Your Ref: EN010025 Our Ref: Date: Enquiries to: Michael Wilks Tel: 01473 264064 Email: michael.wilks@suffolk.gov.uk

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 in the DCO. 8. Other matters The Council awaits clarification on the nature of jointing bays (Appendix, paragraphs 111 – 115). The Council also awaits clarification of the alternate HDD options at landfall and their respective environmental impacts (Appendix, paragraph 118).

Yours sincerely

Michael Wilks Spatial Planning Project Manager Economy, Skills & Environment

Agenda Item 8

Committee: Cabinet Meeting Date: 26 February 2013 Lead Councillor/s: Councillor Guy McGregor, Cabinet Member for Roads and Transport Local Councillor/s: Councillors Andrew Reid, Patricia O’Brien, Peter Bellfield and John Field Director: Lucy Robinson, Director for Economy, Skills and Environment Assistant Director Bryn Griffiths, Assistant Director Environment or Head of Service: Author: Michael Wilks, Spatial Planning Projects Manager, Telephone: 01473 264064 John Pitchford, Spatial Planning and Partnership Manager, Telephone: 01473 264804

East Anglia ONE offshore windfarm – Comments of Suffolk County Council on Section 56 Consultation

What is the Cabinet being asked to decide? 1. That East Anglia ONE Ltd is informed that the Council considers the principles identified in paragraph 57, relating to maximising local economic opportunities, securing adequate mitigation for the environment and minimising negative impacts on local communities, should inform their final proposals for East Anglia ONE. 2. That the Council makes the following comments to East Anglia ONE Ltd in response to its Section 56 consultation on the East Anglia ONE offshore windfarm: a) The Council expects East Anglia ONE Ltd to continue to engage with the promoters of the Sterling Suffolk Greenhouse development and commit formally to binding proposals which satisfactorily respond to the requirements of both projects; b) The Council recognises and welcomes the potentially significant socio- economic benefits that East Anglia ONE, and future phases of the East Anglia Zone may bring, but believes that East Anglia Offshore Wind Ltd, in advance of the examination of East Anglia ONE, should set out the mechanisms it intends to use to realise these benefits and to mitigate any cumulative adverse impacts. Furthermore, East Anglia Offshore Wind Ltd urgently needs to work with the local authorities to ensure that its ability to invest in the sub-region is not undermined by infrastructural constraints which could be remedied in advance; c) The Council expects East Anglia ONE Ltd to conclude the archaeological field evaluation for the converter station prior to development consent and to provide more substantive mitigation

81 proposals for the cable corridor in order to adequately safeguard the historic environment; d) The Council has pressing concerns over the adequacy of the transport assessment and in particular the estimation of HGV numbers. The Council should be provided with draft versions of the Access Management Scheme, Traffic Management Plan and Travel Plan as a matter of urgency. The Council cannot confirm that adequate mitigation for the transport impacts of this scheme has been provided for at this time and considers that planning obligations may be required for this purpose; e) The Council expects the deficiencies identified herein relating to the assessment of noise, vibration and air quality impacts, in particular relating to the consistency of assumptions across these areas, are addressed by the applicant as soon as possible; f) The County Council should be identified as the relevant authority to agree matters related to the public rights of way network including, but not limited to, diversionary routes, advertisement of temporary closures and provisions for surveying and restoration; and g) The Council considers that the residual impacts of the development on visual amenity, landscape character and biodiversity warrant a comprehensive Section 106 agreement to make the development acceptable in planning terms. Furthermore, the Council requires more detail on the proposed ecological mitigation to confirm its robustness, further consideration of bed levels at the converter station and assurances that the landscape restoration will commence as soon as possible. 3. To authorise the Director for Economy, Skills and Environment, after consultation with the Cabinet Member for Roads and Transport, to make amendments to this submission in the event of further information becoming available before the closing date of this consultation and furthermore that officers engage on an ongoing basis with the applicant to resolve the outstanding issues identified herein.

Reason for recommendation 4. The reasons for the recommendations are set out in full in the main report below, but broadly, this is to protect the natural and historic environment and the amenity of communities of east and mid Suffolk and to maximise the opportunities arising from the development. What are the key issues to consider? 5. The key issues to consider at this time are how the opportunities afforded by the proposals may be best achieved and whether the mitigation proposed to deal with any adverse impacts is sufficient to overcome any unacceptable harm to the communities and environment.

82 What are the resource and risk implications? 6. Growth in the offshore engineering and renewable sectors represent a significant opportunity for the county to secure local economic benefits. Inward investment might be delayed or reduced should the Council set out unreasonable expectations of developers. 7. However, it is considered that the recommendations herein strike an appropriate balance between safeguarding the environmental qualities of the county, which are an economic asset in themselves, without putting an unacceptable burden on the applicant. Indeed, the recommendations seek to improve the application so that benefits are maximised and impacts minimised. Council officers have been guided by Government policy in formulating this response. 8. The principal resource implication of this proposal is the demand upon the time of existing staff required to continue to pursue the issues set out in this report. However, the Council has an expectation that the developer will reimburse the costs reasonably incurred during this pre-examination stage. What are the timescales associated with this decision? 9. This consultation, the final one to be undertaken by the applicant, will conclude on 6 March 2013. The Planning Inspectorate is then anticipated to begin the public examination of the project in late April or early May 2013, meaning a final decision by the Secretary of State is expected no more than 12 months later. It is anticipated that onshore construction would begin in 2016, with the offshore works the following year. The first export of electricity is anticipated in 2018.

Alternative options 10. The Cabinet could take the view that, despite the Council’s in principle support for offshore renewable energy, the specific proposals put forward for East Anglia ONE should not be supported. It is however, the view of officers that East Anglia ONE can be a successful development for Suffolk, providing a positive economic legacy, while safeguarding the environment, if the recommendations of this report are adequately addressed by the applicant. Who will be affected by this decision? 11. Residents along the cable route and in the vicinity of the converter station will be directly affected by the development in the construction phase, and in the case of the converter station, the operational phase as well. Landowners, such as farmers would endure temporary disruption to their operations, though will be eligible for compensation. Some residents further afield will be affected by increased traffic movements associated with construction traffic for a period of time. Local businesses could be positively affected by an increased demand for their services.

83 Main body of report

Background 12. East Anglia Offshore Wind Ltd, a joint venture between Scottish Power Renewables and Vattenfall, was awarded the rights to develop up to 7,200MW of wind capacity off the coast of East Anglia as part of The Crown Estate's Round Three offshore wind programme. Upon full build out, the windfarm will be one of the biggest in the world, providing sufficient electricity to power up to five million homes. 13. The scale of this zone (approximately 6,000km2) is such that East Anglia Offshore Wind Ltd has split its development in to six phases, of which East Anglia ONE, the subject of this Cabinet report, is the first. East Anglia ONE is being developed by East Anglia ONE Ltd, a subsidiary of East Anglia Offshore Wind Ltd. 14. In terms of future proposals; East Anglia THREE and East Anglia FOUR, which will be the next phases brought forward, are at initial stages of development and, like East Anglia ONE, connect to the National Grid at Bramford. East Anglia TWO is proposed to connect to Lowestoft and East Anglia FIVE and SIX to Norwich, though this is currently under review. The Council has been working to avoid a Lowestoft connection due to the potential onshore cabling implications. 15. As the Cabinet will be aware, National Grid is currently developing proposals to reinforce the electricity transmission network between Bramford and Twinstead (in north Essex), predominantly through the use of pylons. National Grid say that that project is needed to accommodate new electricity generation in the region, principally new nuclear at Sizewell and windfarms off the coast of Suffolk and Norfolk, and that it is too expensive to wholly underground that route, which is, by contrast, the current proposal for East Anglia ONE, THREE and FOUR. 16. As mentioned, the East Anglia Zone comprises multiple phases of development. It is understood that the early phases of this development could be accommodated before the Bramford to Twinstead reinforcement is needed, though latter stages could likely not. The Cabinet has previously resolved that a more strategic, long-term perspective on national transmission requirements which pays full regard to the environmental implications of alternative approaches should be taken, and that should the Bramford to Twinstead reinforcement be required, it should be entirely underground. East Anglia ONE 17. The applicant has estimated that East Anglia ONE could create up to 2,700 construction jobs across the UK, with up to 1,600 based in this region. It reports that it has already handed out £7m of contracts to local companies for preparation work, such as sea bed surveys, and calculates that the project will add over £100m to the regional economy annually during the construction period (complete build out of the windfarm is expected to take three years). During East Anglia ONE’s operational phase (of approximately 25 years) the project will employ around 170 engineers and technicians, adding around £10m annually to the local economy. More workers would be needed for subsequent phases.

84 18. The East Anglia ONE application seeks development consent for up to 325 wind turbines and associated infrastructure with an installed capacity of 1,200MW. The windfarm would be located approximately 43.4km from the Suffolk coast at its nearest point (45.4km from Lowestoft) and cover an area of around 300km2. 19. The associated infrastructure comprises: a) offshore export cables (approximately 73km) to the landfall at Bawdsey; b) onshore export cables (approximately 37km) from the landfall point at Bawdsey to a new converter station at Bramford; c) additional cable ducts (approximately 37km) for two future phases of development (East Anglia THREE and East Anglia FOUR) between Bawdsey and Bramford to be installed alongside the onshore export cables for East Anglia ONE; and d) an onshore converter substation at Bramford (the building is not to exceed 130m by 85m and 25m in height) and connection to the National Grid. 20. Due to the distance of the windfarm from the coast (it would not be visible from the mainland), the principal physical impacts, as they affect Suffolk, relate to the onshore cabling proposals (including the landfall point) and the converter station and this report therefore focuses on these issues. The offshore impacts are discussed in brief at paragraphs 31 – 36 below. 21. The onshore cabling works for East Anglia ONE consists of four High Voltage Direct Current (HVDC) cables. As mentioned, the application provides for ducting to house cabling for two future phases of development, so in addition to these four HVDC cables, ducts for a further eight HVDC cables are proposed to be installed. The installation of cabling in these ducts will be the subject of separate subsequent applications 22. These cables and ducts follow a route north from the landfall point at Bawdsey before crossing under the River Deben and emerging on the west bank near to Falkenham. From here the corridor travels north, keeping to the east of Newbourne and west of Waldringfield before heading under Martlesham Creek. The cables then bear west under the A12, passing between the settlements of Little and Great Bealings and then continue westwards through the parishes of Playford, Culpho, Tuddenham, Witnesham, Westerfield, Akenham and Claydon. After passing under the A14, River Gipping and the Ipswich-Cambridge/Ely Line, the cables divert south through the parish of Little Blakenham to terminate on agricultural land adjacent to the existing National Grid substation, which is approximately 2km west of Bramford village. A third of the cable route passes through the Suffolk Coasts and Heaths Area of Outstanding National Beauty (AONB) and a further 20% through Special Landscape Areas (as identified in the District Councils’ Local Plans). Please see Map 1 appended to this report. 23. The cables and ducts would be installed via open trenching, except where environmental and physical constraints dictate that Horizontal Directional Drilling (HDD), i.e. tunnelling, techniques should be used. The working width will be 55m, of which 35m will require a permanent easement. Land either side will be used temporarily for soil storage. East Anglia ONE Ltd is

85 however seeking to secure consent for a 75m wide corridor, which would allow some flexibility for the location of the 55m working width within that 75m, enabling them to respond to very localised constraints such as ground conditions. A temporary haul road will be installed down the middle of the cable corridor. A schematic indicating the proposed working arrangements appears in Figure 1 appended to this report. 24. As the HVDC cables are available in fixed lengths, so-called “jointing bays” will be needed at regular intervals, potentially every 400m to 800m. The jointing bays, which comprise a shallow concrete-lined underground structure with access via a manhole cover, measure approximately 10m (length), by 3m (width) by 2m (depth), although at the point of landfall, slightly larger predominantly subterranean structures of 10m (length), 5m (width) and 5m (depth) will be required to connect each offshore cable with its corresponding onshore cable. Where possible, jointing bays would be located at the edges of field boundaries or roads to facilitate future access for maintenance and inspection purposes, to reduce visual intrusion and to minimise disruption on landuse operations. Please see paragraphs 111 - 115 in the Appendix for more discussion on these structures. 25. The corridor width can be narrowed where HDD is used (though a temporary compound of 2,500m2 will be needed to house the equipment at either end of the tunnel) and also where hedgerows need to be crossed. Apart from where HDD is used, cables would be installed at a minimum depth of 1.2m – up to 25m is proposed for the River Deben. Currently HDD is planned in a number of locations, including at the landfall point under the Bawdsey Cliffs (geological) Site of Special Interest (which is also located in the Suffolk Coast and Heaths AONB), the River Deben and other rivers, the East Suffolk (railway) Line, the A12, A14 and Ipswich-Cambridge/Ely (railway) Line and at Little Bealings where the built environment poses particular constraints. All other road crossings would be trenched, necessitating traffic management measures, including partial, and potentially full, closures (see paragraphs 95 and 103 for more detail). 26. Post-construction the cable corridor will be restored to a ‘natural’ state. Hedgerows will be replanted (though trees will not be – see paragraphs 127 - 128) and the previous (predominantly agricultural) land use restored. The land directly above the cables can remain in productive agricultural use, with some limited restrictions. 27. As mentioned, electricity is being transmitted by HVDC cables as this is the most efficient way to do so over long distances. However, this necessitates the electricity being converted from direct current to alternating current, which is the form electricity is transmitted around the National Grid. 28. A converter station is needed to perform this function. A converter station is needed for each phase of development, i.e. three in total for East Anglia ONE, East Anglia THREE and East Anglia FOUR. While East Anglia ONE Ltd is applying for consent for the future ducts for future phases of development, they are not applying for converter stations necessitated by future phases. Consequently, the application proposes a single compound limited to no more than 190m by 150m (2.85 hectares) in area within which no building(s) should exceed 130m in length, 85m in width or 25m in height. The exact details regarding layout, scale and appearance are to be agreed by the local planning authority post-consent. Please refer to Map 2 appended to this report.

