Statement (ES) Chapters 11-16 (Document 5.2 [APP-030]).

3.2.2. Since the ES was submitted to PINS the following three major planning applications have been submitted to the relevant authorities but have not yet determined:

 Planning reference DOV/16/00254 - An application for the erection of a 305m high / 2.5m wide guyed communication mast (with 5no. 9m wide anti-twist frames at intervals above 140m) with 6no. 3.7m diameter dish antenna, 206sqm base compound enclosing associated equipment cabins and electric meter cabinets up to 2.5m in height (4.2m above ground level), 9no. guy stay compounds, stone access track, hard and soft landscaping and associated works, on land to the

North of Kings End Farm, Richborough, Sandwich, CT13 9JH has been submitted to DDC;

 Planning reference DOV/16/00044 - An application for the erection of a guyed steel lattice mast (322m in height) with 9 anchor points, installation of telecommunications and associated equipment, site compound, secure fencing, single storey equipment structure, access track, ground mounted solar panels within compound and associated works, on land to the south of the site of the former Richborough Power Station, Ramsgate Road, Sandwich, CT13 9NL has been submitted to DDC; and

 Planning reference TH/16/0550 - A hybrid planning application regarding the comprehensive redevelopment of the former Manston Airport site comprising up to 2,500 residential units, 85,000 sq.m of employment floorspace, a new local centre, a hotel, 2 primary schools and other non-residential institutions, open space/landscaping, car parking and associated infrastructure, on land at Manston Airport, Manston Court Road, Ramsgate has been submitted to TDC.

Further details of these schemes are set out in the relevant development proposals section below.

4. Policy Context

4.1. National Planning Policy Framework/Planning Practice Guidance

4.1.1. The NPPF is the Government’s planning policies for England and sets out how these are expected to be applied. The weight of the NPPF relating to NSIPs is clarified in paragraph 3 of the NPPF:

“This Framework does not contain specific policies for nationally significant infrastructure projects for which particular considerations apply. These are determined in accordance with the decision-making framework set out in the Planning Act 2008 and relevant national policy statements for major infrastructure, as well as any other matters that are considered both important and relevant (which may include the National Planning Policy Framework). National policy statements form part of the overall framework of national planning policy, and are a material consideration in decisions in planning applications.”

4.1.2. Although the NPPF does not contain specific policies for NSIPs, it states that local planning authorities should work with other authorities and providers to take account of the need for strategic infrastructure, including nationally significant infrastructure within their administrative areas. The NPPF is therefore a relevant consideration in decision making NSIPs. The Government’s Planning Practice Guidance (PPG) supplements the NPPF and must also be taken into consideration.

4.2. Statutory Development Plans

4.2.1. The Joint Councils concur with National Grid’s assessment of the proposed development against the following relevant adopted and saved local planning policies

as set out in Section 7 and Appendix C in Volume 7 of the Planning Statement (Document 7.1 [APP-127]):

Kent Minerals and Waste Local Plan 2013 -2030 May 2016 Kent County Kent Environment Strategy March 2016 Council Kent Downs Management Plan 2014-2019 April 2014 Kent Local Flood Risk Management Strategy June 2013

Draft Canterbury District Local Plan (Potential Main April 2016 Canterbury Modifications)1 City Council Saved Policies of the Canterbury District Local Plan 2006 2009

Dover Dover District Land Allocations Local Plan January 2015 District Dover District Core Strategy February 2010 Council Dover District Council Local Plan Saved Policies 2002

Thanet Draft Thanet Local Plan to 2031 (Preferred Options January 2015 District version) Council Thanet Local Plan 2006 Saved Policies 2009

5. Relevant Development Proposals

5.1. Dover District Council

5.1.1. The two mast proposals referred to in the planning history section above have been validated by DDC.

Vigilant Global

5.1.2. It is noted that reference is made to one of the mast proposals, proposal by Vigilant Global, (DOV/16/00044) in the ES (Document 5.2, Chapter 5, Table 5.2 Cumulative effects assessment: developments scoped-in [APP-029] and Chapter 16, Table 16.2 Developments considered within the assessment of inter-project cumulative effects, Development ID H [APP-030]). At the time of submission of the ES, a planning application had not yet been received, but the proposal had been subject to pre- application discussions with officers and screened by DDC as EIA development under the Town and Country Planning Environmental Impact Assessment Regulations 2011 (as amended 2015). Amended plans and additional information, including information pursuant to a Regulation 22 request under the EIA Regulations was received on 9th June 2016 and the application has been revalidated and is currently out for re-consultation and publicity.

5.1.3. The communications mast is proposed to be located to the south of the River Stour and to the northwest of PC58, PC59 and west of PC60 shown on National Grid drawing reference PDD-21497-2-OHL-1138. Access to the mast site during construction is proposed utilising one of two potential options: using the new temporary bridge over the River Stour included in the Draft DCO (as detailed at figure

1 Stage two of the Examination into the Canterbury District Local Plan is due to take place in summer 2016, with hearings in July and September. After the hearings have concluded, the Inspector will decide on the main modifications that he considers necessary for the plan to be sound or legally compliant. The final schedule of main modifications will be subject to public consultation and the comments received taken into account by the Inspector in his final report on the Local Plan.

