North Somerset Council

REPORT TO THE PLANNING AND REGULATORY COMMITTEE

DATE OF MEETING: 9 OCTOBER 2013

SUBJECT OF REPORT: NATIONAL GRID -HINKLEY C CONNECTION

TOWN OR PARISH: BANWELL, LOXTON, CHRISTON, WINSCOMBE AND SANDFORD, YATTON, CONGRESBURY, WESTON-SUPER-MARE, PUXTON, CHURCHILL, KENN, TICKENHAM, NAILSEA, BACKWELL, WRAXALL, CLAPTON-IN-GORDANO, PORTBURY, PORTISHEAD, EASTON-IN-GORDANO

OFFICER/MEMBER PRESENTING: GRAHAM QUICK, LOCAL PLANNING TEAM LEADER

KEY DECISION: NO

RECOMMENDATIONS

That National Grid be informed that:

(i) the T Pylon design option is supported;

(ii) subject to further assessment on the impact of undergrounding at the Portbury Wharf Nature Reserve, the Option B route which takes the 400kv line away from the M5 motorway is supported;

(iii) the Green Route (cross country) for undergrounding the 132 kv line from Nailsea to Portishead is supported;

(iv) the use of lattice pylons and the route for the 132kv route from the proposed Sandford Substation to the 132kv WsM AT route is supported;

(v) the re-alignment of the Strawberry Line and the provision of a public car park should be incorporated into the design of the Sandford Substation;

(vi) the route in the vicinity of Moorland Park should be moved further eastwards to create a greater distance between the proposed 400KV line and the gypsy and traveller site;

(vii) further assessments are required to minimise the impact on Tickenham Church and a clear mitigation strategy agreed upon to lessen any impacts on this listed building;

(vi) delegated authority be given to the Director of Development and Environment and Executive Member to: (a) submit further detailed comments on the Development Consent Order and the methodology and assessment of the proposals as part of the joint submission by all of the affected authorities and (b) where appropriate expand on the Council’s submission to take account of any material and significant concerns expressed by local councils;

(vii) that officers continue to work jointly with other affected authorities and National Grid to secure appropriate requirements ( conditions ) ,sufficient mitigation measures and Section 106 contributions to control and offset any harm caused by these proposals;

(viii) the detailed comments relating to the Preliminary Environmental Information Assessment (PEIR), proposed mitigation strategies and the lack of a Transport Assessment are noted and should be incorporated into the final Environmental Statement.

SUMMARY OF REPORT

1.1 The report sets out the background, policy considerations and the key issues to be considered on the formal consultation undertaken by National Grid for the Hinkley C Connection Project. The report focuses on the key site specific issues. Detailed comments on the methodology, assessment and the accompanying Development Consent Order are currently being drafted by advisors to all the affected authorities and they will be forwarded to National Grid under delegated powers.

1.2 These advisors have been appointed by the affected authorities under the framework established by the Planning Performance Agreement with National Grid. There is no cost to the Council for this work

1.3 There are a significant amount of plans, reports etc that have been submitted as part of the consultation exercise. These are available on the National Grid’s website http://www.hinkleyconnection.co.uk/default.aspx and exhibition boards and plans will be on display at the Committee meeting. Each member of the committee will have access to a copy of the “Project Overview Report “ at the meeting. Where appropriate the document reference from the consultation material is referred to in the body of this Committee report

POLICY

2.1 The 2008 Planning Act introduced a new planning system for applications to build nationally significant infrastructure facilities (NSIPs) in England and Wales. The new system covers applications for major energy generation, railways, ports, major roads, airports and water and waste infrastructure. Under the new system, national policy on infrastructure is set out in a series of new National Policy Statements (NPS).

(i) National Policy

2.2 For energy-related NSIPs, there are two NPS s designated on 19th July 2011 that are relevant to the proposed development: overarching National Policy Statement for Energy (EN-1); and National Policy Statement for Electricity Networks Infrastructure (EN-5).

2.3 EN-1 states that in considering any proposed development, and in particular when weighing its adverse impacts against its benefits, the following should be taken into account:

 its potential benefits including its contribution to meeting the need for energy infrastructure, job creation and any long term or wider benefits; and  its potential adverse impacts, including any long term and cumulative adverse impacts, as well as any measures to avoid, reduce or compensate for any adverse impacts.

2.4 It goes on to note that, in this context, the relevant Secretary of State should take into account environmental, social and economic benefits and adverse impacts, at national, regional and local levels. The NPS provides guidance on assessment relevant to all energy projects which is supplemented by guidance specific to the project type. In the case of the Hinkley Point C Connection, the relevant guidance is to be found in the National Policy Statement for Electricity Networks Infrastructure (EN-5). EN-1 recognises that “in most cases, there will be more than one technological approach by which it is possible to make such a connection or reinforce the network (for example, by overhead line or underground cable) and the costs and benefits of these alternatives should be properly considered ….”

2.5 Section 4.4 of EN-1 provides guidance on the consideration of alternative options for infrastructure projects, including the principles that should guide the relevant Secretary of State when deciding what weight to give to alternative options. This includes “alternative proposals which mean the necessary development could not proceed, for example because the alternative proposals are not commercially viable or alternative sites would not be physically suitable, can be excluded on the grounds that they are not important and relevant to the IPC’s decision”.

2.6 Good design is an important part of EN-1 which makes it clear that good design goes beyond physical appearance, with the functionality of an object, including fitness for purpose and sustainability, being equally as important. Paragraph 4.5.3 states that “the IPC should satisfy itself that the applicant has taken into account both functionality (including fitness for purpose and sustainability) and aesthetics (including its contribution to the quality of the area in which it would be located) as far as possible. Whilst the applicant may not have any or very limited choice in the physical appearance of some energy infrastructure, there may be opportunities for the applicant to demonstrate good design in terms of siting relative to existing landscape character, landform and vegetation.”

2.7 Paragraph 2.8.2 of EN-5 states that "Government does not believe that development of overhead lines is generally incompatible in principle with developers’ statutory duty under section 9 [sic] of the Electricity Act to have regard to amenity and to mitigate impacts. In practice new above ground electricity lines, whether supported by lattice steel pylons/pylons or wooden poles, can give rise to adverse landscape and visual impacts, dependent upon their scale, siting, degree of screening and the nature of the landscape and local environment through which they are routed. For the most part these impacts can be mitigated, however at particularly sensitive locations the potential adverse landscape and visual impacts of an overhead line proposal may make it unacceptable in planning terms, taking account of the specific local environment and context."