86 29. In addition to the permanent works, temporary construction compounds will be established at various points along the cable route which will provide secure storage of plant and equipment, and accommodate essential welfare facilities for the site workforce. Two primary construction consolidation sites, each of one and a half hectares, have been identified. The first is immediately south of the Claydon interchange on the A14 (Junction 52); the second is located at the junction between the A12 and the B1438 south- west of Woodbridge. Both primary construction consolidation sites will likely form the principal means of access along the onshore cable route, and will also act as a hub for deliveries. Please refer to Map 1 appended to this report. 30. Additionally, up to five secondary construction consolidation sites, each of one hectare, will also be formed along the onshore cable route. These will act as secondary access / interchange hubs and will be located at the Bramford converter station site, the confluence of the B1077 south of Fynn Valley Golf Club, west of Church Street (south of Culpho), the confluence of Newbourne Road and Woodbridge Road (north of Newbourne) and the confluence of Park Lane (north-west of Kirton). Please refer to Maps 1 and 2 appended to this report. Offshore impacts 31. With respect to offshore issues, the Marine Management Organisation is the Government’s expert body on maritime issues. It, like the County Council, is a statutory consultee, and also a licensing and consenting body. 32. Based on the Council’s experience at the recent Galloper Offshore Windfarm examination, the principal offshore issues are likely to be ecological, particularly relating to sea birds, where a potentially significant residual impact on the red–throated diver remains. Impacts on offshore biodiversity, including seabed, fish and mammal communities are reported by the applicant to be not significant. 33. In the case of shipping and navigation, the windfarm would affect a number of shipping routes, principally those used by ships travelling between the UK ports of Tees and Humber and those in Belgium and the Netherlands. The expectation is that ships would route around the farm, slightly elongating their journeys. 34. The applicant describes the loss of fishing area as a negligible element of the overall resource available to commercial fisherman. 35. A Written Statement of Investigation has been provided which sets out how the applicant proposes to manage impacts on any archaeological assets that may be affected by the offshore works. 36. In all cases the applicant appears to have consulted the bodies with the relevant expertise.

The consenting process 37. The Planning Act 2008 created a separate consenting regime for certain schemes, described within that Act as being Nationally Significant Infrastructure Projects (NSIP). By virtue of having a generating capacity of over 100MW, East Anglia ONE qualifies as such a project. 38. Rather than a planning application being determined by the local planning authority, an application for a Development Consent Order is made directly

87 to the relevant Secretary of State – for energy projects it is the Secretary of State for Energy and Climate Change. In practice, the Planning Inspectorate undertakes a public examination and makes a recommendation to the Secretary of State. 39. The local authorities nevertheless retain a significant role in the consenting process. The Council is a statutory consultee and it has a number of roles and responsibilities to undertake. In particular, it must agree the consultation arrangements undertaken by the applicant and subsequently report to the Planning Inspectorate on the applicant’s performance in this regard. 40. The Council has fulfilled its remit in this respect, confirming that consultation undertaken by the applicant to date has been adequate. East Anglia ONE Ltd has also previously consulted widely on its project prior to submitting its application and the Council has responded to these consultations under delegated powers, after consultation with the relevant Cabinet member. 41. East Anglia ONE Ltd submitted their application for development consent to the Planning Inspectorate in November 2012 and it has since been accepted. The applicant is now responsible for holding a further and final round of consultation on its proposals. This is termed a Section 56 consultation (referring to the relevant clause of the Planning Act 2008) and runs for 40 days between 25 January and 6 March. This report comprises the Council’s recommended response to this consultation. 42. Council officers continue to work constructively with the applicant on the main issues as identified in this report, with an ambition of reaching common ground on as many matters as possible prior to the examination. Progress is likely to be made between the completion of this report, the meeting of Cabinet and the close of consultation and updates will be provided to the Cabinet Member for Roads and Transport at appropriate times. 43. Recommendation: That the Director for Economy, Skills and Environment, after consultation with the Cabinet Member for Roads and Transport, is authorised to make amendments to this submission in the event of further information becoming available before the closing date of this consultation and furthermore that officers engage on an ongoing basis with the applicant to resolve the outstanding issues identified herein.

Next steps 44. Following the closure of this consultation, the Planning Inspectorate will convene a preliminary meeting. Once this meeting closes, the examination period begins. A statutory timetable then comes into effect, with only 6 months allowed for examination, three months allowed for the Planning Inspectorate to make a recommendation to the Secretary of State and three further months for the Secretary of State to then make a decision. Therefore a final decision is expected around April/May 2014. 45. In terms of the ongoing role of the Council, the Planning Inspectorate will invite the submission of a Local Impact Report during the examination stage, the purpose of which is to provide each directly affected local authority with an opportunity to set out the likely impact of the proposed development(s) on the local authority’s area. As mentioned, it is the officers’ intention to also engage with East Anglia ONE Ltd in the meantime to seek

88 to resolve outstanding issues (as described below) with the intention of agreeing Statements of Common Ground. It is the intention to resolve as many of these concerns as possible prior to the examination. 46. The Council has to date been working very closely with the affected local planning authorities, Suffolk Coastal District Council and Mid Suffolk District Council, and the views of the authorities on the issues (so far as they are shared) do not differ. It is possible for the local authorities to submit a joint Local Impact Report, if this is considered appropriate. The Council has done this in the past, for example for the Galloper Offshore Windfarm – the examination of which has recently concluded. 47. Throughout the consultation process, the roles of the upper and lower tiers of local authorities are equal, though if consent is granted, it is the respective district councils as local planning authorities which would be responsible for the monitoring and enforcement of any permission granted. The Development Consent Order will require the local authorities’ subsequent agreement of a number of documents, for example relating to plans for traffic routeing, rights of way diversions, landscape strategy and archaeological investigations, before construction can begin. The County Council’s statutory duties and officers’ specialist knowledge means it will have a significant role in this respect. 48. Furthermore, the applicant states they intend to seek separate permits for movement of abnormal loads, temporary road traffic orders and notice of street works all of which the Council, as local highway authority, would need to issue. As Lead Local Flood Authority, the Council is also responsible for issuing certain consents under the Land Drainage Act 1991. Additional approvals may be needed from the Council concerning surface water management, depending on the timetable implementing the relevant provisions under the Flood and Water Management Act 2010. 49. If planning consent is achieved, and subject to gaining the other relevant consents, East Anglia ONE Ltd anticipate the onshore construction to commence in 2016 and offshore installation to start in 2017, with commissioning (first power generation) to occur in 2018.

Policy Context

National policies 50. The Planning Act 2008 requires that major infrastructure proposals must be considered in accordance with the relevant National Policy Statements. These relate to different types of infrastructure (ports, energy, waste water for example) and have been ratified by Parliament. 51. In the context of this proposal, the relevant National Policy Statements are the Overarching National Policy Statement for Energy (EN-1), National Policy Statement for Renewable Energy Infrastructure (EN-3) and the National Policy Statement for Electricity Networks Infrastructure (EN-5). Developments covered by these National Policy Statements can still be refused where the adverse impacts are judged to outweigh the benefits. 52. The National Policy Statements set out criteria against which the Planning Inspectorate should test applications. In large part these replicate the types of test that would be used for any development proposal, but their specific applicability to the energy sector is identified. Of additional note though is

89 that the National Policy Statements allow the Planning Inspectorate to proceed with the examination of projects on the basis that the scale and urgency for new energy infrastructure nationally is such that the “need” for each project does not have to be demonstrated on a case by case basis. This is a change from the past, where such discussions used to lead to considerable delay in the consenting process. 53. Although the National Policy Statements provide the main policy context for the Planning Inspectorate, it should also refer to other matters which it thinks are both important and relevant to the consideration of the application. This could include the affected local planning authorities’ development plans. However, in the event of a conflict between any National Policy Statements and any other matter, the National Policy Statements prevails.

Local Policies 54. As mentioned, this project affects parishes in both Suffolk Coastal and Mid Suffolk Districts. Suffolk Coastal’s new Local Plan (“Core Strategy and Development Management Policies”), although not yet adopted, is at an advanced stage of preparation. Mid Suffolk’s Local Plan consists of an adopted Core Strategy, but relies on development management policies dating from its previous Local Plan. The East of England Plan, which did form part of each district’s development plan has now been revoked. 55. Neither development plan contains policies that are specifically related to projects of this nature, though both contain generic development management policies which align with the principles set out in the National Policy Statements. For this reason, reference below is restricted to the National Policy Statements as they are primary reference documents for the Planning Inspectorate and generally cover the relevant matters most recently.

Recommended Response to Consultation 56. The following section sets out the rationale for the recommendations to the Cabinet set out in paragraphs 1 to 3 above.

General principles 57. Before looking at the detailed response on individual matters below, it is appropriate to set out a general set of principles which form the framework for the Council’s response: a) The Council recognises the need for a secure, affordable and sustainable energy supply and therefore supports in principle the development of renewable resources. However, East Anglia ONE Ltd should recognise that such schemes have potentially significant impacts on the natural and historic environment and local communities, which must be appropriately mitigated; b) Such major projects also have potentially significant implications for the local and sub-regional economy. The Council expects East Anglia ONE Ltd to minimise any negative impacts, but, equally importantly, seek to work with the local authorities and other parties to undertake wide ranging initiatives to ensure that any opportunities that secure socio-economic benefits for Suffolk are maximised;

90 c) The converter station will have a significant and permanent impact which cannot be adequately mitigated on site. Off-site planting will be essential to address, in some part, the residual visual impacts. The Council acknowledges that with the onshore cables proposed to be undergrounded, the potential for long-term impacts is reduced. However, there will still be permanent impacts particularly associated with the loss of trees and important hedgerows. The Council again considers this could be alleviated by a commitment from East Anglia ONE Ltd to engage with nearby landowners to secure offsite planting to offset the impacts of the project through environmental enhancements in the locality; d) Adequate protection is required for the historic environment. This means a thorough, systematic appraisal is required for the cable corridor to ensure the risk of destruction of archaeological assets is minimised. Similarly the mitigation of ecological impacts, particularly reptiles and bats must be robust; e) The impact of the construction process on communities in south east and mid Suffolk needs to be carefully managed. In particular, the road transport consequences (including noise, vibration and air quality) should be adequately addressed through appropriate traffic management, travel planning and provision of planning obligations (as necessary) by East Anglia ONE Ltd in consultation with the Council; f) The Council supports East Anglia ONE Ltd’s proposal to include the ducting for future phases of development in the East Anglia Zone with this application, as this would significantly reduce future disruption to local communities and expedite the restoration of the natural environment; and g) The Council believes that in developing the future phases of the East Anglia Zone, and in particular their connection to the National Grid, full consideration needs to be given to the onshore cabling and the potential impact on local communities and the local environment. 58. Recommendation: That East Anglia ONE Ltd is informed that the Council considers the principles identified above should inform their final proposals for East Anglia ONE.

Main issues Local routeing 59. The most locally contentious sections of the onshore cable route have related to the Bealings area where the parish councils (Playford, Great and Little Bealings and Grundisburgh) had requested alternative routeing to minimise impacts on those settlements (see below) and in Great Blakenham due to conflicting landuse proposals (see paragraphs 63 – 70). 60. Council officers have met with representatives of Playford, Great and Little Bealings and Grundisburgh to discuss their concerns. These can be summarised as relating to traffic disruption, noise, landscape effects, drainage impacts, safety concerns and the duration and timing of the construction works. 61. East Anglia ONE Ltd, in response to the consultation feedback produced an additional report in May 2012 setting out the respective impacts of

91 alternative routeing arrangements in this area. This review concluded that the alternatives available were longer, had greater environmental impacts, particularly relating to tree loss, and potentially more river crossings. East Anglia ONE Ltd now also proposes to use HDD to minimise disruption where the corridor passes through the narrow strip of land between Great and Little Bealings. 62. Having undertaken a site visit, and having had regard to the potential long- term environmental implications of an alternative route either to the north of Great Bealings or to the south of Little Bealings, the council officers consider the routeing put forward by East Anglia ONE Ltd and the mitigation provided by way of HDD is appropriate.