3.12 in Document 5.3.3 [APP-064] and section 3.5 in Document 5.1 [APP-028]) or a new access track from the Bailey Bridge (which is located approximately 750 m southwest of the former Richborough Power Station site entrance on Ramsgate Road (A256), extending in a northerly direction for approximately 1.5 km to the proposed location of the mast and stay foundations. The applicants note that the majority of this temporary track will be built by National Grid and is expected to be available for use by the Applicant. In this event, only a small spur of 150m of new track would be required to access the mast from this track.

5.1.4. Officers requested that as part of the application a plan showing the proposed mast and associated works and access in relation to the extent of the proposed DCO limits be provided. A site overview plan (reference: A1/PTD/3360/0003) has been provided, and is appended at Appendix A.

5.1.5. National Grid have raised a holding objection to the scheme in a letter dated 22 February 2016 on the following grounds: (1) programme - further information is provided so that agreement can be reached with the applicants regarding the interaction of the two projects and the associated construction programmes; (2) impact on the proposed access route to the Richborough Connection project site – the location of the eastern guy rope anchor point within the proposed Order limits of RCP and its impact on the access road required for construction of the Richborough Connection project. Agreement is sought to ameliorate the impacts of the proposed locations on the access routes for the Richborough Connection project; and (3) location of access route of the proposed development - the access route for the proposed mast development follows the same access route as that proposed for the construction and maintenance of the Richborough Connection project. Agreement is by National Grid sought on construction and maintenance access arrangements for both schemes. A copy of the holding objection is appended at Appendix B. Discussions have continued between National Grid and the applicants, and the additional information, currently out to further consultation, may address the matters raised by National Grid.

New Line Networks

5.1.6. The other mast proposal submitted to DDC by New Line Networks (reference DOV/16/00524) has not been scoped in to the National Grid DCO submission given its status at the time of submission. Nonetheless National Grid is aware of the proposal through ongoing discussions with DDC officers at regular meetings held with National Grid and the relevant authorities. It is understood that the access proposed to the communications mast follows the route of one of the proposed accesses to the south of pylon PC56 shown on National Grid drawing references PDD-21497-2-OHL-1137 and PDD-21497-2-OHL-1139. Comments have not yet been received by National Grid on this application, but it is understood that there is no conflict with the proposed mast and the proposed Order limits.

For ease of reference a plan showing the locations of the two masts that are the subject of the above applications is appended at Appendix C.

5.2. Thanet District Council

Nemo Link

5.2.1. The Nemo link application F/TH/13/0760 was approved on 19th December 2013 and included the installation of onshore, underground and sub-sea cables between Pegwell Bay and the former Richborough Power Station site. Part of a 130km High Voltage Direct Current (HVDC) electrical interconnector with an approximate capacity of 1000 megawatts (MW) extending from Zebrugge to Thanet.

5.2.2. The majority of the approved development site falls within the administrative boundary of Thanet District Council. However, approximately 720m of the onshore HVDC cable and a small area at the south east corner of the proposed converter station compound (outdoor hard landscaping and security perimeter fencing) is within the administrative boundary of DDC.

5.2.3. The application site includes 9.3 hectares of the former Richborough Power Station site, with access from the roundabout on the A256. The original cooling towers and chimney serving the former power station were demolished in March 2012 but the site retains the substantial turbine hall frame which is due to be demolished shortly. The majority of the site is hardstanding and remediation work is currently being undertaken on site.

5.2.4. The application also consisted of the erection of a converter station and substation at the former Richborough Power Station site. A reserved matters application F/TH/16/0128 was approved 24th May 2016 for the appearance, layout and scale of the converter station building, substation building, spare parts building, storage unit, and outdoor electrical equipment for substation and for converter station, associated temporary construction compounds, and fence to boundary of substation and converter station. Duplicates of these applications have been approved by DDC (planning application reference DOV/13/00759).

5.2.5. This application comes as part of a wider proposal for the Richborough site, as the Nemo link requires a connection to the National Grid network. This application, therefore, directly relates to the Development Consent Order at Richborough.

Manston Airport

5.2.6. Manston Airport has been closed since May 2014. The former Manston Airport site is subject to three prospective proposals:

 TDC has sought to find an indemnity partner for the compulsory acquisition of the airport. In January 2016, TDC undertook a soft marketing process to ascertain any interest in operating the site as an airport. A report was taken to TDC’s Cabinet meeting on 16th June 2016 to outline the outcome of the soft market testing exercise. Cabinet agreed to note the results of the soft market testing assessment and take no further action in respect of the interested parties;  A potential DCO for the upgrade and reopening of Manston Airport primarily as a cargo airport, with some passenger services, with a capacity of at least 12

12,000 air cargo movements per year. RiverOak is in pre-application discussions with the Planning Inspectorate. As part of this process, RiverOak have also started a public consultation on their plans for the airport http://www.riveroakinvestments.co.uk/riveroak-investments-launches- informal-consultation-manston-airport-dco-proposals/; and  A mixed use scheme (Stone Hill Park Limited). Stone Hill Park Limited submitted an application (OH/TH/16/0550) on 31 May 2016 to TDC for determination. A hybrid application - the outline application (with all matters reserved except access) is for the following use classes: employment (B1a- c,B2/B8); Residential (C3/C2), Retail (A1-A5), education and other non- residential institutions (D1), Sport and Recreation (D2), Hotel (C1), open space, car parking, infrastructure, site preparation and associated works. The detailed element is for four industrial units (B1c/B2/B8) with car parking and associated infrastructure. National Grid has not made any representations in relation to the application. The consultation period has now closed for consultee and neighbour comments. The application is currently due to be determined by 2nd September 2016.