2.8 EN-5 goes on to say that although Government expects that overhead lines will often be appropriate and their effects can often be mitigated, where there are serious concerns about the potential adverse landscape and visual effects of a proposed overhead line, “the IPC will have to balance these against other relevant factors, including the need for the proposed infrastructure, the availability and cost of alternative sites and routes and methods of installation (including undergrounding)”.

2.9 EN-5 states that the main opportunities for mitigating potential adverse landscape and visual impacts of electricity networks infrastructure includes the “selection of the most suitable type and design of support structure (i.e. different lattice tower types, use of wooden poles etc.), in order to minimise the overall visual impact on the landscape”.

N.B. In April 2012 the Infrastructure Planning Commission (IPC) was abolished and transferred its property, rights and liabilities to the Secretary of State. Applications for major infrastructure projects were thereafter submitted to the Planning Inspectorate with a decision being made by the relevant Secretary of State.

(ii) Local Policy

2.10 There is no Council policy on the siting of overhead electricity lines although, the North Somerset Replacement Local Plan and Core Strategy contains policies that seek to protect residents from harmful environmental effects and also protect the landscape from inappropriate development.

DETAILS

The consultation material consists of the following:

3.1 Volume 1: A guide to the consultation This section includes the plain English documents we have produced to explain the proposals. It includes Project News, the Overview Report, the Feedback Form and Document Navigation Booklet.

3.2 Volume 2: Preliminary Environmental Information Report (PEIR) As part of the Environmental Impact Assessment process, National Grid have carried out surveys to establish the potential effects of their proposals. They have published a report that gives the environmental information they have gathered so far on the project and on which they have based their decisions. This is called the Preliminary Environmental Information Report or PEIR. It covers such issues as landscape impact, noise traffic, etc.

3.3 Preliminary environmental information means information reasonably required to assess the environmental effects of the development and any associated development. The information referred to includes the following:

 A description of the proposed development;

 An outline of the main alternatives considered and the main reasons for the Applicant’s choice taking into account the environmental effects;

 A description of the aspects of the environment likely to be significantly affected by the proposed development including population, fauna, flora, soil, water, air, climatic factors material assets, including the architectural and archaeological heritage, landscape and the inter- relationship between these factors;

 A description of the likely significant effects of the proposed development on the environment including direct, indirect, secondary, cumulative, short, medium and long-term, permanent and temporary, positive and negative effects;

 A description of the measures envisaged to prevent, reduce and where possible offset any significant adverse effects; and

 An indication of any difficulties encountered in compiling the required information.

3.4 The PEIR also describes the outstanding information that National Grid currently anticipates will subsequently be provided in the Environmental Statement to accompany the DCO application.

3.5 Volume 3: Plans The plans show where National Grid propose to undertake work. There are nine different types of plans each showing a different element of the project.

3.6 Volume 4: Draft Development Consent Order (DCO) In order to build the proposed connection National Grid will need consent from the Government. The DCO details the legal powers National Grid are seeking in order to build and operate the connection. It contains a list of all the work they propose to do and a series of ‘Requirements’, similar to planning conditions, which set out the various obligations which will apply if consent is granted. There is also a Draft Explanatory Memorandum which explains the purpose of the Draft Development Consent Order.

3.7 Volume 5: Other documents This volume includes additional documents National Grid has produced for the consultation and includes details of the T Pylon design and the local works on the 132kv lines in North Somerset.

(i) Description of the project

3.8 The proposed connection would be between Bridgwater in Somerset and the existing 400,000 volt Seabank substation near Avonmouth. The 400,000 volt connection would compromise 46.6 kilometres (29 miles) of overhead line and over eight kilometres (five miles) of underground cables through and either side of the Mendip Hills Area of Outstanding Natural Beauty (AONB).

3.9 As part of the proposed development, an existing 132,000 volt overhead line, owned and operated by Western Power Distribution (WPD), would be removed between Bridgwater substation and Avonmouth substation. This necessitates the reconfiguration of the local electricity network in North Somerset. This includes building a new substation at Sandford. The purpose of this work is to connect to the existing overhead line that runs to Weston- super-Mare and Churchill to ensure its power supply is secure.

3.10 To enable the construction of the 400,000 volt overhead line across Tickenham Ridge a second 132,000 volt overhead line, owned and operated by WPD, would be removed for approximately eight kilometres (five miles) from the south west of Nailsea to Portishead substation. This overhead line is an essential part of the WPD distribution network in North Somerset and would be replaced by 132,000 volt underground cables.

(ii) Previous consultations with North Somerset Council

3.11 Since 2009 the Council has been consulted on route options and then more detailed alignments on a number of occasions (Planning and Regulatory Committee 26 November 2009, 21 July 2010, 25 July 2012 and 5 December 2012). Throughout these consultations the Council has continually pressed for a sub sea route or a proposal that does not involve overhead pylons. At the last meeting in December 2012 it was resolved:

(1) that North Somerset Council ask National Grid to continue to actively explore and evaluate emerging practical technologies such as gas insulated lines (GIL) which would not necessitate the use of 400kv overhead power lines, and to re-evaluate the relative costs of alternative solutions and consult with the public on the potential implications for energy bills; and

(2) that National Grid be informed that:

(i) the undergrounding of the draft route through the Mendip Hills AONB and the second 132kv line from Nailsea to Portishead sub station is welcomed;

(ii) the Council will continue to work with National Grid to ensure the adverse environmental, social and economic impact of the new 400kv line and associated works throughout North Somerset is minimised wherever possible;

(iii) the Council re-iterates its support for the proposed siting of the Sandford sub-station and strongly suggests that this is gas insulated and grass roofed, with measures to assist bat roosting/foraging. In addition the detailed design and layout should allow for a more direct alignment of the nearby Strawberry Line cycleway;

(iv) the preferred route corridor for the new 132kv link to Weston-super- Mare is supported and that this should be undergrounded to minimise any impact on the level landscape;

(v) further investigations should be undertaken to assess the impact on the residents of Moorland Park Congresbury with a view to moving the line further east;

(vi) more work needs to be undertaken to assess the impact on the setting of Tickenham Court;

(vii) the full impact on Portbury and Sheepway needs to be assessed and mitigated by careful pylon design and positioning;

(viii) North Somerset officers will continue to work with National Grid in order to identify appropriate mitigation measures and fully assess the impact of the draft route on key environmental concerns.