Sterling Suffolk Greenhouse Proposal 63. When Suffolk County Council granted planning permission for the energy from waste plant at Great Blakenham (which is currently under construction) a condition was imposed requiring the applicant to undertake ‘best endeavours’ to make use of the surplus heat that would be generated by the facility and thus deliver combined heat and power (CHP). 64. Having explored a number of options, SITA UK, the developer of the plant, is now pursuing an opportunity to use the ‘waste’ heat in commercial greenhousing nearby to facilitate the large scale production of fresh produce. 65. While no formal planning application has been submitted at this time, it is understood that the development would consist of two greenhouses covering an area of 20 hectares to the west of Bramford Road (B1113) and south of Blackacre Hill in the parishes of Little and Great Blakenham. The cable corridor for East Anglia ONE passes directly through this land and poses a particular conflict with the northernmost of the two proposed greenhouses, where the cables emerge from an HDD installation under the A14, River Gipping and Ipswich-Ely/Cambridge Line, as explained earlier in this report. The pipe(s) bringing the heat from the energy from waste plant to the greenhouses will also intersect with the East Anglia ONE cables. 66. Such an innovative greenhouse project would bring welcome local economic benefits (potentially 180 permanent jobs) and offset significant carbon emissions by making use of otherwise waste heat and by encouraging more localised food production, hence reducing the associated ‘food miles’; all benefits which align well with the Council’s ambitions to become the Greenest County. 67. Consequently, without wishing to prejudice any views the Council may express on a future planning application, the Council would not wish the East Anglia ONE development to exclude the possibility of this type of development in this location. 68. To this end, the Council has been working to ensure the two projects are not mutually exclusive by encouraging pro-active discussions between the respective developers. A number of solutions have been discussed with concessions being made by both parties. 69. The Council has recently received assurances from East Anglia ONE Ltd that, particularly through modifications to the layout of the greenhouse development and careful thought to the phasing of both projects, neither

92 scheme will be compromised. It is understood that the parties continue to work together to formalise an agreement and the Council encourages East Anglia ONE Ltd to conclude this process before the Preliminary Hearing. 70. Recommendation: The Council expects East Anglia ONE Ltd to continue to engage with the promoters of the Sterling Suffolk Greenhouse development and commit formally to binding proposals which satisfactorily respond to the requirements of both projects. The application documents 71. Overall, the Council is broadly supportive of the provisions included in the draft Development Consent Order, though retains some concerns in certain areas, in particular related to the discharge of some of the conditions or “Requirements” – as they are termed in the Development Consent Order. 72. The Council has a particular interest in the Requirements as they relate to onshore matters and comments below on their adequacy, and in particular the supporting documents that they provide for (where submitted in draft form), namely the Outline Code of Construction Practice, Design and Access Statement, Ecological Management Plan, Outline Landscape Strategy and Archaeological Mitigation Plan and Written Statements of Archaeological Investigation. 73. In a number of cases, the application lacks detail on the mitigation measures as this is proposed to be set out in future documents to be agreed with the local authorities. 74. Please note that a more detailed consideration of the topics below is attached in the Appendix.

Socio-economic and skills 75. The Council welcomes the potentially significant benefits of this project in terms of the number of jobs it will create and contribution it will make to the local economy. However, the Council believes that greater efforts need to be made to realise the maximum extent of these benefits and that the framework to achieve this should be set out in advance of the examination of the application. 76. In particular, by failing to identify the measures East Anglia ONE Ltd might take to deal with both the supply chain and the skills issues, the Council does not believe that the proposals set out in the Environmental Statement adequately respond to the identified infrastructural and labour market pressures. 77. A particular complication is that the documentation does not indicate the preferred port(s) for construction and operations work, which makes it difficult for the public (or private) sector to respond to any infrastructure capacity constraints that might exist. Improvements to quay headings and site accessibility and servicing, for example, can take time to implement and if there are not adequate facilities in place locally, then investment could go overseas, contrary to East Anglia ONE Ltd’s stated objectives. This issue over timescale is equally pertinent to building industrial capacity and retraining, and measures need to be put in place early. At the moment the lack of clarity over the choice of ports and scale of associated business development makes planning for this very difficult.

93 78. The Council supports the Offshore Wind Developers Forum’s (a Government and industry body) “Vision” for UK firms to provide 50% of the content of future windfarms and East Anglia Offshore Wind Ltd’s view that 30% of total UK content could be regionally based. In the case of the latter, the Council considers that East Anglia Offshore Wind’s procurement strategy should contain a commitment to achieve this. 79. Though the Council notes the commitment to work with local suppliers, it would wish to see more evidence in the application as to the initiatives that will be undertaken to support economic development in Suffolk to minimise leakage; a clear reference to drawing on best practice from elsewhere should be included. Initiatives should include setting up local supply chain events and a portal to promote East Anglia ONE and later phase opportunities. The Council would also expect to see a local procurement resource established to advise and encourage companies in Suffolk and the sub-region to supply this project and subsequent phases. It should help local companies ready themselves to be a supplier to the offshore industry and set out how they can successfully promote their services for procurement. 80. The Council also expects East Anglia Offshore Wind Ltd to engage on an ongoing basis with business representative organisations, such as the Federation of Small Businesses and Chambers of Commerce, as well as the East of England Energy Group (EEEGR). 81. Any supply chain strategy should also have strong regard to the potential long-term benefits of initiatives being undertaken and should include measures targeted at both the construction and operational stages of the East Anglia Zone’s development. The strategy should also include measures to deal with a potential ‘boom and bust’ scenario and should be developed in consultation with other major developers in the region such as EDF Energy. 82. The Council would also wish to see a stronger commitment from East Anglia ONE Ltd to engage with the New Anglia Local Enterprise Partnership and its initiatives, for example in helping to deliver development within the Great Yarmouth and Lowestoft Enterprise Zone. Similarly, recognition of, and support for Lowestoft and Great Yarmouth’s designation as a Centre for Offshore and Renewable Engineering is warranted. 83. Having identified that there will be pressures on the local labour market, no specific mitigation is detailed to address this, other than the brief mention of a Skills Strategy which East Anglia Offshore Wind Ltd is developing separately. Without being able to comment on that strategy, the Council cannot confirm that the mitigation proposed is adequate. While the measures being developed regionally may well be of benefit, there is no guarantee when or where they will be effective. 84. The Council’s ambition is to see as many local people as possible secure employment during the construction and operational phases of the project. The Council therefore expects East Anglia Offshore Wind Ltd to work closely with the local authorities and other agencies to develop a jointly agreed skills strategy which seeks to maximise local opportunities, reduce the need for imported labour and catalyses sustained improvements in education and skills attainment locally. In particular, the local authorities

94 expect East Anglia Offshore Wind Ltd to have regard to Suffolk’s ‘Raising the Bar’ initiative. 85. The Skills Strategy should set out an indicative target for local recruitment during the construction and operational phases and identify the types of interventions required to maximise the opportunities for Suffolk residents. This should include how 'hard to reach' groups and the unemployed will be engaged, the provision of apprenticeships, pathways to higher skilled occupations and the up-skilling and re-skilling of workers to sustain employment at each stage of the development. Provisions which set out the degree to which skills displacement as a result of the project can be mitigated should also be included. The Skills Strategy should consider the full term of the East Anglia Zone’s development, not be focussed on East Anglia ONE alone and also be cognisant of work being undertaken to support other major projects locally, such as Sizewell C. 86. A further significant omission in the Environmental Statement is the failure to consider in any detail the in-combination impacts of this project (as required by National Policy Statement EN-1), not only with other windfarms but with other major infrastructure projects, in particular Sizewell C, which is currently at Stage 1 consultation. This would magnify the potential impacts on the local labour force, and highlight other cumulative issues, particularly demand for local tourist accommodation. East Anglia ONE Ltd should therefore seek to develop a long-term mitigation strategy that complements others being developed in the area, for example EDF Energy’s proposals to support their development of Sizewell C. 87. Recommendation: The Council recognises and welcomes the potentially significant socio-economic benefits that East Anglia ONE, and future phases of the East Anglia Zone may bring, but believes that East Anglia Offshore Wind Ltd, in advance of the examination of East Anglia ONE, should set out the mechanisms it intends to use to realise these benefits and to mitigate any cumulative adverse impacts. Furthermore, East Anglia Offshore Wind Ltd urgently needs to work with the local authorities to ensure that its ability to invest in the sub-region is not undermined by infrastructural constraints which could be remedied in advance.

Archaeology 88. The extensive onshore works will cause significant ground disturbance that has the potential to damage, and destroy, any archaeological deposit that exists in these areas. The proposed onshore cable route passes through a number of areas of high archaeological importance – within the immediate area of the proposed route nearly 600 heritage assets have been recorded. 89. The significance of most of these heritage assets has not yet been established. It is also very likely that the total number of archaeological remains is considerably higher, because the area has not been the subject of systematic field evaluation. It is therefore critical to ensure that the investigation proposed for East Anglia ONE adequately protects both designated and undesignated assets. 90. The Council considers that the “Written Scheme of Investigation: Cable Corridor” is inadequate and undertaking of the proposals therein is likely to pose serious risks to the historic environment in Suffolk. Targeting trenched evaluation towards only the known archaeological resource poses

95 significant risks to potentially significant heritage assets, hitherto unidentified. As noted above, Suffolk’s rich historic environment makes the likelihood of encountering such resources high. For this reason a systematic trenched evaluation, involving digging of trial trenches along the entire cable route in advance of construction, is critical. This advice is consistent with that given by the Council for other comparable linear schemes (water pipelines) in Suffolk. The Council has also reached a similar agreement with National Grid concerning their proposed undergrounding of electricity transmission cables in south Suffolk. 91. With regard to the archaeological interests of the converter station, the Council is satisfied with the approach set out by the applicant. However, the Council would reiterate that both the geophysical survey of the site boundary and the trenched evaluation of the footprint of the converter station should be undertaken before consent is granted, to allow for in situ preservation of any important archaeological remains. The Council is concerned that there appears to have been little progress on this work and expects every effort to be made to secure access to the land for this purpose. 92. Recommendation: The Council expects East Anglia ONE Ltd to conclude the field evaluation for the converter station prior to development consent and to provide more substantive mitigation proposals for the cable corridor in order to adequately safeguard the historic environment.

Transport and Traffic 93. Impacts of construction traffic are a major concern of residents of those parishes directly affected by the onshore works, particularly with respect to the operation of the Construction Consolidation Sites, which will be the main destination points for HGVs. These are the locations from which point the vehicles access the cable corridor using a temporary haul road (see Figure 1, appended to this report). Additionally, they (like the HDD sites) will be lit on a 24 hour basis giving rise to additional concerns about residential amenity. 94. In terms of the scale of trips during construction, the applicant’s Environmental Statement sets out a worst case scenario as follows. However, as detailed below and in the Appendix, the Council considers that further information is required to substantiate these figures, which are considered likely to be underestimates: a) Landfall point (Bawdsey); 45 HGVs deliveries and nine construction workers per day over a 21 week duration; b) Cable corridor; 29 HGV deliveries per day per section (there are seven sections, focused around the seven consolidation sites) and 45 additional HGV deliveries per day for each of the nine HDD sites. 79 personnel per 500m section plus nine workers at each HDD site. All over a 44 week duration; and c) Converter station: 14 HGV deliveries and 100 construction workers per day of 46 week duration. 95. The Environmental Statement identifies five locations which will experience a significant increase in traffic volumes (more than 10%); namely Ipswich Road, Grundisburgh; Top Street, Martlesham; Paper Mill Lane, Bramford;