5.2.7. In terms of potential future aviation uses on the site, National Grid consulted with the Civil Aviation Authority (CAA), National Air Traffic Service (NATS) and Defence Estates Safeguarding (MOD) in respect of routeing and technology choice (including that of pylon design). The CAA responded during the statutory consultation period (10 February to 27 March 2015) and stated that the project will not constitute an en- route obstruction for civil aviation purposes (Document 6.1 - see Section 10, page 297 [APP-127]).

5.2.8. In terms of the mixed use proposals, National Grid and TDC consider that the Richborough Connection project would have no impact on the development proposals currently pending determination by TDC. National Grid and TDC agree that the Richborough Connection project would have no impact on the potential future use of the former Manston Airport site.

5.3. Canterbury City Council

5.3.1. An application for a lawful development certificate for proposed substation infrastructure, electrical reinforcement works and associated upgrades to secure enclosures has been submitted to CCC under reference CA/16/01238. The works proposed at Canterbury North Substation involve the construction of two line entry gantries with down-leads into the substation and the installation of a range of new electrical plant within the existing operational site boundary.

6. Needs and Benefits

6.0.1. National Policy Statement on Energy (EN1) sets out the scale and urgency of the need for new electricity network infrastructure and states that, without significant amounts of new large-scale energy infrastructure, the objectives of its energy and climate change policy cannot be fulfilled.

6.0.2. Major investment in new generating capacity is needed to ensure that secure electricity supply is maintained. The UK government envisages a net addition of 40 Gigawatt (GW) of new capacity by 2020.

6.0.3. The electricity industry in the UK is undergoing unprecedented change. Coal-fired power stations are expected to close in the next few years as they are not able to meet the requirements of European Large Combustion Plant Directive. Existing nuclear capacity is expected to come to the end of its original expected operating life. Significant additional investment in new generating and interconnection capacity is needed to ensure that existing minimum standards of security of supply are maintained.

6.0.4. Interconnectors are a key part of the developing European energy infrastructure. The UK has an existing interconnector capacity of approximately 3.5GW comprised of connections to France, Northern Ireland and the Netherlands. Greater interconnection will contribute to the achievement of a properly functioning European energy market and it will also enhance security of supply in both the UK and Europe. Furthermore, an interconnection will provide an important mechanism for responding and managing both intermittency and excess power associated with renewable energy generation. The proposed Richborough Connection project will provide the necessary infrastructure and connect to the Nemo Link to facilitate the onward transmission of electricity across the wider network.

7. The Likely Significant Effects of the Proposed Development

7.0.1. The Joint Councils have been consulted on the scope of the Environmental Statement (ES), and throughout the preparation of this LIR, have considered the following local impacts, in no priority order, which the Examining Authority will be required to consider:

. Landscape and Visual Impacts . Historic Environment . Archaeology . Biodiversity . Highway Impacts . Public Rights of Way . Noise and Vibration . Air Quality . Water Environment . Waste Management . Geology, Soils and agricultural land . Socio-economic impacts . Cumulative Effects

Reference is made to the NPSs and legislative compliance, where appropriate, to support the Joint Councils’ position.

7.1. Landscape and Visual Impacts

7.1.1. The proposed overhead line would create a 21km prominent man-made linear feature within the landscape, inevitably resulting in a visual impact and an impact on landscape character. There would be direct loss of hedgerows and woodland (including the loss of an area of ancient woodland at Kemberland Wood).

7.1.2. The applicant’s ES (Document 5.2 [APP-029] and [APP-030]) indicates that a typical standard lattice 400kV overhead line approximately 50m high can be discerned at distances up to 10km. Consequently the adverse visual and landscape effects would be experienced over an extensive area much of it within the characteristically open and expansive landscape setting of the Chislet Marshes and the Ash Levels. This landscape has little topographic ‘backgrounding’ or screening and mitigation through woodland or screen planting would not be characteristic elements. There would be adverse visual impacts on the Saxon Shore Way long distance footpath particularly where the proposed overhead line crosses over the footpath. The Ash Levels is also the location where a section of the PY route would run parallel with the 400kV overhead line creating a wider corridor of adverse visual and landscape impact.

7.1.3. Landscape and visual impact matters, that are considered to be still outstanding and agreed, are set out in a SoCG between National Grid and the Councils (Document 8.4.6) and will be further clarified in the Written Representations.

7.2. Historic Environment

7.2.1. Matters regarding the impact of setting on designated heritage assets have been assessed by the City and District Councils’ Conservation Officers and Historic England.

7.2.2. KCC and CCC consider that whilst the provision of new pylons would not have a significant impact on the World Heritage Site, the impact on other heritage assets must be more fully assessed against the verified photomontage surveys accompanying the ES (Document 5.2 [APP-029] and [APP-030]) and the Draft DCO (Document 2.1 [APP-006]) and any future photomontages requested by the Examination Panel.

7.2.3. Further historic environment matters are set out in the SoCG between National Grid and the Councils (Document 8.4.6).

7.3. Archaeology

7.3.1. KCC and CCC’s archaeologists have been involved in active discussions with National Grid’s archaeological consultants throughout the development of the scheme and have agreed the approach to and the process of assessment and survey works.

7.3.2. The proposed development is located within a rich archaeological landscape. The scheme does have archaeological impacts arising from pylon foundations, work areas and access roads, as well as a potential to impact on unknown archaeological remains, however these are of a nature that can be dealt with through either slight

adjustment during detailed design or through programmes of archaeological investigation and monitoring.