(iii) What are the major differences in the proposals to the previous consultation in December 2012?

3.12 Fundamentally the proposed alignment and the length of overhead/ undergrounding remains the same however there is considerable more detailed information relating to:

 exact positioning of pylon positions - subject to limits of deviation of 60m for the Lattice Pylon (30m either side of the centre line); and 80 m for the T Pylon ( 40 m either side of the centre line)

 the design of the pylon with the new “T” pylon proposed throughout North Somerset with the exception of 5 lattice pylons on the approach to the River Avon and the undergrounding section through the Loxton Gap

 there are two route options for the 400KV line put forward in the Portbury/Portishead area

 further details of the Nailsea to Portishead 132KV undergrounding are available for comment with two options put forward for consultation

 detailed designs for the Sandford sub station are available for comment

 National Grid are favouring the lattice style pylons linking Sandford Sub- station to the Weston-super- Mare 132 KV link ( referred to as the AT Route )

 much further information is available in their Preliminary Environmental Information Report (PEIR)on the methodology and assessment of the effects of their proposals on such issues as landscape, nature conservation ,historic environment ,traffic, noise ,vibration, air quality and electro-magnetic fields;

 more general details available on proposed mitigation measures to offset any adverse social, environmental and economic effects arising from the proposal.

(iv) What are the key issues?

(a) T Pylon or steel lattice pylon?

3.13 The consultation material includes a “ Pylon Design Option Report “ which for each of the sections of the route, the effects of both designs are assessed against a series of subject matters. Having considered the main issues National Grid recommend that for consultation, the T-pylon is adopted in preference to the steel lattice pylon along much of the overall route where overhead lines are proposed.

3.14 Whilst there are differences between the T-pylon and steel lattice options, both designs share similar characteristics, i.e.:

 They are above ground structures capable of carrying high voltage electricity;  They are capable of carrying three sets of twin conductor bundles on each side of the supporting structure;  There is a standard span of 360m between each of the structures;  All structures would have similar finishes; and  All structures would need to maintain statutory safety clearances

Officer comments:

3.15 A key distinction between previous consultations and the current consultation is the confirmation that the’ T Pylon’ will be included within the project. Based on the review to date, the advisors to the affected authorities (Arup) are stating there appears to be a lack of information to compare the significance of effects between the T Pylon and the Lattice Pylon and as such the Councils are placed in a difficult position of understanding which approach might be more appropriate. However National Grid have specifically requested comments on this issue.

3.16 The lattice tower (46.5m) is much taller than the T-pylon but is less wide and is an open structure allowing views through the structure. Lattice towers are already common place throughout the landscape and as such may be considered less noticeable in the wider landscape. When viewed backdropped against the ground or the landscape i.e. when viewed against a hill or from an elevated viewpoint, the lattice tower would become much less visible than when viewed against the sky.

3.17 The T-pylon (34.5m) is a shorter but wider structure than a lattice tower with a single solid central support which will partially obscure views past the pylon. T-pylons have not yet been used in the UK and would introduce a new structure to the landscape which may draw the eye to them. Depending on the colour used for the T-pylon (unclear if this will be a standard colour or a site/project specific colour) the pylon may be less when viewed against the sky – for example a light coloured pylon against a cloudy sky. However the pylon would potentially be more visible when viewed backdropped against the landscape. However, due to the lower height of the T-pylon there is potential for vegetation to provide a greater degree of screening, especially of longer distance views of the T-pylons.

3.18 The similarity in physical characteristics is reflected in the environmental appraisals that have been undertaken, where the assessed effects are considered to be largely similar. This is particularly so for ecology, and to some extent historic environment, where no real preference was determined throughout the majority of the overall proposed route. The T-pylon design was found to be marginally preferable in terms of landscape and visual amenity appraisals for the majority of the route.

3.19 Throughout North Somerset the T-pylon is proposed to be used, except where cables are underground through the Mendip Hills AONB and where steel lattice towers are necessary to cross the River Avon.

3.20 There are significant benefits in keeping the pylon heights as low as possible, particularly where crossing the more open Somerset Levels and Moors landscape. These alternative tower designs (36m tall) are approximately 12m shorter than the proposed lattice towers and this is a significant difference. It will help reduce the visual impact of the pylons, particularly in the wider landscape.

3.21 There will be relatively few lattice towers seen in combination with these new pylons in North Somerset. Although initially they will appear different, they won’t for the most part look incongruous as there are few cumulative effects. If they are to be used, then it is right to use them along as much of the route as possible for continuity of appearance as well as the benefit of reduced height. This being the case, they will soon become an accepted part of the landscape once the new design becomes familiar. Careful choice of colour can also help integrate them into the landscape.

(b) Undergrounding of 132kv line from Nailsea to Portishead (W route)

3.22 Due to the proximity of development at Stone Edge Batch and Tickenham and blocks of ancient woodland on Tickenham Ridge, National Grid have identified that sections of the WPD 132kV overhead line between Nailsea and Portishead would need to be undergrounded to facilitate the construction of the 400kV overhead line. (a distance of approximately 8 km).

3.23 National Grid have examined two options for undergrounding this route:

- The Green Route which is 10km in length and as being cross country is very direct

- The Blue Route which is within the highway (road) and is much longer (27.6km) due to having two circuits to the south and north of Nailsea Town Centre.

3.24 National Grid favour the Green Route.(see Western Power Distribution 132kV W Route Undergrounding Options Report Vol 5.2) Whilst this route would have greater effects on ecology and would be more likely to encounter unknown buried archaeology, these are not considered to be factors that would rule out the Green Route ( cross country) as they can be mitigated against. Adopting the Green Route will also avoid the greater levels of disruption to the large number of local businesses and residential properties in Nailsea and Portishead that would be affected by the Blue Route ( within highway ) because of installing cables in roads.

3.25 In terms of costs, the Blue Route would incur capital and lifetime costs of approximately £8 to £8.8 million above that of the Green Route. The Blue Route would take 2years and 3 months to complete while the Green Route would take 1 year and 11 months.

