Public Document Pack

Stephen McGrath – Member Services Manager General Enquiries: Telephone No. 01362 656870 Member Services Fax No. 01362 690821 DX743950 2

To The Chairman and Members of the Your Ref: Development Control Committee Our Ref: HM/L.3.4

All other Members of the Council – for information Contact: Helen McAleer Direct Dial: 01362 656381 E-mail: helen.mcaleer @breckland.gov.uk Date 01 October 2010

AGENDA SUPPLEMENT

Dear Sir/Madam

DEVELOPMENT CONTROL COMMITTEE - MONDAY 11 OCTOBER 2010

I refer to the agenda for the above-mentioned meeting and enclose the following items:

Item No Report Title Page Nos

10. ///Stanfield//Beeston/Gre 79 - 84 at Dunham/Kempstone//: Proposed Underground Electricity Cable System for Dungeon Offshore Wind Limited: Reference: 3PL/2009/1189/F

Report of the Deputy Chief Executive.

11. Necton: Land Off Necton Road, Little Dunham: Proposed 85 - 95 Electricity Substation for Dungeon Offshore Wind Limited: Reference: 3PL/2009/1188/O

Report of the Deputy Chief Executive.

Yours faithfully

Helen McAleer

Senior Committee Officer

Breckland Council, Elizabeth House, Walpole Loke, Dereham, NR19 1EE www.breckland.gov.uk

Breckland Council, Elizabeth House, Walpole Loke, Dereham, Norfolk NR19 1EE www.breckland.gov.uk

Agenda Item 10

BRECKLAND COUNCIL

DEVELOPMENT CONTROL COMMITTEE – 11 TH OCTOBER 2010

REPORT OF DEPUTY CHIEF EXECUTIVE (Author: Nick Moys, Principal Planning Officer (Major Projects))

COLKIRK/HORNINGTOFT/WHISSONSETT/STANFIELD/MILEHAM/BEESTON/ /KEMPSTONE/LITTLE DUNHAM/NECTON PROPOSED UNDERGROUND ELECTRICITY CABLE SYSTEM Applicant: Dungeon Offshore Wind Limited Reference: 3PL/2009/1189/F

Summary – This report concerns proposals to construct an underground electricity cable linking an offshore wind farm to a proposed substation at Little Dunham. Key issues relate to potential effects on the rural landscape, ecological interests and residential amenity. It is recommended that permission is granted.

INTRODUCTION 1.1 This report concerns an application for full planning permission for the construction of part of a new underground electricity cable system linking a proposed offshore wind farm to the National Grid at Little Dunham. Separate planning applications have been submitted respectively to Breckland Council and District Council for an associated substation at Dunham and the remainder of the onshore cable route.

1.2 The applicant has been awarded rights by The Crown Estate to develop an offshore wind farm in the Greater Wash Strategic Environmental Assessment area. This award is subject to the applicant being successful in gaining the necessary planning and licence consents for the construction and operation of the wind farm. The wind farm proposed at Dudgeon would cover an area of around 35km 2 (approximately 168 wind turbines) and will have a generating capacity of 560MW. Applications for environmental and other consents required for the offshore elements of the wind farm are currently being determined by the Department of Energy and Climate Change (DECC) and the Department for Environment, Food and Rural Affairs (Defra). A further phase of wind farm development at Dudgeon is also being contemplated by the applicant.

1.3 The onshore cable route would be around 45km in length, of which 17km would fall within Breckland and the remaining 28km in North Norfolk. The cable route would run through agricultural land, skirting around a number of villages, and passing through the parishes of Colkirk, Horningtoft, Whissonsett, Stanfield, Mileham, Beeston, Kempstone, Great Dunham, , Little Dunham and Necton. The cable route would cross public roads at 13 locations, including the B1446 at Colkirk and the B1145 at Mileham. The proposed cables would be laid in up to 4 trenches to a depth of around 1.3 metres, spanning a 16 metre wide strip, within an overall working corridor of 40 metres. This arrangement is based on an AC system. Should a DC system be adopted, the number of cables/trenches would be reduced. Most of the cable would be laid in open trenches, but, where this would not be

79 practical, horizontal direct drilling (HDD) is proposed. Compounds for the temporary storage of materials are proposed at Mileham and Little Dunham.

1.4 Both the proposed substation development and the onshore cable works are proposed in two stages to correspond with anticipated offshore development in the Dudgeon area. Stage 1 would provide onshore infrastructure to support the current offshore wind farm proposals with an output of up to 560MW. Stage 2 would support a further phase of offshore wind development at Dudgeon, resulting in a total offshore capacity of up to 1,400MW. Applications have not yet been made for this second phase of development.

1.5 The application is supported by an Environmental Statement (ES), a Statement of Community Involvement, and a number of Technical Notes. The Environmental Statement includes detailed assessments of the proposed development on nature conservation, rural landscapes, archaeology, ground conditions, traffic, noise/vibration, dust and air quality and communities/recreation/tourism.

KEY DECISION 2.1 This is not a key decision.