7.3.3. An outline Written Scheme of Investigation was included in the ES submission (Document 5.2 [APP-029]). KCC and CCC’s archaeologists have been involved in the development of this document and the approach to mitigating the archaeology on the scheme. The final version of the WSI has been agreed by KCC and CCC’s archaeologists as of June 2016.

7.4. Biodiversity

7.4.1. The Joint Councils are satisfied with the rationale for scoping in/out ecological receptors, as detailed in Table 9A.1 in the submitted Evaluation of Receptors (Volume 5, Document 5.4.9A [APP-086]) and are broadly satisfied with the assessment of ecological impacts however raise the following outstanding queries:

 It is reported in paragraph 9.8.1 within the submitted Evaluation of Receptors (Volume 5, Document 5.4.9A [APP-086]) that the ecological assessment method is based on the ‘industry standard’ Guidelines for Ecological Impact Assessment (2006). These have now been superseded with a second edition, published in January 2016. Whilst the Joint Councils consider that the second edition is not likely to result in significant changes to the submitted assessment, it is recommended that assurance is sought regarding the review of the method and outcomes of the assessment with reference to the Guidelines for Ecological Impact Assessment, 2nd edition (2016).

 With regard to the consideration of cumulative impacts, the assessment, taking into account the Sturry Broad Oak Masterplan, concludes no cumulative effect on West Blean and Thornden Woods Site of Special Scientific Interest (SSSI). The assessment does not appear to have considered whether the proposed works associated with the Richborough Connection project could provide greater opportunities for public access (whether official or unofficial) that with the increase in residential development planned for the Sturry Broad Oak area could be detrimental to the SSSI.

 The timescales for construction are not clearly considered, with conclusions of ‘short-term’ impacts provided throughout much of the assessment. While justification for short-term impacts being assessed as not significant is provided, it is questioned whether there has been sufficient consideration of this in relation to the potential impacts to water voles, particularly within the Ash Level and Richborough Pasture Local Wildlife Site.

7.4.2. The Joint Councils support the approach to avoiding culverts at locations in which water vole activity is recorded during the pre-commencement surveys. However, while this approach will avoid direct impacts, and the use of mammal ledges within the culverts will ensure connectivity during operation, the assessment does not appear to consider the extent to which the use of culverts could reduce the amount of potential water vole habitat available in the local area (whether for foraging or burrowing). Therefore, further details of the timing and duration of the works, would help to inform these conclusions. 16

7.4.3. The Joint Councils are satisfied with the approach to ecological mitigation, with embedded environmental measures delivered through method statements, alongside bespoke measures according to the potential for ecological impacts to arise in relation to each pylon and associated works. This provides clarity to contractors and ensures that ecological expertise is appropriately used.

7.4.4. The Joint Councils note that the submission includes a Landscape Habitat and Enhancement Scheme (Document 5.8 [APP-123]) contains measures additional to the proposed ecological mitigation approaches. It is stated that these are not guaranteed as they rely on landowner agreement and therefore do not form an integral part of the DCO.

7.4.5. Whilst the Joint Councils have not considered the extensive documentation relating to the mitigation measures, the generic method statements and the particular impacts and overview of mitigation approaches provided within Chapter 9: Biodiversity of the ES (Document 5.2 [APP-029]) have been reviewed.

7.4.6. In terms of woodland areas, it is questioned whether the submission incorporates a means through which the long-term methods of maintenance of safety clearance zones during operation of the proposed development can be adequately informed by the ecological survey and monitoring data.

7.4.7. It is noted that the ecological survey work has been undertaken and/or overseen by ecologists who are members of the Chartered Institute of Ecology and Environmental Management. In accordance with good practice for members, and the guidelines under which the surveys have been undertaken, the Joint Councils expect that all of the ecological survey and monitoring data will be provided to the Kent and Medway Biological Records Centre to improve ecological understanding within Kent.

7.4.8. It would also be beneficial for the County Ecologist to be provided with ecological monitoring reports as this information will help to inform future decision-making.

7.4.9. The submission includes a Landscape Habitat and Enhancement Scheme (Document 5.8 [APP-123]) that contains measures additional to the proposed ecological mitigation approaches. It is stated that these are not guaranteed as they rely on landowner agreement and so do not form an integral part of the DCO. It is questioned whether these agreements are actively being sought.

7.5. Highway Impacts

7.5.1. A separate SoCG (Document 8.4.5) has been agreed between National Grid and KCC, as Local Highway Authority for the area in which the proposed Richborough Connection project is located. National Grid and KCC are in agreement on all relevant specific matters and these are set out in Table 3.1 of the SoCG.

Sturry Relief Road

7.5.2. The Sturry Relief Road is considered by both CCC and KCC to be essential infrastructure required to mitigate the highway impact of two strategic site allocations 17

identified in Policy SP3 of the emerging Canterbury District Local Plan (‘Land at Sturry/ Broad Oak’ and ‘Land North of Hersden’). The proposed route of the Sturry Relief Road is identified on the emerging Local Plan Policies Map (Policy T14).

7.5.3. Previous representations made by KCC did refer to the potential impact of the proposed Richborough Connection project on the delivery of the Sturry Relief Road. National Grid and KCC have engaged on an active and constructive basis to ensure that the Richborough Connection has no material impact on the design and construction of the Relief Road. The SoCG states the final position of KCC, as Local Highway Authority and National Grid. In so far as is related to the proposed Richborough Connection, there are no outstanding matters which would adversely impact upon the deliverability of the Sturry Relief Road.