96 B1083 to Bawdsey and Ipswich Road, Waldringfield. The draft Development Consent Order also provides for three roads to be stopped up temporarily, with specific arrangements to be agreed with the County Council; Park Lane, Kirton; The Street, Newbourne; Ipswich Road, Waldringfield. Any further stopping up would be subject to the agreement of the County Council. 96. The Council is currently reviewing the detailed assumptions behind the analysis undertaken by East Anglia ONE Ltd and therefore the comments in this section and in particular in the relevant section of the Appendix should be regarded as preliminary with further detail to follow. 97. The proposed mitigation for the anticipated transport impacts is set out in the conditions of the draft Development Consent Order. The applicant must produce an Access Management Scheme, Traffic Management Plan and a Travel Plan. 98. While the Council is broadly content with this arrangement, it has not been provided with any of these documents so cannot confirm that the proposed measures within them, individually or collectively, will be satisfactory. Furthermore, all these documents should be agreed by the local planning authority in consultation with the local highway authority. 99. As mentioned, traffic management and working arrangements are a key issue for local communities affected by the project. The Council is concerned that if these documents do not materialise until post-consent, residents will have insufficient opportunity to raise their specific concerns on the proposed mitigation, for example relating to routeing, access arrangements, and working hours. 100. Consequently the Council has concerns about progressing to the Preliminary Hearing without these documents being available in draft form. They form a critical part of the project’s mitigation strategy and the Council or local communities may wish to bring specific issues to the Examining Authority’s attention at the Preliminary Meeting to inform the examination of the application. East Anglia ONE Ltd should provide them at the earliest opportunity to enable constructive discussions to progress in advance of the examination. 101. East Anglia One Ltd also proposes to undertake a “dilapidation survey” before and after project construction to identify any necessary remediation to the highway. This is supported in principle and should be committed to in the Code of Construction Practice. 102. The detailed views of the Council on the contents of the Access Management Scheme, Traffic Management Plan and Travel Plan can be found in the attached Appendix. In summary, the Council expects safe access to be achieved to all the consolidation sites. This may necessitate the construction of passing places on some routes. The Council would wish to assess, on a case by case basis, and having regard to the views of the local community, the need for any of the highways improvements necessitated by East Anglia ONE to be retained. For this reason the Council considers that Requirement 34 concerning restoration should also require the involvement of the local highway authority. In all cases, the Council reserves the right to seek planning obligations to secure offsite works which are needed to mitigate the transport impacts of the development. The extent to which this might be necessary cannot be confirmed until the Council

97 receives the aforementioned clarifications on the transport assessment to date. 103. With respect to the Traffic Management Plan, the Council wishes to see any disruption to the highway network minimised and in particular has concerns over street works to Paper Mill Lane and Somersham Road in the parishes of Bramford and Little Blakenham due the options available for diversions. Furthermore, the Council does not support routeing of construction traffic through Sproughton or Coddenham. 104. In line with provisions agreed at the recent examination of the Galloper Offshore Windfarm, the Travel Plan for East Anglia ONE should include measures to encourage those individuals working on the East Anglia ONE project both onshore and offshore to travel to their places of work more sustainably. 105. Recommendation: The Council has pressing concerns over the adequacy of the transport assessment and in particular the estimation of HGV numbers. The Council should be provided with draft versions of the Access Management Scheme, Traffic Management Plan and Travel Plan as a matter of urgency. The Council cannot confirm that adequate mitigation for the transport impacts of this scheme has been provided for at this time and considers that planning obligations may be required for this purpose. Noise, Vibration & Air Quality 106. The Council is unable to comment comprehensively on the likely impact of the development on these matters due to the level of detail presented in the Environmental Statement and discrepancies in the way that data has been presented in some cases – in particular there is inconsistency between the Noise, Vibration and Traffic assessment reports as to exactly which routes are likely to be affected. Furthermore, a number of the policy tests, as set out in the National Policy Statement EN-1, have not been met. 107. In the case of noise, noise sensitive areas that may be affected have not been identified with respect to the construction traffic routes. Furthermore, there has been no quantification of the likely numbers of properties that would be impacted by noise, nor differentiation between the relative uplift of HGV versus other traffic movements. At the moment it is therefore not possible to determine whether any mitigation is required and what it might consist of. 108. With respect to vibration, the impacts cannot be confirmed until routeing arrangements are clarified. To avoid the potential for damage to sensitive buildings and unnecessary disturbance the routes used for HGV traffic will need to be maintained in good order throughout the construction process. The “dilapidation survey” referred to in paragraph 101 above should be used to identify areas in need of remediation to mitigate the vibration impacts of the development. 109. In terms of air quality, the Council has some concerns about the impact of increased HGV movements on the Air Quality Management Area at the Norwich Road/Valley Road junction in Ipswich and believes that, in line with Section 5.2 of the National Policy Statement EN-1 an assessment of the impact on air quality in this location should be undertaken. 110. Recommendation: The Council expects the deficiencies identified herein relating to the assessment of noise, vibration and air quality impacts, in

98 particular relating to the consistency of assumptions across these areas, are addressed by the applicant as soon as possible. Public Rights of Way 111. Thirty-nine temporary closures would be put in place on the public rights of way, with diversions provided for all but four of these, namely at the landfall point near Bawdsey, near Newbourne and two adjacent to the Converter Station at Bramford. Ten cycle routes are also crossed, but none would require closure as access for cyclists will be maintained as part of traffic management. While the temporary closure notices sought will cover a six month period, actual closures are only anticipated to last for approximately two weeks at each location. 112. Five of the public rights of way affected are ‘promoted footpaths’; The Suffolk Coastal Path, The Stour and Orwell Walk, The Fynn Valley Walk, the Gipping Valley River Path and Martlesham Circular Walk. The Suffolk Coastal Path is however currently impassable at the point affected (landfall at Bawdsey) due to coastal erosion. 113. East Anglia ONE Ltd should be aware that it is the County Council, as local highway authority, who should agree the diversionary routes, rather than the local planning authority. The Council emphasises the need to minimise the duration of any closures, particularly related to the promoted footpaths. It is also important that closures are properly managed, and supported with an effective communications strategy. This should be set out in the Code of Construction Practice. 114. A pre-construction survey of the public rights of way affected is needed to ensure that on completion of the project the network is returned to its original state. 115. Recommendation: The County Council should be identified as the relevant authority to agree matters related to the public rights of way network including, but not limited to, diversionary routes, advertisement of temporary closures and provisions for surveying and restoration.

Environment 116. The size of the converter station is such that it cannot be wholly screened and there will be significant residual impacts on visual amenity. At 37km long and with a working width of 55m, the cable corridor involves disturbance to a significant area and will have temporary and permanent impacts on the environment. 117. As mentioned, one third of the cable corridor passes through the Suffolk Coast and Heaths AONB; in doing so it also crosses the Deben Estuary (including Martlesham and Kirton creeks), which is a designated Special Protection Area, Ramsar site and Site of Special Scientific Interest (SSSI) for its populations of over-wintering waders and wildfowl and also for its diverse saltmarsh communities. Bawdsey Cliffs SSSI, noted for its geological interest, is also directly affected. The cable corridor crosses four non-statutory sites, namely Millers Wood Ancient and Semi-Natural Woodland, the River Gipping, Mill River and Suffolk Shingle Beaches County Wildlife Sites. 118. In the case of the Deben Estuary, the associated creeks and the County Wildlife Sites, it is proposed to use HDD, i.e. to tunnel under them.

99 Temporary access may be required to Suffolk Shingle Beaches County Wildlife Site at Bawdsey, depending on the approach taken to HDD (see paragraph 118 in the Appendix). This site is designated for its vegetated shingle and associated invertebrates; although the main areas of vegetated shingle are proposed to be avoided, there will be impacts if this area is used for temporary working. The practicalities of re-instating the maritime cliff and slope habitat may have been underestimated in the Environmental Statement given its unconsolidated nature, and therefore access to the beach should be avoided.

Landscape, visual and ecological impacts 119. The Council supports the principles that have been used to inform the choice and location of the onshore infrastructure for this project, in particular that the cabling will be entirely underground. A pylon-led scheme would have been entirely unacceptable in the Council’s view. 120. The Council also generally supports the approach taken to routeing, specifically that efforts have been made to avoid built up areas and designated sites as far as possible, with permanent landscape impacts being reduced in some cases by using HDD (but see paragraph 128) as well as avoiding large areas of woodland and reducing the need to create gaps in hedgerows. 121. Similarly, the Council agrees that the choice of the location of the converter station compound being sited as near as possible to the existing Bramford electricity substation, and positioned to take advantage of the screening offered by the adjacent woodland, is appropriate. 122. However, despite the ‘embedded mitigation’ within the project’s design, the development still has significant environmental impacts which need to be appropriately mitigated and compensated for, as necessary. 123. The National Policy Statements EN-1 and EN-5 are quite clear in this respect and furthermore that opportunities not only to protect, but also to enhance, the environment should be captured. The Council also draws attention to the ability of the Planning Inspectorate to require off-site tree and hedgerow planting as a form of mitigation, and the expectation that opportunities to maximise gains for biodiversity in and around the development should similarly be secured by condition or planning obligation.

Landscaping 124. The Council is broadly content with the drafting of the conditions that relate to the landscaping, other than the time span proposed for maintenance. A five year period of aftercare for the planting associated with the converter station is insufficient; given the scale and visual impacts of the development, 10 years would be appropriate to ensure that the onsite planting is properly delivered. 125. The Outline Landscape Strategy is not only inadequate in this respect, but also in others, discussed in brief here and also in the Appendix in more detail. Principal amongst these concerns is that the Council considers that off-site planting is critical to make the development acceptable in planning terms. Specifically, it is needed to further mitigate the residual visual impacts of the converter station over a wider area, improve the capacity of

100 the local landscape to absorb the impact of the converter station in the longer term, and also to offset, by way of local environmental enhancements, the impacts of the onshore cabling on hedgerow and tree loss, as discussed in more detail below. Offsite planting should be secured via a Section 106 agreement. 126. The Environmental Statement notes that around 90 hedgerow crossings will be made. A proportion of these are identified as ‘important’ having regard to their age and species diversity and/or the wildlife they support. Each crossing will be approximately 35m in length. In all, therefore, nearly 3km of hedgerow will be temporarily removed. 127. While it is recognised that hedgerows will be replaced, there will be permanent loss of hedgerow trees and other important, including ‘veteran’, (such as oak and ash in the Newbourne and Martesham areas) trees. Veteran trees are recognised as key biodiversity assets, the loss of which should be offset. Clearly important hedgerows, which by definition must be at least 30 years old cannot be replaced in the short term. This indicates an enduring impact that extends beyond visual amenity, but also to landscape character and habitat loss (for example bat roosts) in a number of locations. 128. The Council notes that HDD is not being proposed widely enough to minimise impacts on hedgerow loss or important tree copses; the proposed mitigation is rather to narrow the working width of the open trenching to 35m from the typical working width of 55m. The Council considers that, as a minimum, East Anglia ONE Ltd should consider further HDD under those hedgerows and tree copses identified as important (provided there are no overriding environmental reasons not to do so). In the event that open- trenching remains the applicant’s preference, it should explore measures beyond just narrowing the working width of the corridor in order to mitigate the impact of these crossings. 129. Furthermore, with respect to the converter station, the Council draws attention to the design policies in National Policy Statement EN-1 and consequently wishes to understand why the bed levels could not be lowered further to help alleviate the visual impact of the building.

Ecology 130. The proposals concerning the translocation of reptiles are currently lacking in detail and therefore inadequate. Information should be provided on the proposed receptor sites so that preparation works to secure and manage them can be instigated. It should not be assumed that receptor sites can be readily identified. It is also important to consider the need to compensate for habitat loss. 131. The Council believes additional surveys are essential to assess the impacts of the converter station, particularly lighting, on bats using the nearby nationally important hibernation site at Little Blakenham Pit SSSI.

Restoration 132. Requirement 34 requires land temporarily used for construction to be reinstated within 12 months of the completion of the connection works. Generally (but see comments at paragraph 102), the Council would expect land to be reinstated as soon as practicably possible, and thus the condition should be reworded accordingly.

101 133. The Council would wish to see the minimum amount of agricultural land, particularly of the highest quality grades, sterilised as a consequence of this development. Thus careful consideration needs to be given to the depth of cabling and the number and location of jointing bays and associated infrastructure.

Use of HDD 134. As mentioned, HDD is used in a number of locations along the cable route as means of mitigating environmental impacts or overcoming physical constraints. Two such locations are at Bawdsey and under the Deben Estuary and associated creeks. 135. The draft Development Consent Order does not provide for open cut trenching in these locations, thus if HDD is not successful, it is not clear how the project may proceed. The Council only raises the issue as it has some concerns over the implications of HDD for the stability of the unconsolidated cliffs at Bawdsey and the highly designated and sensitive Deben Estuary, should open trenching be required. 136. Recommendation: The Council considers that the residual impacts of the development on visual amenity, landscape character and biodiversity warrant a comprehensive section 106 agreement to make the development acceptable in planning terms. Furthermore, the Council requires more detail on the proposed ecological mitigation to confirm its robustness, further consideration of bed levels at the converter station and assurances that the landscape restoration will commence as soon as possible.