COUNCIL PRIORITIES 3.1 The following Council priorities are relevant to this report: • A safe and healthy environment • A well planned place to live and work

CONSULTATIONS 4.1 Colkirk Parish Council has raised no objection to the application.

4.2 Horningtoft Parish Council has raised no objection to the application.

4.3 Beeston Parish Council has raised no objection to the application, subject to details of the proposed construction compounds.

4.4 Necton Parish Council has objected to the application on grounds of increased traffic associated with the whole project.

4.5 Little Dunham Parish Council has raised objection to the application subject to the outcome of substation application.

4.6 No comments have been received from Whissonsett, Stanfield, Mileham, Great Dunham and Kempstone Parish Councils.

4.7 The Highway Authority has raised no objection subject to a condition requiring a Construction Traffic Management Plan.

4.8 Norfolk County Council has raised no objection to the proposals, subject to conditions relating to external lighting and wildlife mitigation.

4.9 The Environment Agency has raised no objection to the application subject to conditions relating to contaminated land and pollution control.

4.10 Natural has raised no objection to the application subject to conditions relating to wildlife protection and ecological mitigation.

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4.11 Norfolk Wildlife Trust has raised no objection to the application, subject to appropriate ecological mitigation measures.

4.12 Norfolk Landscape Archaeology has raised no objection subject to a condition requiring a programme of archaeology evaluation.

4.13 The Ramblers Associations has made comment on the effects of the proposals on existing public footpaths.

4.14 The Tree & Countryside Officer has raised no objection to the proposal subject to the conditions relating to wildlife mitigation, reinstatement of hedgerows and geodiversity recording.

4.15 The Council’s Contaminated Land Officer has raised no objections.

4.16 The Council’s Environmental Health Officer has raised no objections.

4.17 Written representations have been received on behalf of a number of landowners raising concerns about detailed changes to the cable route, the proposed phasing of the development and the resulting prolonged impact on soil structure and rural landscapes.

POLICY 5.1 Relevant national planning policy can be found in PPS1 ‘Delivering Sustainable Development’, the Supplement to PPS1 ‘Planning & Climate Change’, PPS 7 ‘Sustainable Development in Rural Areas’, PPS 9 ‘Biodiversity & Geological Conservation’ and PPG 22 ‘Renewable Energy’.

5.2 Relevant local planning policies include Policy DC15 of the Council’s Core Strategy & Development Control Policies DPD which supports renewable energy proposals subject to criteria relating to landscape impact, residential amenity and conservation of ecological/heritage interests. Other relevant policies include: Policy CP10 (Natural Environment), Policy CP11 (Landscape protection), Policy DC1 (Amenity) and Policy DC12 (Trees & Landscape).

ASSESSMENT 6.1 The principal issues raised by the application concern the effects of the proposals on: i) the character and appearance of existing rural landscapes, ii) wildlife interests, and iii) residential amenity. National planning policy on renewal energy projects provides a wider context for the consideration of these issues.

Landscape impact 6.2 A detailed assessment of the long and short term impacts of the installation of the cables is included within the ES. The landscape through which the cable route would pass is predominantly arable farmland, with hedgerow boundaries and interspersed with small blocks of woodland. The Council’s Landscape Character Assessment (LCA) identifies two landscape types along the cable route: Settled Tributary Farmland and Plateau Farmland. Core Strategy Policy CP11 requires these landscapes to be protected for their own sake, having regard to the findings of the LCA, but they are not afforded special protection by local or national designation/policy.

81 6.3 In the short term, it is considered that the development would result in some visual disruption to the landscape due to the excavation of trenches, storage of spoil/materials and presence of plant and machinery. However, this effect would be transient. The cable laying process is relatively quick, with trenching, installation and reinstatement being undertaken as a continuous operation. Typically, around 100m of cable would be laid per day per gang.

6.4 The proposed satellite construction near Mileham would have some adverse effects on the appearance of the area, but given its size, set back from the road and temporary nature, these effects would not be significantly harmful. The cable compound at Little Dunham would effectively form part of the substation site, the impact of which is considered separately.

6.5 In the long term, the impact of the proposal on the rural landscape would be minimal, due mainly to the cables being buried underground. Following cable installation, ground surfaces would be restored to their former condition as soon as possible. Following completion of the cable installation process, the only visible sign of the development would be a series of inspection covers or small equipment cabinets located every 700m or so. Some tree and hedge removal is proposed, but this would be limited in extent and replacement planting is proposed. Where trees would be removed, they would be replaced on a 5 to 1 basis. No TPO trees or woodlands are affected by the proposal.

6.6 Overall, it is considered that the proposal would not cause any significant harm to rural landscapes and in this respect would comply with relevant planning policies.