Impact on the Existing Highway Network

7.5.4. KCC is satisfied that each individual access point from the adopted highway has been appropriately assessed and suitable mitigation measures proposed and agreed to accommodate the construction traffic generated by the project. In addition all site compounds have been shown to allow for adequate turning provision to ensure all vehicles enter and leave the adopted highway in a forward gear. KCC is satisfied that the Construction Traffic Management Plan (Document 5.4.3G [APP-068]) appropriately conditions the routing/ timing and impacts of construction traffic on the local road network.

7.6. Public Rights of Way

7.6.1. The Joint Councils concur with the impacts and severity levels that have been identified within the submitted documents, which in summary, for PROW are relatively low.

7.6.2. The closure and/or temporary diversion of PROW is considered to be the main impact of the proposed development. National Grid has incorporated the requested ‘hierarchy of intervention’, which seeks the option with the minimum impact first. As a result, the majority of temporary closures will be only 2 days in duration at a time. The closure that is of greatest concern is the long term closure of PROW EE42. This is part of the Saxon Shore Way; a long distance regional recreational promoted route. Therefore it is argued by KCC and DDC that the potential impact is greater than identified in the ES.

7.6.3. PROW EE442 which is part of a national route, falls within part of the proposed Order limits and during construction part of this route is identified for closures/diversions potentially extending up to 12 weeks (see table 3H.3.1 in the Public Rights of Way Management Plan, Document 5.4.3H [APP-069]). The table identifies the route of the diversions, and the Draft DCO (Document 2.1 [APP-006]) Plan submitted in Volume 4 (Document 4.7 Access, Rights of Way and Public Rights of Way) includes the details of the proposed diversions and schedule 7 of the Draft DCO (Document 2.1) identifies the extent of the temporary stopping up and the temporary diversion. There is concern that the proposed temporary diversion would result in some harm to the enjoyment of the PROW network by virtue of the potential duration of the temporary diversion of the diverted route.

7.6.4. A briefing note prepared by National Grid clarifies the position with regard to the duration of any potential closure. In summary, KCC has agreed a ‘hierarchy of intervention’ which seeks the minimum impact in the first instance during construction and comprises the following: signage regarding keeping routes open; using local management to hold PROW users for short period (e.g. to allow vehicles to pass); using scaffold protection over PROW; creating very short diversions immediately around works and the temporary closure and temp diversion where there is no other option. National Grid has identified the likely duration of these closures for the majority are only 2 day closures.

7.6.5. The relatively low impacts identified are based on the PROW usage surveys that have been conducted. There is a very real risk attached to this, since the surveys were conducted over two days only and therefore are unlikely to be representative. The impact of any closure is arguably greater for a pedestrian in the rural environment due the potential length (distance) of any alternative route and therefore the additional journey time that this may add. This is considered as a negative impact, even on recreational journeys. Experience has shown that when processing permeant diversions on the PROW network, the general public object if the distance is increased.

7.6.6. It is noted that no permanent diversions are proposed; therefore any impacts are only during construction. Therefore, any impacts on the surface of the PROW during construction should be rectified following construction to restore the surface back to the same condition; resulting in no long term impacts. However, short term impacts may arise during construction, where surfaces become damaged through, for example, shared use with construction traffic. The ES does not include any mitigation measures that will be in place to address such situation during construction and therefore it is expected that there will be a direct impact on users which has not been addressed. As no information has been forthcoming from National Grid about how these closures will be publicised in advanced and further clarification is required from National Grid on this important matter.

7.6.7. The preferred option is that diversions are kept to a minimum distance and duration, rather than to provide temporary alternative routes further away from construction sites and traffic.

7.6.8. Additionally, the ES (APP 029/030) does identify that there will be ‘significant adverse visual effects’ from ‘some public rights of way’ along the whole route.

7.7. Noise and Vibration

7.7.1. Concern has been previously raised with National Grid in the period leading up to the submission of the project about the Core Working hours that have been included in the Draft DCO (Document 2.1, Schedule 3, Section 7 [APP-006]). National Grid have subsequently, submitted a draft Noise and Vibration Management Plan which has been reviewed by DDC, CCC and TDC Environmental Health Officers.

7.7.2. Whilst the Environmental Health Officers at DDC, CCC and TDC do fully appreciate that the project stretches over a long distance and there are environmental 19

constraints in terms of when construction can take place on certain stretches of the route, concerns have been expressed regarding the proposed blanket working hours. It is generally accepted across the UK that the standard hours for noisy works are 8am to 6pm Monday – Friday, 8am to 1pm Sat and at no time at all on Sundays or Bank Holidays. These hours are followed in major projects like HS2 and it is considered that the Richborough Connection project should adopt a similar approach.

7.7.3. In the interest of moving this project forward, the Environmental Health Officers suggest that a potential way forward would be where there are no noise sensitive receptors within 500 metres of any construction operation, that the hours suggested by National Grid are acceptable. Where there are noise sensitive receptors within 500 metres of any construction operation, the standard (COPA) hours must be adhered to. If National Grid wanted to work outside of the hours of operation as detailed above, these instances can be dealt with via the submission of a section 61 application. However, detailed justification should be given in advance of such works in order to avoid disturbance to the surrounding area and the need for enforcement action on behalf of the Joint Councils.