Sources of Further Information a) East Anglia ONE Ltd application documents http://infrastructure.planningportal.gov.uk/projects/eastern/east-anglia- one-offshore-windfarm/?ipcsection=app [NB. The Council holds a hard copy of all this documentation] b) Department of Energy and Climate Change: National Policy Statements: Overarching Energy (EN-1); Renewable Energy Infrastructure (EN-3) and Electricity Networks (EN-5) http://www.decc.gov.uk/en/content/cms/meeting_energy/consents_pla nning/nps_en_infra/nps_en_infra.aspx c) Minutes of Cabinet meeting 10 July 2012 (Bramford to Twinstead Electricity Transmission Line – Connection Options Report – Response of Suffolk County Council) http://committeeminutes.suffolkcc.gov.uk/LoadDocument.aspx?rID=09

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102

103 104 Figure 1 – Cable Installation

105 Appendix

This appendix contains the detailed comments of specialist officers of the Council as they relate to the main issues. A summary is provided in the main report. Socio-economic and skills 1. The Council welcomes the potentially significant benefits of this project in terms of the number of jobs it will create and contribution it will make to the local economy. However, the Council believes that greater efforts need to be made to realise the maximum extent of these benefits. 2. The Council is disappointed not to have been consulted on the scope of the socio-economic chapter (Chapter 27) of the Environmental Statement until extremely late in the process – only being provided with a draft socio-economic chapter on 16 October 2012. This report was made available following a tri-partite meeting with the Planning Inspectorate at which the concerns of the local authorities on this subject matter were presented. 3. That the Council was not able to comment on the draft socio-economic chapter has meant it must now raise concerns against the submitted application and its performance against the relevant tests in the National Policy Statement EN-1. Section 5.12 of this document requires promoters to undertake and include in their application an assessment of all relevant socio-economic impacts, including cumulative effects with other major schemes in the region. This was reiterated through the EIA scoping process and in subsequent correspondence from this Council dated 2 August 2012. East Anglia ONE Ltd will be aware that in coming to a view on this application, the Planning Inspectorate is directed to have regard to any positive provisions the developer is planning to mitigate the impact of their development, so they should be made clear. 4. The Socio-Economic chapter recognises that (Chapter 27, paragraphs 137-139); “the current constrained capabilities of the regional and sub-regional businesses and the scale of commercial and industrial infrastructure needed to service the offshore wind industry [requires] major investment from both the public and private sectors …, including providing a more extensive supply chain, an increase in appropriately skilled labour, and extended port facilities.” And referring to the particular issue of cumulative demands on labour; without a continuing and extensive programme of skills training [this] would potentially lead to skills shortages in the period 2016/2017 onwards. 5. The Council does not believe that the proposals set out in the Environmental Statement adequately respond to this analysis, in particular there is insufficient specificity presented within the application (as required) as to the measures East Anglia ONE Ltd might take to deal with both the supply chain and the skills issues.

1 6. A further complication is that the documentation does not indicate the preferred port(s) for construction and operations work, which makes it difficult for the public (or private) sector to respond to any infrastructure capacity constraints that might exist. Improvements to quay headings and site accessibility and servicing, for example, can take time to implement and if there are not adequate facilities in place locally, then investment could go overseas, contrary to East Anglia ONE Ltd’s stated objectives. This issue over timescale is equally pertinent to building industrial capacity and retraining, and measures need to be put in place early. At the moment the lack of clarity over the choice of port(s) and scale of associated business development makes planning for this very difficult. 7. The Council supports the Offshore Wind Developers Forum’s (a Government and industry body) “Vision” for UK firms to provide 50% of the content of future windfarms and East Anglia Offshore Wind’s view that 30% of total UK content could be regionally based (Chapter 28, paragraph 155). In the case of the latter, the Council considers that East Anglia Offshore Wind Ltd’s procurement strategy should contain a commitment to achieve this. 8. Though the Council notes the intention to work with local suppliers, it would wish to see more evidence in the application as to the initiatives that will be undertaken to support economic development in Suffolk to minimise leakage; a clear reference to drawing on best practice from elsewhere should be included. Proposals should include setting up local supply chain events and a portal to promote East Anglia ONE and later phase opportunities. The Council would also expect to see a local procurement resource established to advise and encourage companies in Suffolk and the sub-region to supply this project and subsequent phases. It should help local companies ready themselves to be a supplier to the offshore industry and set out how they can successfully promote their services for procurement. 9. The Council also expects East Anglia Offshore Wind Ltd to engage on an ongoing basis with business representative organisations, such as the Federation of Small Businesses and Chambers of Commerce, as well as the East of England Energy Group (EEEGR). 10. Any supply chain strategy should also have strong regard to the potential long-term benefits of initiatives being undertaken and should include measures targeted at both the construction and operational stages of the East Anglia Zone’s development. The strategy should also include measures to deal with a potential ‘boom and bust’ scenario and should be developed in consultation with other major developers in the region such as EDF Energy. 11. The Council would also wish to see a stronger commitment from East Anglia ONE Ltd to engage with the New Anglia Local Enterprise Partnership and its initiatives, for example in helping to deliver development within the Great Yarmouth and Lowestoft Enterprise Zone. Similarly recognition of, and support for, Lowestoft and Great Yarmouth’s designation as a Centre for Offshore and Renewable Engineering is

2 warranted - the Council notes that the Baseline Literature Review (Chapter 28, section 28.2.1) makes no reference to the supporting documentation for the Enterprise Zone, nor to the prospectus which explains Great Yarmouth and Lowestoft’s designation as a Centre for Offshore Renewable Engineering. 12. East Anglia ONE Ltd recognises that the region is “well positioned” to benefit from the offshore wind industry (Chapter 28, paragraph 153) with a workforce “with the capability for retraining and up-skilling” (Chapter 28, paragraph 154). However, having identified that there will be pressures on the local labour market (Chapter 28,, paragraph 170), no specific mitigation is detailed to address this, other than the brief mention of a Skills Strategy which East Anglia Offshore Wind Ltd is developing separately (Chapter 28,, paragraph 191). Without being able to comment on that strategy, the Council cannot confirm that the mitigation proposed is adequate. While the measures being developed regionally (Chapter 28,, paragraph 172) may well be of benefit, there is no guarantee when or where they will be effective. 13. The Council’s ambition is to see as many local people as possible secure employment during the construction and operational phases of the project. The Council therefore expects East Anglia Offshore Wind Ltd to work closely with the local authorities and other agencies to develop a jointly agreed skills strategy which seeks to maximise local opportunities, reduces the need for imported labour and catalyses sustained improvements in education and skills attainment locally. In particular, the local authorities expect East Anglia Offshore Wind Ltd to have regard to Suffolk’s ‘Raising the Bar’ initiative. 14. The Skills Strategy should set out an indicative target for local recruitment during the construction and operational phases and identify the types of interventions required to maximise the opportunities for Suffolk residents. This should include how 'hard to reach' groups and the unemployed will be engaged, the provision of apprenticeships, pathways to higher skilled occupations and the up-skilling and re-skilling of workers to sustain employment at each stage of the development. Provisions which set out the degree to which skills displacement as a result of the project can be mitigated should also be included. The Skills Strategy should consider the full term of the East Anglia Zone’s development, and not be focussed on East Anglia ONE alone and also be cognisant of work being undertaken to support other major projects locally, such as Sizewell C. 15. A further significant omission in the Environmental Statement is the failure to consider in any detail the in-combination impacts of this project (as required by National Policy Statement EN-1 (section 5.12.3)), not only with other windfarms (Chapter 28, paragraph 211), but with other major infrastructure projects, in particular Sizewell C, which is currently at Stage 1 consultation. This would magnify the potential impacts on the local labour force, and highlight other cumulative issues, particularly demand for local tourist accommodation. While the use of tourist facilities would provide direct benefit to the proprietors of such facilities,

3 construction workers are unlikely to contribute to the local economy in the way tourists staying in such accommodation otherwise would. Equally, there may be issues of compatibility between, say, construction workers living for extended periods of time in caravan parks alongside seasonal, short term visitors. East Anglia ONE Ltd should therefore seek to develop a long-term mitigation strategy that complements others being developed in the area, for example EDF Energy’s proposals to support their development of Sizewell C. 16. Recommendation: The Council recognises and welcomes the potentially significant positive socio-economic impacts that East Anglia ONE, and future phases of the East Anglia Zone may bring, but believes East Anglia Offshore Wind Ltd, in advance of the examination of East Anglia ONE, should make more explicit the commitments it intends to make to realise these benefits and to mitigate any cumulative adverse impacts. Furthermore, East Anglia Offshore Wind Ltd urgently needs to work with the local authorities to ensure that its ability to invest in the sub-region is not undermined by infrastructural constraints which could be remedied in advance. Archaeology 17. The extensive onshore works will cause significant ground disturbance that has the potential to damage, and destroy, any archaeological deposit that exists in these areas. The proposed onshore cable route between Bawdsey and Bramford passes along the northern side of the Felixstowe peninsula, which is an area of high archaeological importance. It skirts the hinterland of Ipswich, one of the earliest and most important towns in the country in terms of archaeological significance. It also crosses the valley of the River Gipping, which is another area of high archaeological importance. 18. There is a high density of known archaeological sites, recorded in the County Historic Environment Record, within the immediate area of the proposed route and nearly 600 heritage assets recorded along the route. This is indicative of the rich historic environment in, and archaeological importance of, south-east Suffolk. However, the significance of most of these heritage assets has not yet been established. It is also very likely that the total number of archaeological remains is considerably higher, because it has not been the subject of systematic field evaluation. 19. It is therefore critical to ensure, in line with Section 5.8 of the National Policy Statement EN-1, that the investigation proposed for East Anglia ONE adequately protects both designated and undesignated assets. As paragraph 5.8.14 notes, “once lost, heritage assets cannot be replaced and their loss has a cultural, economic and social impact”. 20. The Council is content with the drafting of Requirement 25 (the relevant condition in the draft Development Consent Order) which provides for a Written Statement of Investigation for each stage of development to be agreed by the local planning authority, in consultation with this Council. However, while the Environmental Statement is generally satisfactory

4 (see further comments below), Appendix 25.6 entitled “Written Scheme of Investigation: Cable Corridor” is considered inadequate and undertaking of the proposals therein is likely to pose serious risks to the historic environment in Suffolk for the reasons explained below. 21. While the Council is content for a staged approach to archaeological investigation for the cable corridor, with fieldwork undertaken if development consent is secured, this fieldwork should not be limited to targeted trenched evaluation based only on the known archaeological resource. The Council has continually advised the applicant that such an approach is insufficient as it poses significant risks to potentially significant heritage assets, hitherto unidentified. As noted above, Suffolk’s rich historic environment makes the likelihood of encountering such resources high. For this reason a systematic trenched evaluation, involving digging of trial trenches along the entire cable route in advance of construction, is critical. 22. Paragraph 5.8.9 of the National Policy Statement EN-1 states that where development sites have the potential to include heritage assets of archaeological interest, applicants should take out a desk-based assessment, and where this is insufficient to properly address the interest, a field evaluation. It is the Council’s view that a systematic trenched evaluation is needed to ascertain the currently unknown archaeological resource along much of the cable corridor. This advice is consistent with that given by the Council for other comparable linear schemes in Suffolk, for example Essex & Suffolk Water (Wixoe) pipeline (St Edmundsbury Borough Council application SE/07/2004) and the approaches being taken by both Anglian Water and National Grid for their major developments in the county. 23. With regard to the archaeological interests of the converter station, the Council is satisfied with the approach set out in Appendix 25.5 of the Environmental Statement. However, the Council would reiterate that both the geophysical survey of the site boundary and the trenched evaluation of the footprint of the converter station should be undertaken before consent is granted, to allow for in situ preservation of any important archaeological remains. The Council is concerned that there appears to have been little progress on this work and expects every effort to be made to secure access to the land for this purpose. 24. Further trenched evaluation will be required for areas requiring topsoil stripping (for example site compound and areas of landscaping), but this can be undertaken post-consent in accordance with Requirement 25. Any further archaeological investigation (for example excavation and/or monitoring) will be based on the results of the evaluation, and will be carried out before and/or during the groundworks. 25. As mentioned, the Council is generally satisfied with the adequacy of the Environmental Statement as it relates to Archaeology and Cultural Heritage, with two exceptions; • The assessment of the early medieval period (Chapter 25, section 25.5.2.2.3). The document states that the potential for early

5 Medieval settlement evidence is low, while the Council would consider that the potential for early medieval occupation along the corridor (especially in valleys) to be moderate to high and furthermore that any discoveries dating to this period would be of very high archaeological importance. The cable corridor crosses through the hinterland of Sutton Hoo and the associated palace site, both on the north side of, and overlooking, the River Deben, and crosses the hinterland of Ipswich, one of the earliest towns in the country. Southeast Suffolk is one of the key areas of England for the study of the early medieval period. Although the density of known early medieval sites might seem low compared to sites of other periods, the density is in fact high compared to other parts of the county and country. Moreover, early medieval settlements are notoriously difficult to identify without intensive fieldwork. • Field walking (Chapter 25, Appendix 26.5, section 1.4.1). The Environmental Statement would benefit from a plan which shows the fields that have previously been subjected to field walking and the extent of the route that is accessible for field walking. Field walking sampling techniques along the entire route should also be done systematically and of consistent methodology and should include systematic metal-detecting by experienced detectorists. 26. In summary, the mitigation proposed for the project as it relates to the cable corridor does not provide adequate protection for the historic environment as there is a significant residual risk that important archaeological resources will be destroyed. The Council would not agree a Written Statement of Investigation, as provided for under Requirement 25, in this form, unless it is amended to include systematic trial trenching for the entire cable corridor. East Anglia ONE Ltd is likely to incur significant cost and delay should it identify significant archaeological sites later in the development process. 27. Recommendation: The Council expects East Anglia ONE Ltd to conclude the archaeological field evaluation for the converter station prior to development consent and to provide more substantive mitigation proposals for the cable corridor in order to adequately safeguard the historic environment. Transport and Traffic 28. Impacts of construction traffic are a major concern of residents of those parishes directly affected by the onshore works, particularly with respect to the operation of the Construction Consolidation Sites. The two Primary Construction Consolidation Sites will form the main access to the construction site, main storage areas and house administration and welfare facilities. The secondary sites facilitate short term secure storage of plant and sufficient materials to support day to day construction activities 29. These consolidation sites will be the destination points for HGVs, from which point the vehicles will then access the cable corridor using a temporary haul road (see Figure 1, appended to the main report).