Ecology 6.7 Extensive habitat and species surveys have been undertaken to enable the ecological impact of the proposal underground cable to be assessed. The proposed cable route has been designed to avoid designated conservation sites wherever possible. No SSSIs within the vicinity of the cable route would be affected by the proposals, and only one locally designated site would be crossed by the cable: a disused railway line designated as a County Wildlife Site. HDD would be used here to minimise the impact. In response to concerns raised by Natural England about measures to minimise impacts on protected species, an Ecological Mitigation Summary Report has been submitted to supplement the surveys and assessments contained in the ES. This document outlines a range of detailed measures designed to avoid harm to wildlife habitats and species. The Report would provide a framework for the production of an Ecological Action Plan to be developed as the project was brought forward. Natural England, the Norfolk Wildlife Trust and the Tree & Countryside Officer have raised no objection to the application on the basis of the information provided.

6.8 Overall, it is considered that the proposal would not cause any significant harm to ecological interests and would provide appropriate mitigation measures. The proposals would in this respect comply with relevant planning policies.

Residential amenity 6.9 The route of the proposed underground cable generally avoids built up areas, but does pass relatively close to a number of outlying properties, notably at Horningtoft and Mileham. In these areas the installation of the cable has the

82 potential to impact on local amenities due to noise, vibration, dust and lighting. These potential impacts are considered in some detail in the submitted ES. Noise and dust emissions from the operation of plant and machinery within the cable working corridor, together with noise and vehicles emissions from transport and working compounds have all been assessed. A range of mitigation measures are outlined in the ES, which are intended to form the basis for the development of a detailed Construction Management Plan. Subject to adoption of normal good working practices, it is considered the impacts generally on residential properties will be localised and not significant in magnitude. For a small number of residential properties located close to the cable route, additional measures, such as temporary noise barriers, would be needed to avoid harmful effects. The Environmental Health Officer has raised no objection on amenity grounds subject to approval of a Construction Management Plan.

6.10 Overall, it is considered that the proposal would not cause any significant harm to residential amenity and in this respect would comply with relevant planning policies.

Other matters 6.11 Highway matters. The proposed cable route crosses roads in thirteen locations in Breckland. Most crossings would be over minor country roads, although crossings of B roads are proposed at Mileham and Colkirk. Some temporary road closures are proposed, subject to approval by the Highway Authority, along with footpath closures/diversions. Given the temporary nature of such closures, it is considered that significant disruption would not be caused. It is anticipated that the majority of traffic generation will be focussed on the main construction compound (outside Breckland) and to a lesser extent satellite locations. The Highway Authority has indicated that it would not object to the proposals, subject to conditions being imposed requiring approval of a Traffic Management Plan to control the nature, timing and routing of construction traffic.

6.12 Land restoration. Objections have been raised on behalf of local landowners about detailed changes to the proposals during the cable route design process. Concerns have also been raised about the impact on farming operations. It is considered that the issues raised are largely private matters between the applicant and individual landowners (it is understood that the applicant does not intend to acquire land compulsorily). In terms of agricultural issues, the applicant has indicated that all land will be restored to its original condition as far as possible. Topsoil and subsoil will stored separately and in accordance with Defra guidelines to avoid damage to its structure. Cable burial depths inspection cover locations would be agreed with landowners.

6.13 Health implications. Some concerns have been raised about the health implications of the proposed cables, particularly in respect of electromagnetic fields (EMFs). Based on advice from the Health Protection Agency, the International Commission on Non-Ionizing Radiation Protection (ICNIRP) guidelines on safe exposure levels to EMFs have been adopted in the UK. Based on information provided by the applicant, it is understood that shielded underground cables produce no external electric fields. Magnetic fields directly above the buried cables would range from around 23 to 67 microTeslas depending on the cable configuration. Magnetic fields would

83 reduce significantly further away from the cables. ICNIRP guidelines indicate that public exposure to magnetic fields should not exceed 100 microTeslas.

Conclusion 6.14 PPS22 and the Supplement to PPS1 establish a generally supportive policy framework for renewable energy projects. Key planning objectives include securing the delivery of the Government’s Climate Change Programme and energy policies. Where projects would contribute to key planning objectives, PPS1 indicates that developers should expect expeditious and sympathetic handling of planning applications. Current government targets for renewable energy seek to ensure that at least 15% of the UK electricity supply should come from renewable sources by 2015. The applicant has indicated that the first phase of wind farm development at Dudgeon would provide sufficient energy for around 400,000 households or around 3% of the energy needed to meet the 15% target. The proposed development would accord in general terms of local and national planning policy that encourages the development of renewable energy projects.

6.15 In terms of the specific effects of the proposal, it is considered that the development would generally not have any significantly adverse effects on environmental considerations, including the appearance of rural landscapes, local ecological interests or archaeology. Where adverse effects would be likely to occur they would be minor and temporary. Impacts on residential amenity could be addressed by appropriate mitigation measures, and would in any case be limited due to the cable route’s avoidance of main settlements. On the basis of the information available it is note considered that any significant traffic or health implications would be raised by the proposals.

RECOMMENDATION 7.1 It is recommended that planning permission is granted subject to appropriate planning conditions. Details of recommended planning conditions will follow.