3.26 Officer comments: Meetings have been held with National Grid on this topic. Although the full impact on ecology and archaeology from the Green Route needs to be addressed there is agreement with the reasoning behind the adoption of the Green Route. The disruption over a period of 2 years and 3 months of highway closures, diversions etc would potentially have a significant adverse impact on the businesses and residents in the area.

3.27 In order to minimise effects on sites designated for their ecological value and disturbance/displacement to ecology, construction activities will need to be undertaken outside of the most sensitive season and kept to the shortest timescale. In the case of Portbury Wharf Nature Reserve, this would involve ensuring that all construction works within, and adjacent to the reserve, take place outside of the wintering bird season, between the months of April and September inclusive. Hedgerow reinstatement would be required.

3.28 In order to minimise effects on archaeology, a programme of archaeological monitoring and investigation would be required. Physical effects on historic landscape elements (i.e. physical features) could be avoided, or mitigated through archaeological recording, careful reinstatement and, in the case of some hedgerow loss, translocation or appropriate replanting could be used.

(c) Sandford Sub Station New 400 KV Line

132KV lines to be removed

Strawberry Line

New AT route back to WsM Proposed Sandford Site Sub Station Compound

Undergrounding of 400KV line

3.29 The proposed Sandford substation is 143m by 217m in size and located to the west of Nye Road Sandford by Drove Way bridge. The embankments of this bridge are heavily vegetated with trees and shrubs, which would be retained and reinforced with new tree and shrub planting to provide additional screening of the proposed substation from the east.

3.30 Other preliminary landscape mitigation proposals include:

 orchard planting around the northern and western boundaries of the proposed substation, to create a landscape buffer and partial screening to the proposed substation.

 the retention and enhancement of the existing orchard tree planting next to Droveway Farm south of the dismantled railway line proposals would assist in filtering and screening views from the south;

 existing vegetation along the disused railway line would be enhanced with new planting and would be managed to provide improved screening of the proposed substation.

3.31 Officer Comments : The general area for the substation has been agreed and supported by a previous Planning and Regulatory Committee (25 July 2102) with a request that that the substation be gas insulated and grass roofed, so as to resemble a farm building and that measures to assist bat roosting/foraging be incorporated.

3.32 Firstly it is recognised that it is difficult to locate large scale infrastructure of this nature in this landscape and particularly in relation to the nearby Mendip Hills AONB, where there would be filtered or glimpsed views of the proposed 400kV substation. However the assessment records the effects on landscape character and views from higher ground within the AONB would be of no greater than Moderate Adverse Significance ( The assessment has 4 levels of significance – major, moderate ,minor and negligible).

3.33 The effects on the Mendip Hills AONB primarily relate to the panoramic views from footpaths on the edge of Sandford Hill and to a much lesser extent from Banwell Hill. The effects are lower than they may be otherwise be due to the siting of the proposed 400kV substation to the north of existing development at Sandford, notably the expanding development at Thatchers Cider.

3.34 The location takes advantage of lower land and some containment due to the embankment to Drove Way Bridge, but all the other boundaries are fairly open, so there is limited assistance in screening from existing hedges and trees. However the area of works does allow for a substantial space beyond the perimeter fence where preliminary landscape proposals are indicated. Mature trees and hedgerow on lower ground to the north of the Mendip Hills AONB boundary would assist in screening the new substation, and associated 132kV connection, and would help to reduce adverse effects. However Moderate Adverse Effects would arise as the development would introduce a new built form into the landscape.

3.35 It is disappointing that all of the equipment is sited in a compound open to the air, rather than within a gas insulated electricity sub-station which could have contained much of the equipment within a building (not unlike the large scale buildings at Thatchers Cider). It is understood that a gas insulated building is not technically possible due to the inclusion of WPD equipment.

3.36 Therefore careful control of the work and design of the mitigation measures will be needed to ensure that this extensive site sits comfortably within the existing landscape. Indicative underground cable runs outside the compound must be carefully sited to ensure that they do not compete with desired planting sites and preclude tree planting as a consequence. Landscape mitigation proposals for the site will need some refining, but accord with the North Somerset Landscape Character Assessment.

3.37 Management of this site, including construction access, control of vehicle parking and tree and hedgerow protection will be key to maintaining the existing landscape features in good condition prior to further mitigation. Early erection of the perimeter fence is welcomed as this will also aid the protection of the adjacent landscape and potentially allow for the early introduction of new planting, rather than introducing it toward the end of the construction period.

3.38 The plans do not indicate the continuation of the Strawberry Line through the site (which would negate the need for cyclists to use Nye Road) and this is considered to be an appropriate mitigation measure which should be included in the final plans. Similarly as this location is also a popular starting/finishing point for cyclists/walkers it would also be beneficial if a small public car park could also be incorporated into the final design.

(d) Western Power Distribution connection between the proposed Sandford Substation back towards Weston-super-Mare

3.39 The removal of WPD’s 132KV overhead line between Bridgwater and Avonmouth would result in the disconnection of electricity supplies across North Somerset unless remedial works are completed, including the construction of a new Grid Supply 400/132kV substation at Sandford and a connection back to Weston-super-Mare (via the existing 132 KV AT route).

3.40 National Grid have concluded that an underground cable would be preferred from a landscape and views perspective compared to an overhead line connection. (see Western Power Distribution Connection between the proposed Sandford Substation and the existing AT Route Connection Options Report Vol 5.4) Whilst an overhead line option would be preferred from an ecological and archaeological perspective as it avoids the negative effects of the installing underground cables. On the basis of Capital and Lifetime costs, the steel lattice pylons are the most economic.

3.41 Having concluded that the use of underground cables is not justified in this area National Grid have made a comparison made between the two overhead line options. (steel monopoles v steel lattice pylons).

3.42 Whilst the steel monopoles are lower in height than the steel lattice pylons (approximately 22 metres compared to approximately 29 metres), there would be three times the number of monopoles in the landscape compared to the steel lattice structures. The use of monopoles would also require two separate sets of overhead lines extending across the landscape in parallel approximately 25 metres apart, whereas a steel lattice pylon would only require one set of lines. Steel lattice pylons also have greater visual permeability than the monopoles allowing views of background features through the pylons. They are also present in the existing landscape .As a result, the scale of change would be minimised by using steel lattice pylons. Another factor in deciding which overhead line technology to take forward is that steel lattice pylons would cost £1m less in total than the monopoles.

