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Shropshire Council FREEPOST Planning Services NATIONAL GRID MID W CONNECTION Shirehall Abbey Foregate Shrewsbury SY2 6ND 9th February 2015 Your ref; Dear Mr Lee, RE: APPLICATION BY NATIONAL GRID FOR AN ORDER GRANTING DEVELOPMENT CONSENT FOR THE MID WALES ELECTRICITY CONNECTION STATUTORY CONSULTATION UNDER S42 AND S47 OF THE PLANNING ACT 2008 I refer to your letter of 22nd January in respect of the above consultation. As you are aware this council has been working with the National Grid team in identifying the impacts of this planned project for Shropshire. Shropshire Council has the status as of a prescribed consultation body under Regulation 9 of The Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 (as amended). As part of the S42 consultation this work has included liaison with the Shropshire Councillors whose divisions are impacted by the proposals, stakeholder representatives and consultation with internal specialists. We also have established links with Powys and the two Councils are collaborating to ensure information is shared about the project between England and Wales. In drawing this response together these are a number of areas where further work is required to enable a thorough and objective consideration of the impacts of the proposal and these are outlined further throughout this consultation response. This project has been developed over a number of years with initial community consultation on route corridor options taking place in 2011. Shropshire Councils position on this project was first set out its response to National Grids informal consultation on route corridor options which ran between March and June 2011. A Summary of the Key Points Shropshire Council: Notes the National Grid position that it will look carefully at the outcome of the inquiry into Powys windfarms and if it’s established that there is no longer a need for a connection then it would not be built. Considers the impact of the proposed high voltage pylons and transmission lines, newly introduced to this part of Shropshire for the first time, to severely impact on the local landscape character, potentially for many generations to come. Identifies the following 3 pinch points of the route as highly vulnerable to environmental impacts: 1. Llanymynech environs 2. Maesbury Marsh to the crossing of the A5 and featuring the canal environment 3.The Tee point at Berghill Notes National Grid’s preference for use of the T pylon in Shropshire over that of low height lattice pylons. However the Council believes more work is needed on the effect of pylon colour, comparison of impacts of angle pylons for both designs and an assessment of a number of current uncertainties regarding the untested T pylon before a final decision is made on its use in Shropshire. Does not consider the cumulative traffic and transport effects have been adequately established particularly given the likely overlap between this and wind farm projects in Mid Wales – a “worst case” scenario should be evaluated as part of the Environmental Statement having regard to these cumulative impacts. Requires a comprehensive impact mitigation scheme consisting of both on- site and off-site environmental and community mitigation measures to address all identified significant adverse effects. When loss of vegetation, hedges and trees cannot be avoided, requires such loss to be re-instated or, where this is not possible, as close to the loss as practicable and in any case avoiding the appearance of a swathe of landscape change along the route. Advises National Grid that some natural assets, such as ancient semi- natural woodland and ancient trees are irreplaceable Requires the essential elements of any planting scheme to be demonstrably deliverable either by Requirement or Planning Obligation or a form of legal agreement, and maintainable over the life of the project Is concerned that impacts are defined separately within the consultation material making a cumulative assessment of these difficult Is concerned that where impacts or policy considerations pull in different directions it is difficult to see how these have been objectively assessed That detailed evidence of the Social, Economic and Environmental Impacts of alternative designs including T pylon, low height lattice are not evaluated against any alternative Issues concerning the transmission via 132kV on wooden poles as an alternative to 400Kv has not been explained as part of the consultation 2 process or evaluated in detail having regard to the Social, Environmental or Economic impacts. Seeks the establishment of a Community Impact Mitigation Fund to address uncertain and intangible impacts, as well as those impacts not capable of mitigation through other means. It would directly focus on delivery to the communities most affected by the development and experiencing loss of amenity. Requests that National Grid work with the Council to promote local skills, training employment and business opportunity to the mutual benefit of our community and National Grid. Requests that should changes to the route be required following consultation, that these are considered alongside a back check review of corridor options where this may result in an improved alignment and where localized undergrounding solutions might thereby become justifiable. Seeks potential health risks, and general community well-being and amenity, is a consideration of the Environmental Statement and is properly evaluated and mitigated. Is highly concerned that the tourism and visitor economy so vital to Shropshire is severely compromised by the proposed overhead line. There is little indication of how this has influenced the design and route alignment, and what mitigation is proposed. Has significant concerns over the potential impact to the setting of historic assets and potential for direct impacts to known and unknown archaeological assets. Has concerns over the implications for flood risk in particular a view that the infrastructure required to construct the wind farms will contribute to more surface water run-off and exacerbate flood events particularly at the confluence of the River Severn and River Vyrnwy. Overview of Shropshire Council’s Position regarding the Mid Wales Connection project to date Cabinet Report 15th June 2011 The Councils Cabinet considered a report on the strategic issues and impacts at that time. Cabinet resolved that the impact of a 400kv overhead line connection was considered to be significantly detrimental and totally unacceptable to Shropshire Council which would object on these grounds to an overhead line solution. As the project developed the route corridor was selected and further refined and a decision taken by National Grid to underground a section of the proposed line through Mid Wales in the Meifod valley but no undergrounding is proposed through Shropshire. While Shropshire Council has continued to work with National Grid to identify the impacts of the scheme, the fact that no undergrounding in Shropshire is a significant disappointment for Shropshire Communities. 3 Shropshire Council also set out a number of key issues raised by members and in representations received by local communities and interested parties at that time for National Grid to consider in its 2011 response. These issues are set out below for information (not all will fall within National Grids remit as promoter of this scheme): The integrity and validity of TAN 8 promoting wind farm development was criticized by a number of speakers and in particular the fact that Shropshire was not consulted on this document and nor were the strategic infrastructure implications considered when TAN 8 was published. The efficiency of wind turbines as a means of providing a reliable and sustainable contribution to the nations power supply was questioned. Visual impact and impact on the landscape of pylons – in particular the 400kv 45m design. The implications for flood risk in particular a view that the infrastructure required to construct the wind farms will contribute to more surface water run-off and exacerbate flood events particularly at the confluence of the River Severn and River Vyrnwy. That the consultation process is flawed and divisive setting one community against another. In addition the project news brochure titled “Mid Wales Connection” is believed by some to have been misleading and inadequate. That National Grid has failed to evaluate the alternative options placing too great an emphasis on the economic cost of providing the connection That potential health risks have not been properly evaluated or considered That tourism and the visitor economy play a key role in Shropshire and this would be compromised if an overhead line solution is promoted That the Government is not looking at the issue of energy generation holistically and there is inadequate coordination between energy generation and transmission projects That the benefit arising from any planning obligation should the development affect Shropshire should go to the communities most affected. Adverse impact on a low wage economy That traffic concerns have not been properly assessed That the IPC process has not been properly explained Motion to Council passed by Shropshire Council in respect of the cumulative impact of Windfarms in Mid Wales 28th February 2013 At the meeting of full Council on 28th February 2013 Members supported a Motion expressing their deep concerns as to the potential detrimental impact in Shropshire of the cumulative effect of the proposed wind
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