84 Agenda Item 11

BRECKLAND COUNCIL

DEVELOPMENT CONTROL COMMITTEE – 11 TH OCTOBER 2010

REPORT OF DEPUTY CHIEF EXECUTIVE (Author: Nick Moys, Principal Planning Officer (Major Projects))

NECTON: PROPOSED ELECTRICITY SUBSTATION, LAND OFF NECTON ROAD, LITTLE DUNHAM Applicant: Dungeon Offshore Wind Limited Reference: 3PL/2009/1188/O

Summary – This report concerns outline proposals to develop land on the edge of Little Dunham as an electricity substation. Key issues relate to potential effects on local amenity, landscape impact and traffic. It is recommended that permission is granted subject to conditions.

INTRODUCTION 1.1 This report concerns an application for outline planning permission for the construction of a new electricity substation on land off Necton Road, Little Dunham. The substation would connect an offshore wind farm proposed at Dudgeon some 32km offshore of the North Norfolk coast via underground cables to the national electricity transmission network at Little Dunham. The onshore cable route would be around 45km in length, of which 17km would fall within Breckland and the remaining 28km in North Norfolk. Separate planning applications have been submitted to Breckland Council and North Norfolk District Council for the underground onshore cable route.

1.2 The applicant has been awarded rights by The Crown Estate to develop an offshore wind farm in the Greater Wash Strategic Environmental Assessment area. This award is subject to the applicant being successful in gaining the necessary planning and licence consents for the construction and operation of the wind farm. The wind farm proposed at Dudgeon would cover an area of around 35km 2 (approximately 168 wind turbines) and will have a generating capacity of 560MW. Applications for environmental and other consents required for the offshore elements of the wind farm are currently being determined by the Department of Energy and Climate Change (DECC) and the Department for Environment, Food and Rural Affairs (Defra). A further phase of wind farm development at Dudgeon is also being contemplated by the applicant.

1.3 The application is in outline form, with all matters reserved for later approval. Indicative site layout and development details have been provided in support of the application, which include the following elements and parameters. The proposed substation development would include two replacement overhead line towers, various electrical switchyards, filter banks, transformers, control buildings, access roads/hardstandings and, depending on whether an AC or DC connection is chosen, a switchroom and outdoor equipment yard or up to 4 converter buildings and associated cooler banks. Cable gantries would be up to 13m in height and electrical switching and connection apparatus up to 12m in height. For a DC configuration, the proposed converter buildings

85 would measure approximately 70m long by 25m wide by 15m high. The proposed substation would occupy an area of up to 9.3 hectares.

1.4 Both the proposed substation development and the on-shore cable works are proposed in two stages to correspond with anticipated offshore development in the Dudgeon area. Stage 1 would provide onshore infrastructure to support the current proposal for a 560MW wind farm at Dudgeon. Stage 2 would provide additional onshore infrastructure to support further offshore wind development with a generating capacity of up to 1,400MW. This second phase of development has not yet been released by the Crown Estate.

1.5 The proposed substation site comprises an open arable field located on the southern edge of the village of Little Dunham (but within the parish of Necton). The site extends to cover an area of 17 hectares. National Grid overhead power lines pass through the middle of the site. Boundaries of the site are generally defined by hedgerows. The site contains two ponds. The site is located within an area of generally open countryside. A group of 8 dwellings is located just to the north of the application site. The southern edge of the village is located around 200m further to the north. A derelict former coal yard is located to the south-east of the site, together with two further outlying residential properties.

1.6 The application is supported by an Environmental Statement (ES), a Statement of Community Involvement and a series of Technical Notes. The Environmental Statement includes detailed assessments of the proposed development on nature conservation, rural landscapes, archaeology, ground conditions, traffic, noise/vibration, dust and air quality and communities/recreation/tourism.

KEY DECISION 2.1 This is not a key decision.

COUNCIL PRIORITIES 3.1 The following Council priorities are relevant to this report: • A safe and healthy environment • A well planned place to live and work

CONSULTATIONS 4.1 Little Dunham Parish Council has raised objection to the application on a number of grounds. The principal objections relate to the visual impact of the development due to its elevated position, unacceptable noise levels, insufficient justification for the selection of the site, increased traffic and planning blight. It is also considered that there has been inadequate consultation with local residents and representatives.

4.2 Necton Parish Council has objected to the application on grounds of increased traffic.

4.3 Sporle Parish Council has objected to the application on the grounds that the development would have a detrimental effect on the character and appearance of surrounding countryside and cause unacceptable disruption to local residents due to increased noise and traffic.

4.4 Parish Council has objected to the application on the grounds that the development would harm the character and appearance of the area.

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4.5 Rougham Parish Council has objected to the application on the grounds that the development would harm the character and appearance of the area

4.6 The Highway Authority has raised no objection subject to a condition requiring a Construction Traffic Management Plan.

4.7 Norfolk County Council has raised no objection to the proposals, subject to conditions relating to external lighting and wildlife mitigation.

4.8 The Environment Agency has raised no objection to the application subject to conditions relating to contaminated land and pollution control .