7.7.4. Notwithstanding the above comments, the draft Noise and Vibration Management Plan (paragraph 1.5.6 and Table 1.3) has identified a number of specific sensitive locations in the administration area of CCC where there would be restricted working hours. DDC, CCC and TDC would like specific reference in the Draft DCO (Schedule 3, Section 7, paragraph 7 [APP-006]) to explicitly refer to the restricted working hours that are contained in the Noise and Vibration Management Plan which would go some way to address their concerns regarding their concerns regarding blanket construction hours as otherwise, in the opinion of DDC, CCC and TDC the Draft DCO is ambiguous in terms of the construction hours. It is considered that properties in the CCC administration area would be most affected and this should be an area that the Inspector’s should visit.

7.8. Air Quality

7.8.1. As identified in the SoCG concerns were initially raised in respect of a seeming disparity between the measures identified in the Dust Risk Assessment (Document 5.4.12A [APP-111]) and where in the Construction Environmental Management Plan (CEMP) (Document 5.4.3C [APP- 064]) such measures would be secured. A briefing note prepared by National Grid to signpost the measures in the CEMP has been prepared and has been agreed by the relevant authorities, as providing sufficient methods to mitigate any potential issues relating to air quality.

7.9. Water Environment

7.9.1. It is likely that both the permanent and associated temporary works required for the installation of the infrastructure will have implications for various watercourses along the route.

7.9.2. Any works that will (or has the potential to) affect a designated ‘main river’ will require the prior formal written Consent of the Environment Agency (EA). This requirement also covers any works that fall within any main river’s byelaw margins. In this area,

the byelaw margins extend to 8m from the banks of any non-tidal main river, and 15m where a watercourse is tidally influenced.

7.9.3. Any works to any non-main river watercourse that lies within River Stour (Kent) Internal Drainage Board’s administrative boundaries will require their formal written Consent. ‘Ordinary watercourses’ are the watercourses which are not maintained by the EA or by an Internal Drainage Board. In the absence of any express agreement to the contrary, maintenance will be the responsibility of the riparian owners. Irrespective of any planning permission granted, any diversion, culvert, weir, dam, or like obstruction to the flow of any such watercourse will also require the explicit consent of the Lead Local Flood Authority (KCC) under the Land Drainage Act 1991, as amended by regulations of the Flood and Water Management Act 2010. This requirement also covers potential temporary works.

7.9.4. From a flood risk management perspective there is no objection to the proposed route of the network.

7.10. Waste Management

7.10.1. The Joint Councils note that the Draft DCO will secure the preparation of an Outline Waste Management Plan and that a Site Waste Management Plan for each phase of the proposed development will follow.

7.11. Geology, Soils and agricultural land

7.11.1. The Joint Councils note that, as set out in the Mineral Planning Report (Document 5.4.14B [APP-114), approximately 6km of the total length of the proposed overhead line/Order Limits is located on deposits (and alluvium in part), which are designated as a Mineral Safeguarding Area under the emerging Kent Minerals and Waste Local Plan 2013-2030 (May 2016). Whilst the deposits affected are small and sporadic by nature, prior extraction should be actively considered, unless physical evidence demonstrates that the presumption of safeguarding can be exempt, as set out in emerging Policy DM7: Safeguarding Mineral Resources.

7.11.2. It is likely that the use of land around the pylon locations will be restricted during pylon construction. The excavation and compaction of ground resulting from construction activity will potentially require reinstatement work.

7.11.3. Additionally, land directly under the pylons will potentially no longer be used for agricultural purposes following construction, with the surrounding land reinstated to its previous condition. The majority of land surrounding the proposed overhead line route is in agricultural use and it is considered that there will be some limitation of this activity as a result of the proposed scheme. The Joint Councils concur with the impacts and associated severity levels set out in Chapter 14 and 15 in the submitted ES (Document 5.2 [APP-030]).

7.12. Socio-economic Impacts

7.12.1. The Joint Councils are not aware of any mechanism that could be employed by the National Grid other than ‘best endeavours’ to ensure that an average of 10 and 6

people per day would be potentially be employed on the installation and removal of the overhead lines (paragraph 15.16.14 of the ES Document [Document APP- 030]). This could be an over estimation of the number of local jobs especially as this is an extremely specialised area of work and no evidence to our knowledge has been put forward by National Grid on comparable schemes and how many local jobs were created locally.

7.12.2. Whilst the Joint Councils recognise and fully support the fact that this project will generate jobs and be of benefit the local economy, questions are raised regarding the other wider scheme benefits that have been outlined in paragraph 15.16.3 in the ES (Document 5.2 [APP-030]) on the grounds that there is no supporting information to demonstrate how these figures have been derived (e.g. number of bed spaces, additional £2.4 million of additional spend in the local economy).

7.12.3. Additionally, limited access along roads and footpaths associated with construction will have a direct impact on local businesses and leisure uses. With regard to tourism, there are no significant tourist attractions along the proposed overhead line route, other than the general countryside itself. However, the Joint Council recognise that concerns have been raised by neighbouring businesses (e.g. Nethergong Campsite).

7.13. Cumulative Impacts

South East Water Broad Oak Reservoir

7.13.1. KCC is concerned with the potential impact of the pylon route on the South East Water (SEW) proposal for a reservoir at Broad Oak, as identified in its Water Resource Management Plan (WRMP) June 2014. The WRMP has the approval of the Secretary of State for Environment, Food and Rural Affairs. The reservoir at Broad Oak is the largest of just two new SEW water supply schemes in East Kent and is therefore a key component of the company’s WRMP. SEW’s previous WRMP (January 2010) also provided significant support for a reservoir at Broad Oak.