3.43 Officer comments: At the 25 July 2012 Planning and Regulatory Committee it was resolved that an overhead line on wooden poles be supported along the route that National Grid are now promoting. However wooden poles are now no longer considered suitable due to the problem of lighting strikes. Given that the area does not have any specific landscape designation and is already occupied by steel lattice pylons the proposals can be supported.

(e) The Portbury/Portishead option

Undergrounding if Option B chosen

Option B B

Undergrounding of 132 KV Line

Option A 132 KV lines removed

Source: Page 31 of Project Overview Report

3.44 There are two potential routes for the proposed 400kV connection in this section. These are described as the ‘Proposed Route (Option A)’ and the ‘Proposed Alternative Route (Option B)’.

3.45 The existing 132kV overhead lines would be removed as part of a new 400kV overhead line on both the Proposed Route Option A and the Proposed Alternative Route Option B. If Option B is chosen there would be 300 metres of undergrounding in the Nature Reserve required so that the new 400kv line does not cross over the 132 kv line between Portishead and Avonmouth substations.

3.46 Option A Route Description- From its crossing of the M5, the proposed route would run broadly parallel and to the north of the M5 crossing the A369 and following the route of a disused railway before entering the Portbury Docks complex. It would cross the A369 at the cross roads with Station Road/Sheepway where there is a gap in the roadside woodland. A short traverse across fields to the east of Sheepway would bring the overhead line to the disused railway which forms the southern boundary of the Portbury Docks.

3.47 National Grid’s conclusions on the visual impact of Option A are contained in the PEIR Chapter 7 are summarised below (3.48 – 3.52).

3.48 For some viewpoints on the north-western edge of Portbury and in the south of Sheepway a new 400kV overhead line on the Proposed Route Option A would be introduced in views where no overhead lines are presently visible.

3.49 A new 400kV overhead line on the Proposed Route Option A would have an adverse effect on public and private views . The greatest adverse effect on public views would be from the elevated part of footpath LA15/2 where it crosses the M5 motorway and would pass beneath the new 400kV overhead line and from National Cycle Route 26 (PRoW LA15/21) where the new overhead line would run close to the right of way.

3.50 The greatest beneficial effects on public views would be from removal of 132kV overhead lines approaching and around Portishead Substation where views from footpaths and bird hides in Portbury Nature Reserve would receive positive effects.

3.51 The greatest adverse effects on private views would be on views from the warehouse and depots north of the M5 and northwest of its junction with The Portbury Hundred. The new 400kV overhead line would run close to the south of the depots.

3.52 The greatest beneficial effects on private views would be from residential properties on the eastern edge of Portbury Wharf where the 132kv lines are to be removed or undergrounded.

3.53 Option B Route Description - The proposed alternative Route B would largely follow the alignment for the existing 132kV overhead line The 400kV overhead line would run to the east of the present alignment of the 132 kv Route, crossing Sheepway at a point west of Sheepway Gate farm and continue north until it reaches the southernmost extent of the drain ‘Old Sea Bank’, which forms the western boundary of Portbury Wharf residential area. Here it would turn to the northeast and would be at its closest to Portbury Wharf approximately 250m to the east, before turning slightly east. The route continues northeast, passing to the southeast of Portishead substation, turns slightly east again and then sharply southeast the Portbury Docks complex.

3.54 National Grid’s conclusions on the visual impact of Option B are contained in the PEIR Chapter 7 are summarised below (3.55 – 3.57).

3.55 A new 400kV overhead line on the alternative route Option B would have an adverse effect on public and private views. The greatest adverse effect on public views would be from people using the public right of way LA15/22 and on views from footpaths and a bird hide in Portbury Wharf Nature Reserve. A new 400kV overhead line would be closer to these receptors than the existing W Route 132kV overhead line.

3.56 There would be beneficial effects on public views from footpath LA15/15 where three 132kV overhead lines presently in views would be replaced by the 400kV overhead line and from a bird hide on Portbury Wharf Nature Reserve.

3.57 The greatest adverse effect on private views would be from residential properties where the new 400kV overhead line would be closer than the W Route 132kV overhead line which would be removed.

3.58 Officer Comments: The previous consultation undertaken by National Grid in Nov 2012 only contained Option A and the P & R Committee in December of that year resolved that “the full impact on Portbury and Sheepway needs to be assessed and mitigated by careful pylon design and positioning;” Given that another option is now proposed a comparison of the effect of the two options is required.

3.59 The main issue is the differing visual impact of these options although there are differences in cost ( Option A £5.3m , Option B £7.7m) and also the ecological impact on the Portbury Wharf Nature Reserve to consider In the opinion of Arup who are advising the Council on ecological matters ,the impact on the nature reserve from the 300m undergrounding is unclear at present (see 3.89) and therefore given its status as a Site of Nature Conservation Importance and adjacent to the Severn Estuary European Marine Site (Ramsar Site , Site of Special Scientific Interest) it is not possible to be conclusive at this stage as to the preferred option .

3.60 The published material shows that the existing 132kV overhead lines in the area, together with Portishead substation and dockland development beyond, reduces the sensitivity (susceptibility to change) of this landscape to the proposed overhead line as compared to one without such development, particularly as the Bridgwater to Avonmouth 132kV overhead line and the W Route 132kV overhead line would be removed (the latter replaced by underground cables), as part of a new 400kV overhead line. There are therefore strong grounds for retaining a route that relates closely to an existing corridor and has less impact on local communities, albeit longer than the alternative and requiring more pylons.

3.61 At present, on the eastern edge of the Ashlands development, residential properties are at their closest approximately 125 metres from the nearer of the two 132KV lines, If Option B was to be chosen these 132KV lines would be replaced with one 400KV line considerably further away (125m – 275 m) but on T pylons that would be approximately 10 metres higher. These T pylons would also be particularly visible form the nature reserve. If Option A was chosen then the eastern edge of the Ashlands development would be free of pylons but would necessitate the introduction of pylons in a more prominent landscape adjacent to the M5 motorway where at present there are none present.

3.62 Representations have been made by Portbury Parish Council in respect of the adverse impact of Proposed Route Option A on the north side of the village, from the public rights of way, particularly west and east of the village and crossing the bridge over the M5 motorway, the church, and Elm Tree Park (mobile home park) to the north side of the motorway and A369. At its closest Elm Tree Park would be located approximately 125 metres from the proposed 400 KV line and properties at the junction of Station Road and The Portbury Hundred would be even closer.