6 Additionally, they (like the HDD sites) will be lit on a 24 hour basis giving rise to additional concerns about residential amenity. 30. In terms of the scale of trips during construction, the applicant’s Environmental Statement sets out a worst case scenario as follows. However, as detailed below, the Council considers that further information is required to substantiate these figures, which are considered likely to be underestimates. • Landfall point (Bawdsey); 45 HGVs deliveries and 9 construction workers per day over a 21 week duration. • Cable corridor; 29 HGV deliveries per day per section (there are seven sections, focused around the seven consolidation sites) and 45 additional HGV deliveries per day for each of the 9 HDD sites. 79 personnel per 500m section plus 9 workers at each HDD site. All over a 44 week, though unlikely continuous, duration. • Converter station: 14 HGV deliveries and 100 construction workers per day of 46 week duration 31. The Environmental Statement identifies five locations which will experience a significant increase in traffic volumes (more than 10%); namely Ipswich Road, Grundisburgh; Top Street, Martlesham; Paper Mill Lane, Bramford; B1083 to Bawdsey and Ipswich Road, Waldringfield. It is noted that the impacts of this on severance, congestion, driver delay, risk of accidents, pedestrian delay and intimidation has not yet been assessed (Chapter 27, paragraphs 105-106). The Council considers that, while the threshold of 10% indicates a potential impact, there are circumstances where a lesser increase would still have significant impacts where there are known issues and these circumstances should not be ignored. It may be that more detailed work on junction capacity is needed in some cases to demonstrate that the scheme does not have unacceptable impacts. 32. The draft Development Consent Order provides for three roads to be stopped up temporarily, with specific arrangements to be agreed with the County Council, as local highway authority; Park Lane, Kirton; The Street, Newbourne; Ipswich Road, Waldringfield. Any further stopping up would be subject to the agreement of the County Council. 33. The Council is currently reviewing the detailed assumptions behind the analysis undertaken by East Anglia ONE Ltd and therefore the comments in this section should be regarded as preliminary with further detail to follow. Our initial observations include; • The Council should be provided with the review undertaken which is said to support the judgement that Bullen Lane in Bramford is suitable for construction traffic (Chapter 27, paragraph 74); • The assessment of traffic flows has been done with regard to Annual Average Daily Traffic Flows. As some of the roads affected are commuter routes, it is important that peak hour flows are also considered;

7 • Distinction not only needs to be made between average and peak traffic flows but also between HGV and other traffic (see Chapter 27, paragraph 115); • While the locations of traffic surveys are identified (Chapter 27, Figure 27.1), the subsequent figures (27.2 & 27.3) cover a different geographical area and therefore the results from some of the counters are not provided, for example those on the B1078 and the A12 near Wickham Market; • Judgements on sensitivity are provided without reference to existing conditions in some cases (Chapter 27, Table 27.10). Furthermore, the B1078 is omitted from this list; • Table 27.10 also provides no information with regard to Annual Average Daily Traffic flows for HGVs on the B1113; A1156, A12 between the A14 and the A1214; A1214 Kesgrave, B1438 Woodbridge and the A12 north of Woodbridge - therefore the impact of construction traffic at these locations is described as “n/a” and the sensitivity as “negligible”. This analysis is likely to underestimate the impacts; • The sensitivity of Kesgrave High School on the A1214 Kesgrave should also be recognised (paragraph 51). • No growth factors seem to have been applied from current traffic levels to determine the development period baseline; • More detail needs to be provided on phasing and the operation of the construction consolidation sites to understand the extent of development being undertaken at any one time and the consequential implications for HGV movements. Additionally, “deliveries” are described on a per week basis, then averaged to a daily figure – it is not clear how a daily average would be maintained – there are likely to be periods of more and lesser intensity and it must be the worst case that is assessed; • There is a general inconsistency in the document between the use of the term “movement” and “delivery”; if the figures presented are deliveries, then the return HGV movements appear to have been excluded; • More detail needs to be provided on the construction works associated with the preparation and decommissioning of the haul road and the HDD and construction consolidation sites. It is not clear if HGV movements associated with these works are included; • The assumed distribution of construction workers and materials is said to be based on experience of similar projects. Further detail is needed on this as currently Figure 27.8 (Chapter 27) shows zero construction workers approaching the site from the A14 north of Claydon; • More information needs to provided on worker shift patterns;

8 • “The Old Fisons Site” is identified under the list of projects that could contribute to a cumulative impact (Chapter 27, paragraph 127). An application (reference 2700/12) has now been lodged for this site with Mid Suffolk District Council, so more detail on the potential timing and numbers of vehicle movements, both during construction and operation is available. Furthermore, should the application receive planning consent, East Anglia ONE Ltd may need to review its comments concerning, for example, severance (paragraph 113), where Paper Mill Lane is described as “pedestrian free”. Any new development (176 dwellings are proposed) is likely to lead to increased footfall on Paper Mill Lane. In any case, it may be more appropriate to describe Paper Mill Lane, Bramford and Top Street, Woodbridge as having no pavement than as being “pedestrian free”. • The list of developments detailed for the cumulative assessment should also include the Ipswich Northern Fringe and development at Adastral Park, Martlesham. Both developments are identified in the respective Local Planning Authorities’ plans. That there is insufficient data available in some cases does not mean those developments should be excluded from further analysis, especially where their location indicates a cumulative impact is likely to occur. Impacts on HGV movements from Sizewell may be obtained from the Stage 1 consultation material, though the Council considers those to be an underestimate. • With reference to the Travel Plan, only a single firm commitment (the use of a mini bus) is proposed. All the other proposals are vague, yet seem to have been factored in as mitigation in determining residual impacts, so more information is required. The number of minibuses also needs to be added to the construction trips. Further discussions will be needed with the Council concerning the designated pick up points for workers, as use of the existing park and rides may not be acceptable (paragraph 138). 34. The proposed mitigation for the anticipated transport impacts is through the agreement, post-consent, of a number of documents with the local planning authority. Specifically; • An Access Management Scheme (Requirement 21 of the Development Consent Order). This is to ensure access to the construction sites are safe. Notwithstanding the comments below, the drafting of this condition is acceptable. • A Code of Construction Practice, including Traffic Management Plan (Requirement 27). This is to control routeing of traffic. The Code of Construction Practice should be agreed by the local planning authority in consultation with the local highway authority. Notwithstanding the comments below, the drafting of this condition is otherwise acceptable. • A Travel Plan (Requirement 32). The Travel Plan should be agreed with the local planning authority in consultation with the local

9 highway authority. Notwithstanding the comments below, the drafting of this condition is otherwise acceptable. 35. It is also proposed to undertake a “dilapidation survey” before and after project construction to identify any necessary remediation to the highway. This is supported in principle and should be committed to in the Code of Construction Practice. 36. The Council has not been provided with an Access Management Scheme, Traffic Management Plan or Travel Plan so cannot confirm that the proposed measures within them, individually or collectively, will be satisfactory. 37. Furthermore, traffic management and working arrangements are a key issue for local communities affected by the project. The Council is concerned that if these documents do not materialise until post-consent, residents will have insufficient opportunity to raise their specific concerns on the proposed mitigation, for example relating to routeing, access arrangements, and working hours. 38. Consequently, the Council has concerns about progressing to the Preliminary Hearing without these documents being available in draft form. They form a critical part of the project’s mitigation strategy and the Council or local communities may wish to bring specific issues to the Examining Authority’s attention at the Preliminary Meeting to inform the examination of the application. East Anglia ONE Ltd should provide them at the earliest opportunity to enable constructive discussions to progress in advance of the examination. 39. Nevertheless, in the absence of the documents, the Council highlights below some key issues at the current time; Access Management Scheme 40. It is noted that minor improvements to accommodate abnormal loads and access to sites are to be identified in the Access Management Scheme in due course. In all cases, though, any additional land required for road improvements (outside the highway boundary) will need to be included in the Development Consent Order. Visibility at all access points to the consolidation sites must be satisfactorily addressed. 41. Consideration should also be given to improvements to footways to ensure pedestrian safety, particularly where there are significant increases in HGV traffic. In all cases, the Council reserves the right to seek planning obligations to secure offsite works which are needed to mitigate the transport impacts of the development. The extent to which this might be necessary cannot be confirmed until the Council receives the aforementioned clarifications on the transport assessment to date. 42. Unless otherwise agreed with the County Council, any road improvements should be removed at the conclusion of the onshore construction works. The Council would wish to assess, on a case by case basis, and having regard to the views of the local community, the need for any of the highways improvements necessitated by East Anglia ONE to be retained. The local highway authority should therefore be

10 consulted under Requirement 34, relating to the provisions for restoration. 43. The Council highlights the following for inclusion; • Layout of the junction of B1113 and Bullen Road in Bramford will need to be improved; • In order to access Site D (Playford) construction of passing places may be needed on the C323 and C329; • Access to Site F (Newbourne) is via C roads which may necessitate the construction of passing places; • Improvements to the junction between the U road and C road in Kirton may be needed in order to access Site G (Kirton); • Improvements may be needed at the junction of the B road south of Bawdsey with the track leading to the beach. Code of Construction Practice 44. The Traffic Management Plan should accommodate the points set out in paragraph 46 below. It should also set out how any road closures will be managed and the anticipated diversionary routes. Wherever possible, the Council wishes to see partial openings (i.e. single lane closures) and disruption concentrated on off peak times. 45. At this point, the Council has particular concerns over any disruption to Paper Mill Lane and Somersham Road in the parishes of Bramford and Little Blakenham due the options available for diversions and therefore would resist closures to either of these roads. If Paper Mill Lane needed to be closed, it would force traffic to access the businesses along Paper Mill Lane from the south. This is an unacceptable route for large vehicles due to the presence of low bridges and residential areas. If Somersham Road needed to be closed, the diversion route would be via Pound Lane, which is unsuitable for increased traffic flow due to its width and the difficulties at the junction with the B1113. 46. The Traffic Management Plan should reflect the following routeing requirements; • HGV construction traffic should follow the Suffolk Lorry Network as far as possible, unless otherwise advised by the Council. • No HGV construction traffic should be routed through Sproughton • No HGV construction traffic should arrive from the south of Paper Mill Lane • No HGV construction traffic should be routed through Coddenham. Access should be via the A1156, A1214 and B1077 to Site C (Witnesham). • The B1078/B1079/U3041 around Clopton have directional weight limits which need to be heeded when accessing Site D (Playford).