4.9 Natural England has raised no objection to the application subject to the proposed wildlife mitigation measures, extensive landscaping and biodiversity enhancements.

4.10 Norfolk Wildlife Trust has raised no objection to the application, subject to appropriate ecological mitigation measures.

4.11 Norfolk Landscape Archaeology has raised no objection subject to a condition requiring a programme of archaeology evaluation.

4.12 The Tree & Countryside Officer has raised no objection to the proposal subject to the conditions relating to wildlife mitigation, reinstatement of hedgerows and geodiversity recording.

4.13 The Council’s Contaminated Land Officer has raised no objections .

4.14 The Council’s Environmental Health Officer has raised no objection to the application subject to conditions relating to noise emissions and construction management.

4.15 A considerable volume of objection to the application has been received. In excess of 200 letters of objection have been received, together with a petition against the proposed development of 1,485 signatories. The objections raised relate principally to the scale of the development, harmful visual impact, increased traffic problems, loss of amenity to local residents and the insufficient justification for the proposal.

POLICY 5.1 Relevant national planning policy can be found in PPS1 ‘Delivering Sustainable Development’, the Supplement to PPS1 ‘Planning & Climate Change’, PPS 7 ‘Sustainable Development in Rural Areas’, PPS 9 ‘Biodiversity & Geological Conservation’, PPG 22 ‘Renewable Energy’ and PPG24 ‘Planning & Noise’.

5.2 Relevant local planning policies include Policy DC15 of the Council’s Core Strategy & Development Control Policies DPD which supports renewable energy proposals subject to criteria relating to landscape impact, residential amenity and conservation of ecological/heritage interests. Other relevant policies include: Policy CP10 (Natural Environment), Policy CP11 (Landscape protection), Policy DC1 (Amenity) and Policy DC12 (Trees & Landscape).

87 ASSESSMENT 6.1 The principal issues raised by the application concern: i) impacts on the character and appearance of the surrounding rural landscape, ii) effects on the residential amenities of nearby residents, iii) traffic safety and iv) the need for the development and the availability of alternative sites. National planning policy on renewable energy projects provides a wider context for the consideration of these issues.

Landscape impact 6.2 Core Strategy Policy CP11 requires rural landscapes to be protected in order to maintain their appearance and ecological/historic value. Rural landscapes must be protected for their own sake and having regard to the Council’s Landscape Character Assessment (LCA).

6.3 The proposed substation site comprises an open arable field, bounded in part by hedgerows, and located in an area of generally open countryside on the southern fringe of the village of Little Dunham. The Council’s LCA identifies the site as falling within the Plateau Farmland landscape character area. Key features of this landscape type include its elevated land forms, extensive views, large scale arable fields defined by hedgerows and interspersed with woodland, strong rural character, and relatively remote and peaceful character. These characteristics are readily apparent in the landscape immediately surrounding the application site.

6.4 Due its scale and nature, the proposed substation development has the potential to result in significant effects on the character and appearance of the surrounding area. Particular attention has therefore been paid to this issue, and the applicant’s ES includes detailed assessment of landscape characteristics and impacts in accordance with established national guidance.

6.5 Despite its elevated position in the landscape, views of the substation site from distance (more 3km away) would be very limited due to screening provided by existing hedgerows, trees, settlements and landscape features. Where views of the proposed substation site are available in the wider landscape they would be limited to distant views of the tops of equipment and buildings on the horizon. It is considered that, in this context, the impact on the landscape would be minor or imperceptible.

6.6 In closer proximity to the substation site the impact of the proposed development would be much greater. The most significant impacts would be experienced from locations on the Necton Road approaching the site, from existing residential properties immediately to the north of the site, from residential properties on the southern edge of the main part of the village and from a public footpath to the south of the village. Whilst the site benefits from some screening from hedges and trees, this screening is not continuous and only partially filters views into the site. Without additional screening, it is considered that the proposed development would result in a significant visual intrusion in this generally open landscape, particularly when viewed from the north.

6.7 In order to address this adverse impact, a number of features have been incorporated into the layout and design of the substation in an effort to reduce its landscape impact. Landscape impact mitigation measures would include the construction of earth banking of up to 5 metres in height between the substation and housing to the north, together with a comprehensive scheme

88 of landscaping. Planting proposed would include blocks of woodland, small copses and the reinforcement of existing hedgerows. Areas of meadow grassland would be created. Approximately 45% of the overall site area (7.7 hectares) would be given over to landscape features. It is also proposed to form three terraces within the substation compound, using existing falls in ground level. The largest buildings proposed would be located on the lowest terrace which would be around 2 metres existing ground levels on the Necton Road boundary. The access road into the site would be configured to limit views on the main substation structures.