3.63 Your officers share the concern of Portbury Parish Council that pylons on Proposed Route Option A would be visually intrusive. They would be harmful to the setting of the church and village as, due to their height, they would not be screened out by existing vegetation in the same way the M5 is.

3.64 The photomontage from the M5 over-bridge (see Photomontage Viewpoint vpe10 - Proposed Route Option A) confirms the impact, with the pylons highly visible in series as they climb parallel with the M5 before crossing it to rise up Caswell Hill. See also the alternative photomontage for Route Option B (Photomontage Viewpoint Vpe10 -Alternative Route Option B). This shows a significantly reduced visual impact upon the M5 route corridor (an important route into North Somerset and the Southwest) and upon Portbury Village and Sheepway.

3.65 The magnitude of effect upon the landscape of Option A is recorded as Moderate Adverse and High Adverse on the edge of Sheepway, whereas Option B is Moderate Adverse reducing to Low Adverse or Negligible with distance (including a moderate adverse effect on the setting of Tickenham Ridge on higher ground).

3.66 Because of the visual impact upon Portbury Village and dwellings to the immediate north of it, there are strong landscape reasons (backed by the landscape assessment) to dismiss the Proposed Route Option A and select the Option B alternative. Option B also avoids minor adverse effects reported on 8 listed buildings.

3.67 However if Option B is chosen as the final route then the alignment of the Option B Alternative route moved further west to ensure that the lines do not directly pass above the former railway bridge at Sheepway. This will help to lessen their impact from this elevated viewpoint and from properties in Sheepway (See Photomontage Viewpoint Vpf3 - Alternative Route Option B).

(f) Traffic and Transport

3.68 To facilitate the proposed development there is a requirement to transport people, plant and materials to and from the proposed development sites. Chapter 12 of the PEIR includes the assessment includes the identification of sensitive receptors, roads and access points likely to be affected, the extent of any likely effects, and potential mitigation measures to reduce or remove identified effects at this stage. This chapter will eventually be replaced by a detailed Environmental Impact Assessment and Transport Assessment that will assess the impacts of the proposed development in regards to any potential effects associated with traffic and transport.

3.69 The chapter identifies the main routes for construction traffic, and the temporary access arrangements that will be required to facilitate the development. It is planned to keep construction traffic on the highway to a minimum especially the quieter country lanes. The construction will be undertaken in phases so that impacts are localised. On the 8km underground route a purpose built haul road will be constructed. A number of traffic management measures and mitigation techniques are proposed which include:

 wheel washing facilities  provide highway improvements to improve capacity if required.  place additional signage in the area as necessary.  traffic routing and management agreements with North Somerset  travel planning initiatives

3.70 Mitigation will be extensive throughout the proposed working corridor and along all construction routes providing access to the development. As such it is likely that in a number of circumstances the level of impact will be reduced, however, there are likely to be a number of slight and moderate residual, adverse environmental effects that cannot be fully mitigated against. These primarily include those relating to severance, driver, pedestrian and cyclist delay. However, these effects will be mitigated against wherever possible and are only likely to be temporary effects during the construction works and are not associated with the operation of the proposed development.

3.71 Officer Comments: Your officers have held a number of meetings with National Grid and have provided detailed comments on the various traffic issues. However “ in principle agreement” with any of the proposed access arrangements and routing of any Abnormal Indivisible Loads (AILs) to Sandford Sub station must await the submission of the Environmental Impact Assessment and Transport Assessment and further information on the capacity assessment of key junctions.

(g) Proximity to residential properties

3.72 Many residents have expressed concern about the health impact of electro- magnetic fields (EMF’s) from high voltage overhead lines. In developing the draft route National Grid has sought to route as far as possible from residential properties on the grounds of general amenity. UK law does not prescribe any minimum distance between overhead lines and homes. National Grid does however ensure that all overhead lines are designed and built to comply with all relevant health and safety legislation. In the UK the Health Protection Agency has the responsibility to advise on standards of protection for EMFs. National Grid will as part of the Environmental Impact Assessment undertake an assessment of the EMFs for the proposed new overhead line to ensure that any proposed route complies with the EMF exposure guidelines published by the International Commission on non- ionizing Radiation Protection (ICNIPRP) which are adopted by Government.

3.73 The undergrounding of the line through the Mendip Hills AONB and one of the 132 KVlines from Nailsea to Portishead realises significant benefits for those localities and their residents. In general, apart from three specific areas ( Moorland Park, Congresbury Tickenham village and Portbury if Option A chosen) , the proposed line is not significantly closer to residential properties than the existing 132 KV line and in some instances the line has been purposely moved to increase distance away from properties. Existing 132 KV line

Proposed 400KV Line

Moorland Park Source: Page 27 of Project Overview Report 3.74 At the December 2012 P & R Committee it was resolved that: “further investigations should be undertaken to assess the impact on the residents of Moorland Park Congresbury with a view to moving the line further east”. The extension of this gypsy and traveller site was (subject to as yet unsigned Sec 106 agreement) granted temporary consent until 31 December 2013. The proposed line with its higher voltage and taller pylons runs very close to this site. Although the existing line is very close to the site, this exercise does give the opportunity to move the line further away from a substantial population. It appears that the line could be moved further east without too many consequential effect such as bringing the line closer to other residential properties or resulting in greater harm to the landscape.

(h) Impact on the Historic Environment

3.75 Chapter 11 of the PIER provides a preliminary assessment of the likely significant effects of the proposals on the historic environment e.g. archaeological remains, built heritage, and historic landscape character and features. Effects assessed in this chapter include potential permanent and temporary effects, and include potential direct physical effects as well as indirect effects (for example from noise, visual, or traffic related changes). These effects are assessed for the construction, operation and decommissioning phases of the proposed development.

3.76 National Grid have concluded that overall, the proposed development would have an adverse effect on the historic environment, affecting a range of assets in all three of the sub-disciplines: archaeological remains, built heritage, and the historic landscape. In North Somerset the greatest impact will be on the listed structures around Tickenham Church and the listed buildings in the vicinity of Stone Edge Batch which may experience adverse effects that would be equivalent to substantial harm, in national policy terms.

3.77 National Grid have stated that the following mitigation measures may be employed to offset any impacts:

Enhancement of the historic environment and specific assets through improved access; Enhancement of public understanding and appreciation through provision of interpretation materials (i.e. popular publications; interpretation boards); Enhancement of public understanding and appreciation through public outreach events or open days; Offsetting payments as setting mitigation; and Production of and adherence to Monument Management Plans.

