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Your Ref: EN010025 Our Ref: Date: Enquiries to: Michael Wilks Tel: 01473 264064 Email: [email protected] Ms Katherine Chapman Case Manager Planning Inspectorate Temple Quay House 2 The Square Bristol BS1 6PN Dear Ms Chapman Suffolk County Council Section 56 Response This response has been agreed by the Director of Economy, Skills and Environment. Please find attached the Council’s full response to the Section 56 consultation. A much briefer version has been provided through the onsite registration form. The Council’s Section 56 response was approved by the Cabinet on 26th February 2013 (without amendment). Appended to this letter is the Cabinet endorsed response, which takes the form of a Cabinet Report and accompanying Appendix. This fuller response is provided to PINS at this point to aid the Examining Authority, upon its appointment, in its “Initial assessment of issues” under Rule 5 of The Infrastructure Planning (Examination Procedure) Rules 2010. The Cabinet Report was finalised sometime before the conclusion of the current consultation, consequently, as the Report notes at paragraph 42, the Council has continued to work with the applicant on the issues identified as outstanding at the time of the report. An update is therefore provided below on the principal matters. As mentioned, the Cabinet Report is accompanied by an Appendix. The Cabinet Report itself describes the development being proposed and the relevant policy context for the benefit of Suffolk County Councillors and members of the public. The Report then highlights key areas of concern for the Council and an assessment of the application documents. Paragraphs 71 to 136 represent a summary of the more detailed analysis of the socio-economic, archaeological, transport and environmental issues that can be found in the Appendix. Update on principal matters for Suffolk County Council; 1. Sterling Suffolk Greenhouse Proposal (Cabinet Report, paragraphs 63- 70) The Council understands that EA ONE and Sterling Suffolk continue to engage constructively to resolve this potential land use conflict. We are aware that consideration is being given to formalising a mutually satisfactory resolution through the finalisation of land agreements. The Council welcomes the progress being made and supports such an arrangement on the understanding that EA ONE would then be unable to implement a consent which would undermine the Sterling Suffolk proposal. 2. Socio-economic and skills (Cabinet Report, paragraphs 75 – 87; Appendix, paragraphs 1-16) Endeavour House, 8 Russell Road, Ipswich, Suffolk IP1 2BX www.suffolk.gov.uk The Council has met with the applicant to discuss the evaluation of the socio-economic impacts as set out in Chapter 28 of the Environmental Statement. In particular discussions have focussed on the level of detail that is required on the mechanisms proposed to; • secure local economic benefits, • deal with any possible labour market issues • address any supply chain issues • mitigate any potentially negative impacts, for example pressures on tourist accommodation • overcome any local infrastructure issues, for example associated with the choice of port. The Council recognises that EA ONE is part of a much more significant development, and that the above issues relate to the East Anglia Zone as a whole and thus the measures put in place should be designed to address the long term impacts associated with the development of the Zone, not just those linked with East Anglia ONE. Consequently the Council does not expect the mitigation strategies relating to the supply chain or skills shortages to be finalised at this point in time. However, so that the Council (and PINS) are able to have greater confidence in the realisation of purported economic benefits and take comfort that the need for any mitigation will be addressed, we consider that the applicant needs to set out its intentions on tackling the above issues. The Council has now been made aware of some of the initiatives that EAOW has been undertaking more widely and supports this constructive approach. For the purposes of the EA ONE examination, the Council would consider it useful if the applicant could set out with which parties it is engaging on which matter(s) and what issues it is seeking to address. Alongside this, it should set out in broad terms its intentions on how it will develop this initial work into an overarching strategy, which should be developed alongside key partners such as this Council. In the view of the Council, a document setting out the intentions of EAOW in respect of these matters should be placed in front of the Inquiry. The Council understands that EA ONE is undertaking further work concerning the impacts of the development on tourism/tourist accomodation and will consider that in due course. With respect to cumulative issues with Sizewell C, given the emerging clarity on the respective timetables of the two projects, we are satisfied that cumulative impacts can be satisfactorily addressed through either that application, or future applications by East Anglia Offshore Wind. However, we consider that the applicant should, in setting out its broad intentions, specifically refer to how it will address emerging cumulative impacts as and when that information becomes available. We are also providing EAOW with information on other projects where the cumulative impact may need to be considered. 3. Archaeology (Cabinet Report, paragraphs 88 – 92; Appendix, paragraphs 17-27) There are two substantive issues; firstly that the trenched evaluation of the converter station site is completed before consent is granted and secondly systematic field evaluation of the cable corridor is undertaken pre-construction. In the case of the former, the applicant now appears confident that those works will shortly commence and thus the evaluation will be complete during the examination period. Discussions continue on the cable corridor. The Council maintains its position that the proposals set out in the draft Written Statement of Investigation are inadequate. Consequently the applicant is currently reviewing the implications of the Council’s requirements for the development programme and the extent to which our expectations differ from their own proposals in practical terms (i.e. whether a systematic versus targeted approach to trenching would have significantly different resource implications). 4. Transport and Traffic (Cabinet Report, paragraphs 93 – 105; Appendix 28-51). The Council maintains a large number of concerns, though the applicant has committed to undertake additional work to address these. It is understood that this additional work, alongside a draft Traffic Management Plan, Access Management Scheme and Travel Plan will be presented to the Council on the 22nd March. The Council will review its position at this time. The Council continues to consider it important that other parties, for example Parish Councils, are able to review and comment on these documents. 5. Noise, Vibration & Air Quality (Cabinet Report, paragraphs 106-110; Appendix paragraphs 52 – 67) No substantive progress has been made in this area. It is understood that following the conclusion of the additional transport work referred to above, the applicant will then undertake to address the issues the Council has raised. 6. Public Rights of Way (Cabinet Report, paragraphs 111 – 115; Appendix 68 -75) The Council has not had any further discussions on this topic. In addition to the comments previously made, the Council also considers that the applicant should seek to work with landowners in the areas where rights of way diversions are not proposed to establish whether an alternative permissive right of way could be established for the duration of the construction works. 7. Environment (Cabinet Report, paragraphs 116 – 136; Appendix 76 – 110) There has been further detailed discussion on environmental impacts, and in particular mitigation. The applicant has now put forward a draft Section 106 agreement to mitigate the residual visual impacts of the converter station. It is intended to provide for offsite planting. Further work is being undertaken to establish the sum that would be needed to deliver adequate mitigation. The applicant has also indicated a willingness to employ further ‘trenchless techniques’ in the cable corridor to minimise impacts on hedgerow and tree loss. The Council has asked for further information concerning the identification of important hedgerows, so that it can take an informed view of where trenchless techniques should be used. The Council maintains that there will be significant residual impacts in the cable corridor which need to be addressed through the use of trenchless techniques and, where they are not employed, through offsetting. The Council has provided the applicant with its initial views on the content of an Outline Landscape Strategy. The Council understands informally from the applicant that bed levels at the converter station cannot be lowered due to concerns over flooding/water ingress. Evidence of this is awaited and will be considered by the Council in due course. The Council considers that any reptile translocation sites should be ready before construction commences. Similarly, the Council would wish to restrict working practices in the vicinity of the converter station until additional surveying of bats has been completed. The applicant is considering whether these issues can be addressed through the Ecological Management Plan or whether additional provisions need to be included

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