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Applicant's Comments on Written Representations and Additional Submissions Norfolk Boreas Offshore Wind Farm Applicant's comments on Written Representations and Additional Submissions Applicant: Norfolk Boreas Limited Document Reference: ExA.WRR.D3.V1 Deadline 3 Date: December 2019 Revision: Version 1 Author: Royal HaskoningDHV Photo: Ormonde Offshore Wind Farm Date Issue No. Remarks / Reason for Issue Author Checked Approved 16/12/2019 01D First draft for internal review VF/WBD/RHDHV JL/VR/JT JL 18/12/2019 02D Second draft for internal review VF/WBD/RHDHV JL/VR/JT JL 19/12/2019 01F Final for Submission at Deadline 3 BT JL JL Applicant’s comment on Written Norfolk Boreas Offshore Wind Farm ExA.WRR.D3.V1 Representations and Additional Submissions December 2019 Page i Table of Contents 1 Comments on Written Representations ................................................................... 5 1.1 NATS Safeguarding Office REP2-082 ......................................................................... 5 1.2 Maritime and Coastguard Agency (MCA) REP2-092 .................................................. 5 1.3 National Federation of Fisherman’s Organisations REP2-076 .................................... 7 1.4 N2RS (No to Relay Stations) REP2-106 .....................................................................14 1.5 Historic England REP2-072 .......................................................................................16 1.6 Cadent Gas Limited REP2-103 ..................................................................................23 1.7 Diana Lockwood REP2-101 ......................................................................................24 1.8 Corpusty and Saxthorpe Parish Council REP2-068 ....................................................26 1.9 The Wildlife Trusts REP2-098 ...................................................................................28 1.10 National Grid Electricity Transmission & National Grid Gas REP2-077 ...................... 31 1.11 RSPB REP2-096 ........................................................................................................32 1.12 Whale and Dolphin Conservation REP2-112 .............................................................41 1.13 Anglian Water Services Ltd REP2-099 ......................................................................61 1.14 Ministry of Defence ................................................................................................. 63 1.15 Network Rail Infrastructure Limited REP2-109 .........................................................64 1.16 Patricia Lockwood REP2-110 ...................................................................................65 1.17 Colin King REP2-100 ................................................................................................65 1.18 Great Yarmouth Borough Council REP2-071 ............................................................65 2 Comments on Additional Submissions .....................................................................67 2.1 Natural England REP2-081 .......................................................................................67 2.2 The Coal Authority REP2-097 ...................................................................................71 2.3 Jan Burley REP2-104 ................................................................................................71 2.4 Jenny Smedley REP2-105 .........................................................................................71 2.5 George Freeman MP REP2-102 ................................................................................72 2.6 Necton Substation Action Group REP2-107 ..............................................................74 3 References ..............................................................................................................76 4 Appendix 1 – Figures 1-3 .........................................................................................77 5 Appendix 2 – Ornithological Assessment ................................................................. 