3.78 Officer Comments: There has been extensive liaison between National Grid and specialist officers from the affected authorities. Further investigations to assess the full impact on the historic environment are required and will form part of the Environmental Statement that will accompany the submission to the Planning Inspectorate in 2014. These investigations will need to fully address and specify the mitigation measures need to offset the impact of the proposals.

3.79 The historic environment assessment includes numerous statements indicating that further assessment will be carried out including Geophysical Survey and Trial Trench Assessment. This indicates that full assessment has not yet taken place and assessments of impacts must therefore be considered preliminary. The DCO submission must fully describe the results of these surveys and the results shared with archaeological officers as they become available and in advance of the main DCO submission.

3.80 In addition there does not appear to be any analysis of the impact on roadside structures from the delivery of Abnormal Loads and there is an absence of detail on how the impact on the setting of Tickenham Church can be mitigated.

3.81 The Tickenham Court area which includes Grade I listed St Quiricus and Julietta’s Church, is an ‘island’ in an area of marshy moorland. The setting of this site is crucial to understanding its significance. The scheme proposes adding pylons running along close to the south of the church in a NE/SW direction through the lower lying moor along a mid line through the moor with residential development of Nailsea to the south. A ‘T’’ Pylon Tower would be located around 320m to the South East. These pylons would replace an existing double line of existing steel lattice towers that presently run closer and beside Nailsea.

3.82 The submission assesses the church to be of Very High Heritage Significance and the effects to the church to be Major Adverse. Some mitigation measures should be considered which might include:  Moving the line further away from the church  Through use of photomontages (view points to be agreed) consider potential effects of different colours to the T pylons. Is it possible that they may be less apparent when seen against the church and from the church against the landscape if a different colour.

(i) Biodiversity and Nature Conservation

3.83 Chapter 8 of the PEIR provides a preliminary assessment of the potential effects of the proposed Hinkley Point C connection on biodiversity and nature conservation interests using information derived from ecological surveys and consultations, the route of the connection, associated substation and 132kV works has been designed to avoid significant effects on the ecology of the area.

3.84 In the absence of mitigation there is potential for moderate to high effects on aquatic habitats and species (invertebrates, water vole, otter, European eel and amphibians) as a result of works affecting SSSI ditches and rhynes, and aquatic habitat and watercourses in general. There is also potential for moderate to high effects upon bats and moderate effects on breeding birds as a result of hedgerow removals to create crossings for works access, for underground cable installation and for substation construction.

3.85 Several local wildlife sites will be overflown by the new overhead line (or will have pylons installed) and there may be effects on plant communities and species assemblages during construction. These effects are largely associated with the construction phase of the development and are temporary or short term. Furthermore, many potential impacts can be avoided through appropriate working practices, to retain or protect hedgerow and watercourse habitats, or mitigated through replacement habitat.

3.86 Officer Comments It is proposed that the DCO will include an “Ecological Mitigation Plan “ which will set out the residual adverse effects on habitats and species and how through mitigation and compensation e.g. habitat creation and management measures the harm from the development can be reduced. Discussions with National Grid over the coming months will examine the proposed mitigation plan in detail

3.87 It is clear that considerable effort has been made to survey the areas likely to be affected by the proposed 400KV connection, it is not however clear if similar effort has been made for the proposed undergrounding of the existing Western Power Distribution 132KV cable from Nailsea to Portishead. The potential impacts of this section of the proposed route alignment are not clearly presented and the PEIR does not provide an assessment of the significance of effects or details of mitigation proposals. It is thus unclear what significant effects would occur and whether the mitigation would be sufficient to reduce the impacts to acceptable levels.

3.88 The surveys reported within the documents have broadly been undertaken in accordance with relevant published guidance. However, the method for assessment does not explain in sufficient detail how impacts are to be judged significant or not. In addition, it is unclear which impacts are targeted for mitigation measure. It is expected that where any adverse effects arise, these would be mitigated as far as possible.

3.89 The assessment of impacts of the 132 kV underground works on the Portbury Wharf Nature Reserve (designated as both Site of Nature Conservation Importance and is adjacent to the Severn Estuary European Marine Site) does not include the loss of habitats, effects on invertebrates or water voles, all of which are reasons for the designation of this area. The potential effects listed on this site are restricted to birds in terms of collision with overhead wires or displacement through disturbance. This inference of the reporting is that the potential effects of the 132kV undergrounding (if Option B is chosen) have not been considered, although there is some reference to open cut works and permanent changes to hydrology.

3.90 Given the volume of outstanding survey material within the baseline it is not considered that sufficient information has been presented at this stage to confirm what significant effects may occur and therefore what mitigation measures would be required.

(j) Landscape and Visual Impacts

3.91 Chapters 6 and 7 of the PEIR provides a preliminary assessment of the likely significant effects of the proposed development on landscape character and the overall visual impact.

3.92 The report concludes that the proposed 400KV overhead line would result in direct adverse effects on landscape character across the project study area due to the introduction of a linear development (comprising conductors suspended from arms on supports at regular distances). Overall this would affect landscape character adversely by presenting a manufactured and functional form into rural and urban landscapes. In the majority of instances, the new 400KV overhead line would be introduced into a landscape where there is at least one existing overhead line. This means that the landscape character overall has a lower sensitivity (susceptibility to change) to the proposed development that would arise as compared to landscapes where there are no overhead lines. The greatest adverse effects would arise where the new 400kV line deviates from the route of the existing 132kV Bridgwater to Avonmouth overhead line which would be removed. e.g. Portbury Option A.

3.93 Removal of 132kV lines would bring beneficial effects where it occurred. In most instances this would be accompanied by the introduction of the proposed 400kV overhead line resulting in an overall adverse effect on landscape character. Where no new 400kV overhead line would be installed, because 400kV underground cables would be used or because the new line would be installed along a different route to the 132kV overhead lines removed, National Grid have concluded there would be an overall beneficial effect. e.g. Nailsea Moor south of Tickenham Ridge, Clapton Moor.

3.94 Higher ground, e.g. Tickenham Ridge area can provide backgrounding to the proposed 400KV overhead line, which would assist in reducing the influence of a new 400KV overhead line in the landscape.