11 • The ‘alternative lorry route’ via Lower Falkenham (Volume 6, Chapter 27, Figure 27.4) is likely to be unacceptable. Travel Plan 47. The Traffic and Transport Chapter of the Environmental Statement states that it does not cover movements associated with the offshore construction works because any movements related to that would be considered to be part of the ‘normal’ operations of the relevant port (Chapter 27, paragraph 5). 48. It was highlighted at the recent examination of the Galloper Windfarm Project that parking by construction workers who were employed by the earlier Greater Gabbard Offshore Windfarm Project had caused problems in the vicinity of Harwich Port and measures to deal with this should be considered by the Galloper Windfarm Project to prevent the problem recurring. 49. The Examining Authority for the Galloper Windfarm Project agreed this was a reasonable approach and the applicant subsequently included in the Code of Construction Practice a public commitment to work with the relevant planning authority to develop a car parking strategy where appropriate. Paragraph 5.13.11 of EN-1 supports the attachment of requirements to a consent “to avoid ‘overspill’ parking on public roads”. 50. The Council therefore believes that the Travel Plan for East Anglia ONE should similarly include measures to encourage those individuals working on the East Anglia ONE project, either at the ports or offshore, to travel more sustainably to alleviate any similar issues arising in the future in Suffolk or elsewhere. 51. Recommendation: The Council has pressing concerns over the adequacy of the transport assessment and in particular the estimation of HGV numbers. The Council should be provided with draft versions of the Access Management Scheme, Traffic Management Plan and Travel Plan as a matter of urgency. The Council cannot confirm that adequate mitigation for the transport impacts of this scheme has been provided at this time and considers that planning obligations may be required for this purpose. Noise, Vibration & Air Quality 52. Section 5.11 of EN-1 requires the identification of noise sensitive premises and noise sensitive areas that may be affected. Chapter 26 of the Environmental Statement (Onshore Noise and Vibration) does not identify these locations with respect to the construction traffic routes. 53. Furthermore, there is inconsistency between the Noise, Vibration and Traffic assessment reports as to exactly which routes are likely to be affected. Schools and other noise sensitive buildings together with any ecological receptors are not referenced in Chapter 26, although it is noted that noise is considered in the Onshore Ecology and Ornithology Chapter 24.

12 54. Whilst it is understood that the nature and extent of the assessment should be proportionate to the likely noise impact, the assessment does not provide any quantification of likely numbers of properties affected on even those routes where the impacts are expected to be greatest. 55. Table 26-5 of Chapter 26 describes the magnitude of impact in the short term for road traffic noise levels, but the description of magnitude does not transfer across to Table 26-13 where Significance of Impact is determined. It is therefore not possible to establish which of the significance criteria would apply when determining outcomes. Clarification of the headings in Table 26-20 would assist as the third heading under AAWT 18 Hour Traffic Flows appears to be the same as for the middle column. It is also not clear why for some routes there are zero entries for HGV numbers in both the baseline and construction scenarios. 56. The basic methodology (Department for Transport's "Calculation of Road Traffic Noise") used for predicting noise levels from changes in traffic and HGV flows is the accepted methodology and does appear to have been applied correctly. 57. In terms of using the Design Manual for Roads & Bridges (DMRB) descriptors as a means of identification of magnitude of impact, this methodology is normally used for overall increases in traffic flow. Whilst it is appreciated that the proportional increase in HGV numbers is included in the predicted noise level, no account has been taken of the potential for changes in perception where HGV numbers increase significantly when compared with a generally equal increase in traffic across all vehicle types. 58. Until further details are confirmed relating to traffic volumes and routes it is not possible to confirm whether noise mitigation would be required. It is likely that the most effective means of mitigation would be to restrict hours during which HGV movements can take place to the less sensitive times of the 24 hour period. This to ensure that disturbance is not caused to residents adjacent to the routes. It is not expected that noise levels and duration of activity would be sufficient to require noise insulation to be offered to dwellings or any other noise sensitive properties adjacent to any of the routes. Vibration 59. The vibration assessment includes a list of potentially sensitive buildings along affected routes. As discussed previously, it is not clear why the routes selected differ from those included in the Noise Assessment. 60. The potential for damage to buildings and also for a nuisance to be caused to occupants adjacent to the routes has been identified and it is concluded that the potential for any damage to be caused would be increased depending on carriageway surface condition. Under normal smooth surface running, effects would not be expected. It is therefore important that, to avoid the potential for damage to sensitive property and for unnecessary disturbance, the routes used for HGV traffic should be maintained in good order throughout the construction period.

13 61. The Council expects that a pre-construction survey of all of the routes is carried out and that any significant irregularities are identified and treated and that the carriageway surfaces are maintained in good order throughout the construction period (see also paragraph 35). Air Quality 62. Section 5.2 of the EN-1 places a number of requirements on the applicant, not all of which have been met. 63. The Air Quality Assessment has correctly identified the main potential emission sources. It has also included reference to the Air Quality Management Areas (AQMA) in the vicinity of both the construction activity areas and also the proposed traffic routes. One AQMA has been identified at the Norwich Road/Valley Road junction in Ipswich through which it is expected that HGV traffic would travel. 64. There is however no assessment of the likely impact of the additional HGV traffic on pollution levels in this AQMA. Whilst it would not necessarily be expected that an air quality assessment would be provided for all of the potential construction routes, to accord with the National Policy Statement, EPUK Guidance and also Suffolk's Supplementary Guidance, it would appear that an assessment of impact at this location should have been provided. 65. Whilst it is acknowledged that effects would be temporary - the minimum period being 44 weeks for construction working, but possibly spread over a two year period, there may be potential effects on an AQMA and it might be appropriate to consider alternative routeings away from this location. Outline Code of Construction Practice 66. Information in this document is general in nature. Whilst sections on Noise and Vibration and also Air Quality have been included, there is no detailed information. Many of the good practice pollution control measures can be specified as Requirements of Consent, to include hours of working and it is not unusual for greater detail to not be available at this stage. A number of best practice measures have been included and these can be used as a foundation for further discussion. 67. Recommendation: That the deficiencies identified herein relating to the assessment of noise, vibration and air quality impacts, in particular relating to the consistency of assumptions across these areas, are addressed by the applicant as soon as possible in consultation with the Council. Public Rights of Way 68. Forty-four public rights of way are crossed by the planned works, though due to the proposed use of HDD a number are avoided by tunnelling. Temporary closures would be put in place for 39 public rights of way, with diversions provided for all but four of these, namely at the landfall point near Bawdsey, near Newbourne and two adjacent to the Converter Station at Bramford. Ten cycle routes are also crossed, but none would

14 require closure as access for cyclists will be maintained as part of traffic management. 69. While the temporary closure notices sought will cover a six month period, actual closures are only anticipated to last for approximately two weeks at each location. 70. Five of the public rights of way affected are ‘promoted footpaths’; The Suffolk Coastal Path, The Stour and Orwell Walk, The Fynn Valley Walk, the Gipping Valley River Path and Martlesham Circular Walk. The Suffolk Coastal Path is however currently impassable at the point affected (landfall at Bawdsey) due to coastal erosion. 71. The draft Development Consent Order (Part 3, paragraph 9 (2)) states that diversionary routes should be agreed with the local planning authority. As the local highway authority, diversionary routes should rather be agreed with the County Council. The Council has reviewed the suggested diversions and is broadly content with the proposals. While, in four cases, no diversions are set out, and this is not ideal, there do not appear to be any viable alternative routes. The Council would emphasise the need to minimise the duration of any closures, particularly related to the promoted footpaths. EN-1 (paragraph 5.10.20) recognises the importance of maintaining connectivity in green infrastructure during construction and the Council expects the applicant to adopt this principle. 72. The Environmental Statement recognises the need to carry out a pre- construction survey (Chapter 23, paragraph 126). The details of this should be set out in the Code of Construction Practice. It needs to cover the public rights of way crossed by the cable corridor, those on the diversionary routes and those used for construction access to the cable corridor. All the surveyed rights of way will need to be restored to their pre-construction condition. It is suggested that the Agricultural Liaison Officer (Chapter 23, paragraph 151) could also be the point of contact for the restoration of the rights of way. 73. It is important that closures are properly managed, and supported with an effective communications strategy, committed to in the Code of Construction Practice. Parish, district and county councillors should be directly informed. As promoted footpaths are being closed, this should be widely publicised. Any signage needed should be appropriately placed, but should not become visually intrusive and should be removed in a timely fashion. The use of interpretation boards in conjunction the signage should be considered to inform the public about the project. 74. It is the convention to identify public rights of way by parish and then by path number, followed by grid reference. The draft Development Consent Order currently does not adopt this protocol, rather referring to the Council’s own numbering system which is not recognisable to other parties. The Council recommends that this is corrected. 75. Recommendation: The County Council should be identified as the relevant authority to agree matters related to the public rights of way network including, but not limited to, diversionary routes,

15 advertisement of temporary closures and provisions for surveying and restoration. Environment 76. The draft Development Consent Order provides for a single converter station of up to 130m in length, 85m in width and 25m in height. The converter station will result in the direct loss of 2.85 hectares of agricultural land, including hedgerows. Its size is such that it cannot be wholly screened and there will be significant residual impacts on visual amenity. 77. At 37km long and with a working width of 55m, the cable corridor involves disturbance to a significant area and will have direct and indirect impacts on the environment. It crosses statutory and non-statutory sites; one third of the cable corridor passes through the Suffolk Coast and Heaths AONB. The AONB includes a number of unique and vulnerable lowland landscapes; habitats of interest include ancient open heathland, saltmarsh, mudflats, wetlands, shingle beaches and woodland. The Deben Estuary (including Martlesham and Kirton creeks), which is within the AONB, is a designated Special Protection Area, Ramsar site and Site of Special Scientific Interest (SSSI) for its populations of over- wintering waders and wildfowl and also for its diverse saltmarsh communities. Bawdsey Cliffs SSSI, noted for its geological interest, is also directly affected. The cable corridor crosses four non-statutory sites, namely Millers Wood Ancient and Semi-Natural Woodland, the River Gipping, Mill River and Suffolk Shingle Beaches County Wildlife Sites. 78. In the case of the Deben Estuary, the associated creeks and the County Wildlife Sites, it is proposed to use HDD, i.e. to tunnel under them. Temporary access may be required to Suffolk Shingle Beaches County Wildlife Site at Bawdsey, depending on the approach taken to HDD (see paragraph 118). This site is designated for its vegetated shingle and associated invertebrates; although the main areas of vegetated shingle are proposed to be avoided, there will be impacts if this area is used for temporary working. The practicalities of re-instating the maritime cliff and slope habitat may have been underestimated in the Environmental Statement given its unconsolidated nature, and therefore access to the beach should be avoided. Landscape, visual and ecological impacts 79. The Council supports the principles that have been used to inform the choice and location of the onshore infrastructure for this project, in particular that the cabling will be entirely underground. A pylon-led scheme would have been entirely unacceptable in the Council’s view. 80. The Council also generally supports the approach taken to routeing, specifically that efforts have been made to avoid built up areas and designated sites as far as possible, with permanent landscape impacts being reduced in some cases by using HDD (but see paragraph 93) as well as avoiding large areas of woodland and reducing the need to create gaps in hedgerows.

16 81. Similarly, the Council agrees that the choice of the location of the converter station compound being sited as near as possible to the existing Bramford electricity substation, and positioned to take advantage of the screening offered by the adjacent woodland, is appropriate. 82. However, despite the ‘embedded mitigation’ within the project’s design, the development still has significant environmental impacts which need to be appropriately mitigated and offset/compensated for, as necessary. 83. The National Policy Statements EN-1 and EN-5 are quite clear in this respect and furthermore that opportunities not only to protect, but also to enhance, the environment should be captured (see for example EN-1 paragraphs 5.3.4 and 5.3.18), both on and offsite. While the submitted Planning Statement notes this provision in the Mid Suffolk and Suffolk Coastal Local Plans, it omits reference to this policy in the National Policy Statements. It is also worth noting that enhancement is a core principle of the National Planning Policy Framework (see for example paragraph 109 therein). 84. Additionally, while EN-5 is primarily concerned with above-ground electricity infrastructure (as underground cables are not, by themselves, a Nationally Significant Infrastructure Project), it is the Council’s view that the principles set out in that document should also apply to the East Anglia ONE application. In particular, the Council draws attention to paragraph 2.8.11 and the reference to the ability of the Planning Inspectorate to require off-site tree and hedgerow planting as a form of mitigation. The Council considers a Section 106 agreement would be the appropriate mechanism to secure this. 85. Similarly, the Council notes the reference in paragraph 5.3.15 of EN-1 to also using planning obligations to secure maximum benefits for biodiversity “in and around development”. Landscaping 86. Requirements 19 and 20 relate to the provision, implementation and maintenance of landscaping. The Council is broadly content with the drafting of these conditions, subject to the comments below. There is however a drafting error in Requirement 20, which erroneously points to Requirement 21, rather than to Requirement 19. 87. In line with Requirement 19, draft principles regarding the implementation of a planting scheme and the avoidance of tree and hedgerow loss are set out in an Outline Landscape Strategy. However, there are matters that are not adequately dealt with currently, even in principle; • Firstly, given the identified significant residual visual impacts (Table 29.16 and Table 29.17, Chapter 29) that will occur as a result of the proposed converter station, a five year period of aftercare for the planting in this area is not sufficient. The Council believes that a time period of 10 years would be appropriate to ensure that the planting scheme is effectively established and maintained. This is in line with recent appeal decisions under the Town and Country Planning Act