7.13.2. Both KCC and CCC wish to ensure that that there is no unacceptable conflict between the proposed Richborough Connection project and SEW’s proposal for a reservoir at Broad Oak. KCC and CCC are aware that SEW continues to raise objection and would urge the Examining Authority to take account of these objections to ensure that there is no unacceptable conflict between the two proposals.

8. Conclusion

8.1.1. The Joint Councils will continue to engage positively with National Grid and the Examining Authority and will welcome further engagement on the content of this LIR as the examination advances.

APPENDIX A A1/PTD/3360/0003 - Site Overview Plan Vigilant Global UK Ltd proposed communication mast

APPENDIX B National Grid Holding Objection: Application Reference 16/00044 – Erection of a Guyed Steel Lattice Mast (324m in height) National Grid house Warwick Technology Park Gallows Hill, Warwick CV34 6DA

Fiona Runacre Emer McDonnell Dover District Council Senior Consents Officer Council Offices [email protected] White Cliffs Business Park 07920295375 Whitfield Dover CT16 3PJ

www.nationalgrid.com SUBMITTED VIA EMAIL TO: [email protected]

22 February 2016

Dear Sir/Madam,

APPLICATION REFERENCE - 16/00044 ERECTION OF A GUYED STEEL LATTICE MAST (324M IN HEIGHT) WITH 9 ANCHOR POINTS, INSTALLATION OF TELECOMMUNICATIONS AND ASSOCIATED EQUIPMENT, SITE COMPOUND, SECURE FENCING, SINGLE STOREY EQUIPMENT STRUCTURE, AND ASSOCIATED WORKS (the Application).

COMMENT ON PLANNING APPLICATION.

This response is on behalf of National Grid Electricity Transmission plc (National Grid) in respect of the Richborough Connection Project (RCP). National Grid exercises its right to place a Holding Objection to the above proposal, whose application site falls partly within the proposed Order limits of the RCP. This holding objection is subject to further information being provided and an agreement being reached between National Grid and Vigilant Global UK Ltd regarding the matters outlined below.

The proposed developments

Mast application (hereafter ‘the Application’)

The proposed development is for a new communications mast to be erected on the north western part of the former Richborough Power Station site (known as the ‘Banana Land’). It is understood that the proposed communications mast would provide point-to-point communication between the UK and Europe for the secure exchange of proprietary information; an improvement to broadband provision in the local area and facilities for broadcasting a Community Radio station.

Richborough Connection Project

National Grid has applied to the Planning Inspectorate (PINS) for a DCO to build a new high voltage 400kV overhead line connection between Richborough 400kV Substation and Canterbury North 400kV Substation in Kent. The proposed development falls within the administrative boundaries of Kent County, Canterbury City, Thanet District and Dover District Councils.

National Grid is a trading name for: National Grid is a trading name for: National Grid Electricity Transmission plc National Grid Gas plc Registered Office: 1-3 Strand, London WC2N 5EH Registered Office: 1-3 Strand, London WC2N 5EH Registered in England and Wales, No 2366977 Registered in England and Wales, No 2006000

National Grid house Warwick Technology Park Gallows Hill, Warwick CV34 6DA

The application for development consent was submitted to PINS on 14th January 2016. The application was accepted for examination on 11th February 2016. Relevant details relating to the project can be viewed on the PINS website: http://infrastructure.planninginspectorate.gov.uk/projects/south- east/richborough-connection-project/.

Grounds for objection

Programme The programme contained at Table 4-1 of the Vigilant Mast Application Environmental Statement (ES) contains insufficient detail to consider the effects of the construction of the proposed mast development against the project programme for the RCP.

National Grid maintains its objection to the proposals until such time that further information is provided and agreement can be reached with Vigilant Global regarding the interaction of the two projects and the associated construction programmes.

Impact on proposed access route to RCP site The eastern guy rope anchor point of the proposed development is within the proposed Order limits of RCP. An anchor point in this location would have an impact on the access roads required for construction of the RCP scheme.

National Grid maintains an objection to the location of the anchor points, subject to further information being provided and agreement being reached to ameliorate the impacts of the proposed locations on the access routes for the RCP.

Location of access route of the proposed development The access route for the proposed mast development follows the same access route as that proposed for the construction and maintenance of the RCP. The effects of the proposed development have been assessed cumulatively with the RCP and concluded as negligible in Paragraph 11.8.2 of the ES submitted with the Application.

As the access route for the proposed mast development directly interferes with the Order limits and proposed access for RCP, National Grid maintain an objection to the route contained in the Application until such time as an agreement is reached regarding construction and maintenance access arrangements for both schemes.

Proposed development access track and UK Power Networks assets

The application proposes to carry out works under Schedule 2, Part 4, Class A of the Town and Country Planning (General Permitted Development) (England) Order 2015 (GPDO), specifically an access track directly underneath the 132kV overhead electric line currently operated by UK Power Networks.

It is assumed that both the applicant and the local planning authority have consulted with UK Power Networks regarding the access track and their assets.

National Grid is committed to continuing discussions with Vigilant Global UK Ltd to ensure both projects can be built and operated in parallel.