3.95 Construction of the proposed 400KV overhead line would likely result in adverse effects on trees and hedgerows along field boundaries, along watercourses such as the drains and ditches or rhynes across the Somerset Levels and Moors, along roads for example Cadbury Camp Lane on Tickenham Ridge, and the A369. There would also likely be some tree loss on the on the northern edge of Mogg’s Wood on Tickenham Ridge. Trees and hedgerow would be lost to allow construction access and in some places would remain absent or cut low to achieve the electrical safety clearances required.

3.96 Officer Comments: A ‘Landscape Strategy’ for mitigation planting along the proposed 400kV overhead line route will be produced as part of the Environmental Statement which will accompany the formal submission of the proposals to the Planning Inspectorate in early 2014. This strategy will include indicative proposals for tree and shrub planting that will assist in reinforcing landscape character in certain areas and separately that would provide screening of some views of the new overhead line. The development of the Landscape Strategy will form part of discussions with National Grid over the coming months.

The Landscape Strategy will include:   Suggested locations and type of mitigation planting;  Specifications for plants to be used;  Landscape maintenance schedules detailing the maintenance activities to be undertaken during the establishment period; and  Future landscape management schedules to be carried out by the owner.

3.97 It is disappointing that this strategy isn’t more developed and is not therefore available for public comment. The mitigation strategy is currently incomplete, largely comprising secondary screening for substation and sealing end compound locations. Although broad areas of hedgerow and tree loss have been identified, the PEIR only commits to replacement of tree and hedgerow planting where possible and subject to landowner agreement. This could result in some significant fragmentation of traditional field hedge boundaries unless such agreement is secured, resulting in a very visible swathe across the landscape following the construction corridor.

3.98 Further work and engagement with all the affected councils is required in respect of developing this mitigation strategy. The proposed undergrounding works in the Mendips have potential to create an adverse visible feature within the landscape where reinstated ground, ground cover and replacement field boundaries have potential to create visual cues as to the route of the cables for a considerable period of time. This impact is currently not assessed and therefore the full scope of mitigation measures has not been presented. The proposals will also give rise to negative effects on the landscape as viewed from the Strawberry Line and potential measures to mitigate this impact could include reinforcement planting and this requires further discussion and agreement. It is vital that mitigation measures are agreed as soon as possible with local authorities and other consultees prior to engaging with landowners.

3.99 In North Somerset, the expectation is that there should be at least like for like hedge planting (or better in terms of species content) along the full extent of removed hedges. Where landowners require replacement secure boundaries to protect young hedges from stock, these should be of a more temporary nature (post and wire), rather than potentially intrusive post and rail fences (except where these already occurred). There should be no option offered to landowners not to replace any removed hedge, because of the harmful effect upon both landscape and wildlife.

3.100 Where walls are breached, the reconstruction should be like for like (or better) using the reclaimed materials. Where new materials are necessary they must match the existing and materials samples should first be agreed. This is necessary to help protect the character of the area. Note that different stone occurs across North Somerset and it is expected that such variations should be taken into account in any proposals.

3.101 Some of the conclusions on residual effects would have to be re-assessed if the full restoration of significant landscape elements, such as hedgerows, was unable to be realised.

CONSULTATION

(i) Consultation to date

4.1 All the consultation to date has been pre- application consultation which is a principal element introduced by the 2008 Planning Act. The Act imposes duties on the promoters of NSIPs to consult those who would be directly affected by the project, people with an interest in the land on which development would take place, the local community, local authorities and other statutory bodies and consultees. While the Act specifies particular requirements for formal consultation, the importance of informal consultation is recognised in related guidance and has been embraced by National Grid in its extensive programme of engagement and consultation on the development of the project to date.

(ii) The current consultation

4.2 The current consultation is undertaken in accordance with section 47 of the Planning Act 2008, which requires National Grid to consult people living in the vicinity of the proposed development, including those who work in or otherwise use the area. The exact details of the consultation arrangements are set out in the Statement of Community Consultation (SOCC) which has been agreed with all the affected authorities. The current consultation period runs from Tuesday 3 September to Tuesday 29 October 2013.

The following consultation methods have been adopted:

-project update newsletter delivered to all households within 1 kilometre of the route;

- standard feedback form;

- availability of a freephone telephone number;

- an interactive website with summary reports ;( linked also from the Council’s website)

- social media such as twitter, facebook;

- advertisements in the local press and press releases

-Emails to registered users ;

-Exhibitions/public meetings along the route

-mobile information vehicle;

- local community forums

- dedicated public relations team

(iii) What happens next?

4.3 After the consultation National Grid will consider any comments, review the proposal and make any final adjustments. They will also finish their environmental studies and technical assessments. They plan to submit the application to the Planning Inspectorate in early 2014 and will include a report on the consultation and how they have taken any comments into account.

(iv) Local Councils views

4.4 Town and Parish Councils are also being consulted by National Grid. Unfortunately the Council calendar is such that North Somerset Council are probably the first council to formally consider these proposals and therefore it is difficult to report and take into account any views expressed by local councils. Local councils have been requested to forward their comments to North Somerset and in the recommendations to this report, delegated authority is sought to expand on the Council’s submission to take account of any material and significant concerns expressed by local councils.

FINANCIAL IMPLICATIONS

There are no financial implications. In accordance with government advice staff time and resources spent on this project are being reclaimed through a Planning Performance Agreement.

RISK MANAGEMENT

Any delay in the programme could result in a consequential delay for National Grid in submitting their application in early 2014 with a consequential impact on their construction timetable.

EQUALITY IMPLICATIONS

Council officers have been advising National Gris on contacting hard to reach groups.

CORPORATE IMPLICATIONS

There are no known corporate implications.

OPTIONS CONSIDERED

Since September 2011 National Grid have put forward a number of route corridor options and through a Strategic Option Report have justified why a number of possible options e.g. subsea, were ruled out on technical and cost grounds and not formally consulted upon. Earlier in 2012 there were a number of options put forward for the sub-station in the Sandford/Churchill area and how this could be connected to the wider area.

At this particular stage there are no further options put forward by National Grid.

AUTHOR

Graham Quick Local Planning Team Leader 01934 426177

BACKGROUND PAPERS Planning and Regulatory Committee 26 November 2009, 21 July 2010, 25 July 2012 and 5 December 2012.

All the National Grid Documents are available on their website http://www.hinkleyconnection.co.uk/default.aspx