17 1990 (see APP/W3520/A/10/2128648 for example). Requirement 20 should be altered accordingly. • Secondly, the principle that a Landscape Clerk Of Works is appointed to supervise tree protection and liaise with local planning authority arborists is required. This will ensure contractors can be adequately supervised and trees and hedges can be effectively protected from damage to the satisfaction of the local planning authorities in accordance with BS5837:2012 or its updates. • Thirdly, offsite planting is required to mitigate the residual impact of the converter station to make it acceptable in planning terms and this is not reflected in the Outline Landscape Strategy. The Council also considers it is necessary to extend offsite planting to the cable corridor for the reasons explained in paragraphs 89 – 92 below. 88. In the case of the converter station, the Council has previously provided a map to East Anglia ONE Ltd indicating likely areas of search for offsite planting. These locations have been suggested based on the ability of planting to reduce the landscape and visual impacts on public viewpoints that is, from roads and rights of way. Views of the development will be available particularly from the west of the site, in the Burstall Hill area, and from rights of way to the east of The Channel (Flowton). Other public viewpoints that need to be considered include Bullen Lane and Tye Lane. Hedgerow and tree loss in the cable corridor 89. Clause 32 of the draft Development Consent Order provides for the removal of the hedgerows identified in Schedule J. The Environmental Statement notes that the number of ‘non-important’ hedgerows crosses is 74 and the number of ‘important’ hedgerows crosses is 14 (having regard to the wildlife and landscape criteria in the Hedgerows Regulations 1997). Each crossing will be approximately 35m in length. In all, therefore, nearly 3km of hedgerow will be temporarily removed, of which around 15% is deemed important. The Environmental Statement records that six hedge crossings along the route have been identified as sensitive to bats. Due to the rarity of this species, the Council considers that all seven hedgerows where Barbastelle activity has been recorded should be identified as important. 90. While it is recognised that hedgerows will be replaced (though important hedgerows, which by definition must be at least 30 years old, cannot be replaced in the short term (this is alluded to in Chapter 24, paragraph 207)), there would be a permanent loss of hedgerow trees and other important, including ‘veteran’, (such as oak and ash in the Newbourne and Martesham areas) trees. 91. Paragraphs 263 – 269 of Chapter 29 describe a number of locations along the cable route where tree loss will not be re-established, leading to residual impacts after 15 years, and ‘prominent, high magnitude changes’ in the landscape. Paragraph 286, summarising the preceding paragraphs 263-269, confirms that “in sections 3-6 and 9 [of the cable route], for most receptors the losses cannot be mitigated and so

18 localised residual visual impacts would remain as major significant”. The Council believes that such losses should also be considered a permanent (not temporary, as Chapter 29 suggests (paragraph 120)) impact on landscape character. 92. Hedgerows also provide important ecological functions and some species of bats use these linear landscape features for foraging and commuting, favouring mature trees to roost in. Loss of trees which have the potential to support roosting bats (45 have been identified in the Environmental Statement (Chapter 24, paragraph 236)) reduces the potential “roost stock” of the area. Paragraph 5.3.14 of EN-1 recognises in particular the biodiversity value of ‘veteran’ trees and directs that their loss should be avoided. Any losses should be compensated for (paragraph 5.3.7). 93. Hedgerows are Priority Habitats in both the UK Biodiversity Action Plan and the Suffolk Local Biodiversity Action Plan and are an integral part of landscape character. The Council notes that HDD is not being proposed widely enough to minimise impacts on hedgerow loss or important tree copses (such as those listed in Chapter 29, paragraph 134); the proposed mitigation is rather to narrow the working width of the open trenching to 35m from the typical working width of 55m. 94. The Council considers that, as a minimum, East Anglia ONE Ltd should consider further HDD under those hedgerows and tree copses identified as important (provided there are no overriding environmental reasons not to do so). In the event that open-trenching remains the applicant’s preference, it should explore measures beyond just narrowing the working width of the corridor in order to mitigate the impact of these crossings. For example, East Anglia ONE Ltd should consider innovative practices such as coppicing, extracting and temporarily storing hedgerows for replanting at the restoration stage. Converter station 95. Section 4.5 of EN-1 sets out how good design should be embedded in the development of energy infrastructure. The document states “energy projects should produce sustainable infrastructure sensitive to place” (paragraph 4.5.1) and that the Planning Inspectorate should be satisfied that such developments “are as attractive…as they can be” (paragraph 4.5.3). The Council acknowledges that there are limitations to the extent a converter station can be manipulated in the interests of good design; however it believes that further consideration should be given to how the impact of the building can be further mitigated, in particular through the lowering of bed levels. 96. Agreement of the detailed design of the converter station with the local planning authority is provided for by Requirement 18. The Environmental Statement does suggest that the converter station is to be constructed on “lowered ground levels” (Chapter 29, Table 29.2), with the draft Development Consent Order, Part 3, clause 18(5) stating that the floor level shall not exceed 54m AOD.

19 97. It appears to the Council that, having analysed the localised topography of the site, that parts of it are already at 54m AOD, thus the purported embedded mitigation appears overstated. It is not explained why the converter station could not be lowered further. 98. It is acknowledged that parts of the site are 56m AOD, and of course there would be environmental impacts associated with any (offsite) movement of soils, but the Council believes that due to the identified significant residual visual impact of the development, consideration of further reducing the bed level is justified, particularly to the extent that excavated material could be reused on site for mounding or other such purposes. Ecology 99. The requirement to use directional lighting and cowls to minimise light spillage around the converter station will need to be year-round not limited to the autumn period (as stated in the Ecological Management Plan, page 13). The Council believes additional surveys are essential to assess the impacts of the converter station, particularly lighting, on bats using the nearby nationally important hibernation site at Little Blakenham Pit SSSI. 100. The proposals concerning the translocation of reptiles are inadequate (Chapter 24, paragraphs 53 and 268-269). Detail should be provided on the proposed receptor sites so that preparation works to secure and manage them can be instigated. It should not be assumed that receptor sites can be readily identified and it is also important to consider the need to compensate for habitat loss. 101. The Ecological Management Plan (Requirement 26) provides a mechanism, within the Code of Construction Practice, to implement the embedded mitigation measures identified. However, it will be essential that any requirements identified by the Ecological Clerk of Works are implemented in full by the contractor/workforce. For example, paragraph 15 of the Plan states “where possible removal of vegetation to avoid the bird breeding season” but fails to include any reference to ecological actions identified to avoid wildlife crime, should the alternative option be required. The Plan should also include information for the operational phase of the converter station, for example potential fencing or licensing requirements for badgers. Restoration 102. Requirement 34 requires land temporarily used for construction to be reinstated within 12 months of the completion of the connection works. Generally, the Council would expect land to be reinstated as soon as practicably possible, though please see comments at paragraph 42. 103. For example, when it is clear that a given construction consolidation site is no longer necessary it should be restored at that point, rather than waiting until the completion of the connection works. Work on the converter station, for example, may be the last piece of onshore infrastructure completed, yet there is no justification to delay the

20 restoration of the construction consolidation areas along the cable corridor in line with this timetable. 104. The Requirement should be reworded to reflect the above. 105. Paragraph 5.10.8 of EN-1 directs that applicants should seek to minimise impacts on the best and most versatile agricultural land (grades 1, 2, 3a). Figure 23.1 of the Environmental Statement shows the distribution of this land in the study area (though not distinguishing between 3a and 3b). 106. The Council therefore expects impacts on land sterilisation to be minimised in the cable corridor through consideration of the depth of cabling and the number and location of jointing bays and associated infrastructure. Clarity should be provided on the implications of the “jointing bays” (see paragraphs 111 - 115 below) for agricultural land. Summary - Landscape, visual and ecological impacts 107. The construction of the converter station and installation of cabling and ducts will, notwithstanding the mitigation proposed, have residual impacts on the environment. In line with the National Policy Statements, these impacts need to be offset in such a way that enhances the environment in order to make the development acceptable in planning terms. 108. The Council has had regard to the tests that apply to the use of Section 106 agreements as set out in paragraph 4.1.8 of EN-1. It considers that East Anglia ONE Ltd should provide, by way of such an agreement, monies to deliver offsite planting in locations to be agreed between the relevant local authorities, landowners and local communities to mitigate and offset the residual impacts of the converter station and cable route on visual amenity, landscape character and biodiversity. 109. The Council notes East Anglia ONE Ltd’s commitment to develop further mitigation measures (Environmental Statement, Chapter 29, paragraph 296), and would advise that the principles above reflect the Council’s expectations. This approach has been adopted on other major infrastructure projects in Suffolk, such as Sizewell B, the expansion of Felixstowe Docks and, most recently, Galloper Offshore Windfarm. 110. Recommendation: The Council considers that the residual impacts of the development on visual amenity, landscape character and biodiversity warrant a comprehensive Section 106 agreement to make the development acceptable in planning terms. Furthermore, the Council requires more detail on the proposed ecological mitigation to confirm its robustness, further consideration of bed levels at the converter station and assurances that the landscape restoration will commence as soon as possible. Transition Pits and Jointing bays 111. The Environmental Statement, Development Consent Order and Cable Statement (document 8.1) appear to be inconsistent in the usage of these terms.

21 112. Paragraph 7.1 of the Cable Statement refers to “jointing bays” being used where the export cable joins the onshore cable. The subsequent paragraph refers both to “transition bays” and “jointing bays” apparently interchangeably. The significance of this inconsistency is that there is ostensibly a difference between the two as they appear to be differently sized. 113. The draft Development Consent Order does not appear to define either in the Interpretations section though makes reference to “transition cable jointing bays” in Work No. 4 (Schedule A Part 1), somewhat of an amalgamation of the two aforementioned terms. Reference to “jointing bays” appears in the list below Work No. 41 in the same Schedule). 114. The Cable Statement describes “jointing pits” (a further variant of the term) as “a shallow concrete-lined structure with access from the surface by a manhole cover”. The table on page 26 of Chapter 29 of the Environmental Statement identifies that on reinstatement three kiosks per cable joint at landfall are assumed. There is no description of a ‘kiosk’, so it is not possible to comment on the potential visual, landscape and seascape impact of such a large number of structures on the coastline. 115. The Council requests some clarity on this matter, specifically; proper definitions of the terms used and rationalisation of them if possible; a visual depiction of both transition pit and jointing bay structures and the associated kiosks, and confirmation of the extent of development above ground. The design requirements should also be clarified, for example related to flood protection. Use of HDD 116. The Environmental Statement (Chapter 24, Table 24.1, page 14) referring to the Deben Estuary and Martlesham Creek, notes that “the development consent order does not seek permission for open cut methods of crossing these watercourses”. It is understood that for all the proposed HDD locations, the draft Development Consent Order does not provide for open cut trenching. The Council does however note that in the table on page 22 of Chapter 29 of the Environmental Statement, part of the embedded mitigation at landfall refers to stockpiling of trenched material. 117. It is not clear, therefore, how the project may proceed (other than perhaps through an application under the Town and Country Planning Act 1990) if unforeseen technical or environmental issues emerge with the use of HDD. The Council suggests that the Environmental Statement might benefit from considering this scenario – it does not appear to have considered alternative (i.e. worst case) scenarios to HDD. The Council notes, for instance, that open trenching was “removed from consideration” at the landfall point at Bawdsey to minimise the direct impacts on the geological SSSI (Chapter 29, page 25). 118. These cliffs are characterised by unconsolidated material and therefore are considered unstable. Use of HDD could have implications for the stability of the cliffs which may only become apparent at the time of

22 construction. The Environmental Statement (Chapter 24, paragraph 328) states that no stabilisation of the landfall would be undertaken on account of the potential impacts on invertebrate potential. However, should HDD or associated movements on to the beach in the case of the “Short HDD option” (Chapter 4, paragraphs 195-198) contribute to instability, then measures would need to be put in place to mitigate this and it is not clear if these have been assessed. In the absence of further detail on the relative merits of either option, the Council’s preference is rather for the “Long HDD Option” in which case access to the beach can be avoided. 119. Similarly, with respect to the HDD under the Deben estuary, this is understood to be a technically challenging operation, which could be unsuccessful. Any open cut trenching would have significant impacts on the adjacent saltmarsh and associated species assemblages either side of, and within, the estuary, which have also not been assessed fully.

23 Drainage 120. The drainage works for the converter station should employ a sustainable drainage systems approach. 121. The Council notes the intention to seek consents under the Land Drainage Act after the approval of the Development Consent Order. East Anglia One Ltd should also be aware of their obligations under the Water Framework Directive; where ‘ordinary watercourses’ (for example the River Fynn or River Lark) are proposed to be crossed by open trenching, depending on the ecological and chemical quality of the water, measures to enhance these standards may be required. Advice should be sought from the Environment Agency in the first instance.

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