6.8 The effectiveness of these proposals has been carefully assessed. Overall, it is considered that the combined effect of the proposed mitigation measures would be to significantly reduce the visual impact of the proposed substation. In the longer term, the proposed landscaping should ensure the successful assimilation of the development into the surrounding landscape. However, in the short term, new landscape features would only partially screen the substation equipment and buildings, and the tallest structures and buildings would be visible above the mound and over existing hedgerows. Notwithstanding the not insignificant presence of existing overhead power lines, the substation development would add visual clutter to the landscape and have an urbanising effect. The earth mound itself would also be a rather conspicuous feature when first constructed. The LCA recommends that the use of bunding and dense screen planting should be avoided as this would create uncharacteristic elements in this type of landscape. In order to avoid such harm, it is considered that the proposed banking must be formed with gentle sweeping slopes in order to assimilate it into the existing landscape. Whilst the location of the site on the edge of a plateau area will make this objective difficult to realise fully, it is considered that the size of the land area available is such that a satisfactory transition from existing to new landscape features could be achieved with sensitive landscape design. The woodland planting proposed would reflect existing characteristic features in the local landscape. Whilst this tree planting would obviously take a number of years to develop, proposed meadow grasslands and ponds would develop much more quickly. It is also proposed to plant fast growing evergreens around the site perimeter as a temporary screen. Advance planting could be required by planning condition.

6.9 To conclude on the issue of landscape impact, it is considered that the construction of the substation would cause short term harm to the rural landscape in and around the immediate vicinity of the site, although this would be increasingly offset over time by proposed landscaping as the planting develops. In the longer term, the proposed mitigation should ensure that the development is successfully integrated into the landscape, albeit with an altered landscape form. This conclusion accords with the views expressed by Natural England, Norfolk County Council and the Tree & Landscape Officer. It is at odds, however, the feedback received locally.

Residential amenity 6.10 The closest residential properties to the proposed substation (an isolated group of 8 dwellings) are located immediately to the north of the application site. The closest dwelling is approximately 170m from the existing overhead power lines and the perimeter of the proposed substation compound. Properties on the southern edge of the village would be around 350m distant. The nearest house to the south of the site would be over 200m from the

89 substation. The proposed transformers would be around 300m from the nearest house.

6.11 It is considered that the main potential impacts of the development on residential amenities relate to noise resulting from construction work and from the operation of the proposed substation equipment itself. Impacts relating to visual amenity, vibration and dust have also been considered.

6.12 For the construction period, given the scale and nature of the project, some impact on local amenities would be inevitable. However, given the separation distances between the substation and the nearest dwellings (+200m) it is not considered that these effects would be significant, provided that proper management measures were implemented (i.e. working hours limits, good working practices, use of appropriate machinery, communication with local residents). It is proposed to construct the raised earth mound at a very early stage in the construction process. Once completed this banking would help considerably to reduce the impact of noise on neighbouring properties. Appropriate phasing of works and management of construction activities could both be secured by appropriate planning conditions. Noise from construction traffic would affect only a few residential properties and is not expected to be significant. Construction periods are expected to extend to 24 months for stage 1 and 18 months for stage 2.

6.13 Detailed consideration has also been given the likely impact of noise from the substation once operational. The applicant’s ES includes a detailed assessment of the effects of noise, and notes that existing background levels are very low, particularly at night. Two types of noise would be generated by the development: a low frequency hum from transformers and noise from cooling equipment (with a more broadband characteristic). The Council’s Environmental Health team has sought specialist advice on assessment of such noise emissions and their control. The Council’s acoustic consultant has given advice on setting noise level limits which would ensure that significant impact on the surrounding area is avoided. Separate conditions have been recommended that would set: i) an overall noise limit for the operation of the substation, and ii) a specific limit for low frequency noise. The overall noise limit would fall below World Health Organisation guidelines to ensure that sleep is not disturbed. There are no UK guidelines for low frequency noise, but the levels recommended are in line with or below those adopted elsewhere in Europe. Conditions are also recommended to require the developer to submit noise mitigation proposals to achieve compliance with the stipulated limits and to provide for future monitoring. Compliance with the stipulated noise limits is likely to require the proposed transformers to be housed in substantial enclosures, together with other attenuation measures. On the basis of the information and advice received, the Environmental Health Officer has raised no objection to the proposal on noise grounds subject to conditions.

6.14 In terms of visual amenity, the principal effect of the development would be to alter the views available from residential properties immediately to the north. The raised earth mound and planting proposed to reduce the landscape impact would also have the effect of obscuring current views across open countryside. However, provided that the high point of the banking is set well back from the site boundary (as shown on the indicative site layout) it is not considered that the effect would be visually overbearing. There is of course no right in law to a view across land in the ownership of others.

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6.15 To conclude on the issue of residential amenity, it is considered that principal effects of the development on surrounding residential properties will result from noise. Provided that adequate safeguards are put in place to control noise emissions during and post construction, it is considered that no significant harm to the living conditions of local residents would result.

Highway safety 6.16 Access to the substation site from the principal road network would via the A47 trunk road and the Necton/Dunham Road (C117). A new entrance into the site is proposed onto the Necton Road. The C117 is a reasonably well used local route providing access from the A47 to a number of villages to the north.