78 Applicant’s comment on Written Norfolk Boreas Offshore Wind Farm ExA.WRR.D3.V1 Representations and Additional Submissions December 2019 Page ii Glossary of Acronyms AEoI Adverse Effect on Integrity CoCP Code of Construction Practice DCO Development Consent Order dDCO Draft Development Consent Order dDML Draft Deemed Marine License Defra Department for Environment, Food and Rural Affairs DML Deemed Marine Licenses EPP Evidence Plan Process EPS European Protected Species ES Environmental Statement ETG Expert Topic Group FCS Favourable Conservation Status FLOWW Fishing Liaison with Offshore Wind and Wet Renewables Group FLCP Fisheries Liaison and Co-existence Plan HBMCE Historic Buildings and Monuments Commission for England HDD Horizontal Directional Drilling HE Historic England HER Historic Environment Record HES Historic Environment Services HHW Haisborough, Hammond and Winterton IPMP In Principle Monitoring Plan JNCC Joint Nature Conservation Committee km Kilometre Kv Kilovolt M Metre MCA Maritime and Coastguard Agency MGN Marine Guidance Note MMMP Marine Mammal Mitigation Protocol MMO Marine Management Organisation MOD Ministry of Defence MoU Memorandum of Understanding MSI Maritime Safety Information NATS National Air Traffic Services NERL NATS En Route plc. NRA Navigation Risk Assessment NRHE National Record of the Historic Environment O&M Operations and Maintenance OASIS Online Access to the Index of Archaeological Investigations OCoCP Outline Code of Construction Practice OLEMS Outline Landscape and Ecological Monitoring Strategy (The Crown Estate’s) Offshore Renewables Protocol for Archaeological ORPAD Discoveries OWF Offshore Wind Farm OWSI Outline Written Scheme of Investigation PTS Permanent Threshold Shift / Permanent Auditory Injury Applicant’s comment on Written Norfolk Boreas Offshore Wind Farm ExA.WRR.D3.V1 Representations and Additional Submissions December 2019 Page iii SAC Special Area of Conservation SCI Site of Community Importance SIP Site Integrity Plan SMS Strip, Map and Sample SNCB Statutory National Conservation Bodies SoCG Statement of Common Ground SPE Set-Piece Excavation TWT The Wildlife Trust UK United Kingdom UXO Unexploded Ordnance WDC Whale and Dolphin Conservation WSI Written Scheme of Investigation Applicant’s comment on Written Norfolk Boreas Offshore Wind Farm ExA.WRR.D3.V1 Representations and Additional Submissions December 2019 Page iv 1 Comments on Written Representations 1. This document contains the Applicant's response to all Written Representations submitted by Interested Parties at Deadline 1 of the Norfolk Vanguard Examination. 1.1 NATS Safeguarding Office REP2-082 Summary of Written Representation Applicant’s Response NATS has confirmed that an agreement has The Applicant agrees with the imposition of the detailed been entered into between NATS (En Route) requirements contained within the NERL representation. plc (NERL) and the Applicant for the agreement of suitable planning requirements and the implementation of an identified and defined mitigation solution in relation to the development that will be implemented under agreement. NERL is prepared to withdraw its objection subject to the imposition of agreed requirements set out in the representation. 1.2 Maritime and Coastguard Agency (MCA) REP2-092 Summary of Written Representation Applicant’s Response The MCA’s remit for offshore renewable It is noted that the MCA accepts that the guidance within energy development is to ensure that safety MGN 543 has been followed by the Applicant. The two of navigation is preserved, and search and items referenced are addressed below. rescue capability is maintained, whilst progress is made towards government targets for renewable energy. The MCA has assessed the process by which the Applicant has undertaken the Navigation Risk Assessment (NRA) and Shipping and Navigation Chapter of the Environmental Statement, in accordance with MCA guidance contained in Marine Guidance Note MGN 543, and is content that the requirements have been followed with the following two items noted. The MCA expects the hydrographic survey The Applicant is currently reviewing its hydrographic requirements to be undertaken in accordance survey data coverage with reference to MGN 543. The with Marine Guidance Note 543 and its Applicant is confident that an agreement can be reached hydrographic survey guidelines, and the with the MCA once the data availability has been Applicant is currently considering how it is reviewed. going to achieve these requirements. The MCA has also agreed a standard set of The standard navigation safety conditions were navigation safety conditions with the Marine promulgated after the Development Consent Order (DCO)/ Management Organisation and Trinity House, Deemed Marine Licence (DML) for Norfolk Vanguard was which we expect to be applied to all finalised. Given that it is likely that Norfolk Boreas and renewable projects to ensure the safety of Norfolk Vanguard will both be controlled and monitored navigation. These include specific timeframes from the same marine coordination centre, it is important Applicant’s comment on Written Norfolk Boreas Offshore Wind Farm ExA.WRR.D3.V1 Representations and Additional Submissions December 2019 Page 5 Summary of Written Representation Applicant’s Response for issuing local notices to mariners, that both DCO/DMLs are aligned to prevent confusion timescales for notifying the UK Hydrographic which could result in errors in notifications etc. being Office for dissemination of MSI (Maritime
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