National Grid house Warwick Technology Park Gallows Hill, Warwick CV34 6DA

Yours sincerely

Emer McDonnell Senior Consents Officer, Consents

Enc. National Grid (Richborough Connection Project) Order Works Plans Regulation 5(2)(J)(I) & (Ii) and TEN-E Regulation EU347/2013 Sheet 17 Of 18 Drawing Reference: PDD-21497-2-OHL-1138

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Drain DOVER DISTRICT COUNCIL

RAMSGATE ROAD Application Number: EN020017 ETL National Grid Drawing Ref: PDD-21497-2-OHL-1138 Scale: Sheet size: Sheet: Status: 1:2,500 A1 17 of 18 S.56

COPYRIGHT NOT TO BE REPRODUCED WITHOUT THE WRITTEN PERMISSION OF THE NATIONAL GRID ELECTRICITY TRANSMISSION PLC APPENDIX C Plan showing locations of Vigilant Global UK Ltd and New Line Networks proposed communication masts P

e l Dra c in y

C D r a i n

MP 83

n D i ra a in r

D Stonelees Cottage in D ra rai Sluice D n Solar Power Generating Site Stonelees

Stonelees House n ai Dr

Power Station Stonelees Nature Reserve

n i Farm a r FW Bungalow D n i Mast a r

D M Dr ud ain

Wind Electricity n i a Generator r D Dr ain

Mast

f Me El Sub Sta e in an D ra Hig D D h W rai a n n t i er a r n Minster Marshes i M D a r i D D r n a in s t e

M S ea L W n t C H r i e C gh LB Wa C a ter o m Co ns t, CP & ED t Bdy an Mud ol G ur to r S ive Ebbsfleet R House

Ebbsfleet E TL Cottage C D P & Ash Level rain ED H Bdy R Dr ain m U Tanks 1 nd 9 .

0 LW E M TL D r a in Mast (Telecommunication)

WB Sluice Sluice Dr M ain LW P ip El e Lin Sub Lagoon e Sta Pond

D ra in D r a in Pump House n i Sluice a 3.2m r Sluice D n i f a e MP 83.25 r Sheepfold D D k c Sports Ground a r T

D rain

D e f

r a Bowling Green i n Pavilion

M LW M Ash Level ud 3.2m Club D Saltwater ra in Sluice FB Escana Tennis Court

Sluice

n ai Dr

M e an g D in n r H ll o a ig i ti i h F n W ta in a S a t r er D

R D iv e ra r i S n to u C r o C o n s t,

n C i P Richborough Port a Drain r & D D D E r a e D in f B d y

f P e a D th

(u m D ) rain in P a r i p e D L in e

Sluice ET L M Filling e in a Station a n r Ash Level H 2.7m D ig h

W M Depot a L t W E e TL r

M in s te r S t r e Tra a cks m

Richborough Power

Station

(disused) Depot Dr ain

M P

8 C 3 M o . 5 u C d o k n Kingfisher Sluice c SL s a t, r C T D P D P r i a p e & e f ni E Mud s L D y D n i d ra ai n B Grid Station in r e B D d y D

M P

C L ,

W t

s n Pipe El Sub Sta o Line

C D

d o r a n 5.2m C i n U

T ETL ra c in k a r D

i p

L i n Foot Bridge e D ra in D r ain MLW

Compound

ET D L ra in D rain

D r a d Mud in r a l o B

E T k L c a r Post T L T D E

a n i 4.0m i n a r

D ra in 2.3m n i e a n r i L D e p i L T P E

D ra in in ra D Sheepfold n i Richborough Port

a r

D D ra

in r a

i in Tank n a Dr El

D Sub Sta r a D i n r a

i n

in ra n i n D a i r a D r D

Drain

8 r 3 e . t 7 a 5

n W i h a M T r Drain g u i r D H a d c n k a e

e r a e t Ash Level n a

n s W i P i t g f a s h a 3.7m h e r o g t D i h D W P M H

( g a u e n n Mud t i m a a e r R e n r r o

) D i o

v M r H f u a e r M

i i n g r a o h h t

W W n e S a w v h t S El Sub Sta e a c e r a t H r N o e h u h e R g c r i f u v f w i o a Ash Level r d t o n s b a R g a h S l Dra ic F in M R

k c a r

k T in c

n a a i r r a W T D r C

a D C r

B W

Dra D in r a i n

n i a r

Rich borough S tream Sluice

MLW Sluice D rain L E T Stone

Dr ain Works R ich b ) MLW oro u n gh i S a tr r eam D

(

r m a

a i

n e r

h D g Works

u r

o a

Sheepfold r i n Depot o in Sheep Wash b Dra h

c i D R r a in 3.5m

i Sluice n M Stonar u d Cottage

M Bollard HW Bollard MHW MHW MLW MP MP 84 Cut Bridge Stonar Cut Drain Mud MLW M M HW MHW Sluice LW Mud M LW

D r ra a MHW i i

n n

n i Mud

n a i r

r D

a n

i Oil Storage Depot

Tank

El Sub Sta

C 3.9m L S W luic e

Sluice

T 2.8m r a c k MP WB

Drain MPs

Drain D

r a i n

2.0m r D a ra i i n n Drain Ash Level ) n i m a Rubery r u (

D Cottage h t

Sluice Mooring Post B F Sluice in a r D

r D Wate D rain rain High Mean Reach taff Mud Flags r Waste Transfer Station River Stou rain CCLW n D

D S andwich Haven

D Water r igh a Mud Mean H i n Refuse

n i a Destructor r D

WB Trac k

El S ub S Little Guston ta

3.8m d D rain u

St Nicholas Dr Villa ain D rain GP MP 84.25 North Stonar