6.17 Whilst the development would generate very little traffic once operational, significant traffic movements would be experienced over the course of the construction period. For the stage 1 construction period (24 months), it is estimated that some 34,000 traffic movements would be generated, of which 25% would be deliveries by HGVs and 75% staff movements by car and light van. Traffic levels would vary, with average daily flows of 71 trips and a peak of 113 trips. Overall traffic flows on the C117 would increase by an average of 9%, with a peak increase of 14%. In terms of HGV movements, there would be overall increase in 30% with a peak increase of 63%. For the stage 2 construction period (18 months), it is estimated that some 14,000 traffic movements would be generated, of which 35% would be deliveries by HGVs and 65% staff movements by car and light van. Average daily flows would be 39 trips, with a peak of 68 trips.

6.18 Careful consideration has been given to the likely impact of the development on traffic conditions and safety on the local road network. Detailed discussions have taken place between applicants, NCC Highways and the Highways Agency. In order to accommodate traffic generated during the construction period, a number of mitigation measures are proposed. These would include minor highway improvements (formalisation of passing places, hedge trimming) and the implementation of a Traffic Management Plan. Traffic management measures would include directing all traffic to approach/exit to the south (thus avoiding Little Dunham), staggered HGV deliveries timed to avoid peak times where possible, escorting of abnormal loads, appropriate signage and road cleaning. At the request of the Highway Authority, additional information has been submitted by the applicant in relation to abnormal loads. This provides details of anticipated vehicle tracking, and demonstrates that such loads could be transported along the C117 within the confines of the existing highway. The type of abnormal load vehicle proposed would be high enough to oversail roadside verges. The location of the site access has also been revised following discussion with the County Council in order to ensure that appropriate visibility splays can be achieved.

6.19 To conclude on this issue, subject to the mitigation measures proposed, it is considered that the construction of the substation would not result in significant traffic congestion/delays or highway dangers, although there would be some temporary local disruption to traffic due to the increased movements generally and the transporting of abnormal loads. Neither the Highway Authority nor the Highways Agency has raised objection to the application.

91 Need for the development 6.20 The applicant has indicated that the purpose of the scheme is to deliver power from the proposed Dudgeon offshore wind farm to an appropriate point on the national electricity transmission network. Development of offshore wind energy is in line with national policy which seeks to increase the proportion of the country’s energy requirements that are met from renewable sources. The Supplement to PPS1 states that renewable energy projects should not be required to demonstrate either an overall need for renewable energy or the energy justification for development in a particular location. On this basis, it is not considered that in principle the need for the proposed substation development requires any further justification.

6.21 The need for a development of the scale proposed has been questioned by some given that the second phase of wind farm development at Dudgeon has not yet under active detailed consideration. Whilst this point is acknowledged, given the national commitment to increasing the supply of renewable energy, it is not unreasonable to assume that further offshore projects will be developed in near future. The Crown Estate has confirmed that further offshore wind capacity may be released in the future. Licences would be released through a competitive tendering process. In this context it does not seem unreasonable for the applicant to plan for this eventuality, particularly taken into account the lead times and costs of infrastructure of this sort. If further offshore capacity is not released, the second phase of cable/substation construction would not take place.

Alternative sites 6.22 In terms of the need for the development to be located at Little Dunham, whilst planning policy does not specifically require a need to be demonstrated, under the Environmental Assessment Impact Regulations, where alternative approaches to the development have been considered, applicants are required provide an outline of the main alternatives studied and indicate the main reasons for the choice of site, taking into account environmental effects. This approach is regarded as good practice and as a means of ensuring that the environmental merits of practicable alternatives are properly considered. Although it is an established principle of planning practice that the existence of alternatives sites on which a proposed development might be yet more acceptable cannot justify refusal of permission, consideration of other sites can be a material consideration, particularly where some adverse environmental effects are inevitable and where the need for the development is a factor.

6.23 The submitted ES considers in some detail a range of alternatives sites for the proposed substation. Discussions between the applicant and National Grid/EDF Energy determined that the proposed wind farm required a connection to the existing 400kV electricity lines between Norwich and Kings Lynn. It is understood that the existing 132kV electricity infrastructure to the north does not have sufficient capacity to accommodate the proposed development. A connection to the Grid via the Wash was discounted due to due to cost and environmental considerations. The Crown Estate has confirmed that possible the future development of a new electricity network using the east coast seabed is unlikely to be in service in time to be of benefit to the Dudgeon scheme.

6.24 Accordingly the submitted ES considers a search area extending some 30km from the south of Norwich to the north of along the route of the

92 National Grid 400kV lines. Initially, some 112 potential sites were considered. Following a sieving process, a large number of sites were discounted based on assessment criteria relating to engineering/technical feasibility, proximity to built up areas, accessibility from the highway network, proximity to environmental/heritage designations and cable route considerations. This process resulted in the identification of 5 shortlisted sites which were considered in greater detail. The shortlisted sites were located at Norwich Main substation, Thickthorn, Barford, Necton and Little Dunham. Assessment of these sites led the applicant to select the application site at Little Dunham as the most practicable and viable site with the fewest environmental problems. The reasons given for rejecting the other shortlisted sites related to difficulties in land acquisition, cable route constraints, access difficulties and potential drainage issues.

6.25 The applicant’s conclusions have been challenged locally on a number of grounds. Objectors reject the conclusions reached on individual site assessments and, more fundamentally, the overall site location criteria adopted. It is argued that it ought to possible for the applicant to find a site with less environmental impact and located further away from residential properties. It is suggested that the site selection process has been skewed to favour the application site and that the reasons for rejecting other potential sites have not been properly justified.

6.26 However, taking into account the information provided, it is considered that overall process of site selection has been approached in a reasonable and sufficiently rigorous manner by the applicant. Whilst there is inevitably scope for differences of views on the merits of particular potential sites, given the range of considerations taken into account, the applicant’s assessments appear to be based on sound judgements and on expert advice received. The technical information provided by the applicant has not been subject to independent expert analysis, but much of it has been corroborated by reference to technical standards and/or corroboration from relevant governing bodies. Given the overall conclusion reached that the long term environmental effects of the substation development would be not significantly harmful, it is not considered necessary to undertake a more exhaustive assessment of the alternative sites.

Other matters 6.27 Ecology. The application site is currently in arable cultivation and has only limited ecological value. However, two ponds are located on the site boundary, both of which are used by great crested newts. In order to mitigate the impact of the development, both existing ponds would be retained and a network of new ponds and associated habitat would be created. On the basis of these proposals and other landscaping, it is considered that the development would result in an overall benefit for wildlife, particularly newts. Natural England has raised no objection to the proposed substation.

6.28 Health implications. Some concerns have been raised about the health implications of the proposed cables, particularly in respect of electromagnetic fields (EMFs). Based on advice from the Health Protection Agency, the International Commission on Non-Ionizing Radiation Protection (ICNIRP) guidelines on safe exposure levels to EMFs have been adopted in the UK. ICNIRP guidelines indicate that public exposure to magnetic fields should not exceed 100 microTeslas. It is understood that whilst substation equipment can generate magnetic fields, levels drop rapidly with distance and are not

93 generally above background levels at the perimeter of compounds. The applicant has indicated that the proposed substation would likely to produce fields of less than 1 microTesla at the boundary. The largest fields close to a substation are generally associated with underground or overhead cables. It is understood that magnetic fields directly above the buried cables entering the substation would range from around 23 to 67 microTeslas depending on the cable configuration. Magnetic fields would reduce significantly further away from the cables.

6.29 Planning Policy. PPS22 and the Supplement to PPS1 establish a generally supportive policy framework for renewable energy projects. PPS22 states that the wider environmental and economic benefits of renewable energy projects should be given significant weight in the determination of planning applications. In this respect in should be noted that current government targets for renewable energy seek to ensure that at least 15% of the UK electricity supply should come from renewable sources by 2015. The applicant has indicated that the first phase of wind farm development at Dudgeon would provide sufficient energy for around 400,000 households or 3% of the energy needed to meet the 15% target. The applicant has also indicated that the capital cost of the first stage of the Dudgeon development as a whole will be approximately £1.3 billion. A proportion of this would be expected to be spent in the region. Employment for around 50 people would be generated directly by the project.

Conclusion 6.30 It is considered that this planning application presents particular challenges for the Council due to the scale of the proposals, the complexity of the issues raised, the high level of local opposition to the scheme, and the general lack of consensus on key issues between expressed local opinion and statutory consultees.

6.31 As noted above, national planning policy provides a generally favourable background to the consideration of renewable energy projects. Key planning objectives include securing the delivery of the Government’s Climate Change Programme and energy policies. Where projects would contribute to key objectives, PPS1 indicates that developers should expect expeditious and sympathetic handling of planning applications. However, this favourable treatment is subject to proper consideration of environmental effects.

6.32 Whilst the high level of local objection to the proposal does not provide a valid ground for rejection of a scheme in itself, the local concerns raised provide an alternative perspective on the principal issues outlined above, and warrant very careful scrutiny.

6.33 A key question which arises from consideration of the principal issues identified above is: would the proposed development adequately safeguard the appearance of the area, the residential amenities of local residents, and highway safety? From a technical perspective, it is considered that this question can be answered in the affirmative, with some qualifications. That is not to say that it is considered that the development would cause no harm (it is acknowledged some local disruption and harm would occur in the short term); but rather that, against a background of policy that favours renewable energy projects, the disbenefits of the proposal are not sufficient to justify refusal of permission. With appropriate landscaping and screening, the development could be assimilated into the landscape, albeit following some

94 disruption in the short term. Significant harm to the amenities of local residents could be avoided by the imposition of appropriate noise controls and management. Highway safety would not be materially compromised provided that traffic was properly managed and any inconvenience to other road users would be temporary. It is also considered that the proposals arise out of a thorough and reasonable site selection process.

RECOMMENDATION 7.1 It is recommended that outline planning permission is granted for the proposed substation subject to appropriate planning conditions. Details of recommended planning conditions will follow.

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