Applicant Comments on Relevant Representations
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East Anglia THREE Applicant Comments on Relevant Representations Document Reference – Deadline 2/RR comments/Applicant Author – Royal HaskoningDHV East Anglia THREE Limited Date – July 2015 Revision History – Revision A www.scottishpowerrenewables.com East Anglia THREE Offshore Windfarm ................................................................................................. July,2016 Table of contents 1 Technical Chapter Example Error! Bookmark not defined. 1.1 Introduction 3 1.2 Anglian water 3 1.3 Babergh and Mid Suffolk District Council 3 1.4 Civil Aviation Authority (CAA) 6 1.5 CRPMEM Nord - Pas de Calais / Picardie 6 1.6 Defence infrastructure Organisations (MoD) 6 1.7 DONG Energy 7 1.8 East Cambridgeshire District Council 7 1.9 ENI 7 1.10 Environment Agency 9 1.11 Forewind Limited 13 1.12 Galloper Wind Farm Ltd. 13 1.13 Harwich Fishermen’s Association 15 1.14 Historic England 19 1.15 Little Bealings Parish Council 21 1.16 Little Blakenham Parish Council 22 1.17 Marine Scotland 22 1.18 MCA 22 1.19 MMO 24 1.20 National Grid 31 1.21 Natural England 33 1.22 Network Rail 67 1.23 NFFO 68 1.24 Norfolk County Council 70 1.25 Rederscentrale 72 1.26 Rijkswaterstaat 72 1.27 Royal Mail 74 1.28 RSPB 76 1.29 RYA 78 1.30 SCC 78 1.31 SCDC and WDC 125 1.32 Smart Wind 136 1.33 Suffolk Preservation Society 137 1.34 SWT 140 1.35 The Crown Estate 143 1.36 Trinity House 143 1.37 Transition Ipswich Energy Group 143 1.38 The Wildlife Trusts 143 1.39 Vattenfall Wind Power 145 1.40 VisNed 145 1.41 WDC 146 Applicant comments on relevant representations Page 2 East Anglia THREE Offshore Windfarm ................................................................................................. July,2016 1 Comments on Relevant Representations 1.1 Introduction 1. Following closure of East Anglia THREE Ltd statutory consultation period under section 56 of the Planning Act 2008, the Applicant has taken the opportunity to review each of the Relevant Representations received by the Planning Inspectorate and has subsequently responded by letter to each of those individual parties. Details of EATL responses to each of those representations are set out within this document. 1.2 Anglian water 2. EATL note that Anglian Water Services have registered as an interested party and would be grateful if you could confirm that you are the relevant member of the Anglian Water Services team to communicate with in relation to the above application and if not could provide details of the relevant contact. 3. EATL note your requirement for the East Anglia THREE development consent order (DCO) to contain the same protection measures as stipulated in the DCO for the East Anglia ONE project. EATL confirm that the East Anglia THREE draft DCO (submitted as document 3.1 of the DCO application) contains the same protective measures as were included in the East Anglia ONE DCO. EATL will continue to discuss the protective provisions with Anglian Water Services. 1.3 Babergh and Mid Suffolk District Council Relevant Representation Comment EATLs Response In general the District Councils are supportive of EATL welcomes the council’s continued support the project, recognising its importance in relation for the project. to the diversification of UK energy supplies and Chapter 28 Socio-economics, Tourism and potential contribution to the national and local Recreation of the East Anglia THREE economy. The economic benefits in terms of environmental statement (ES) (document investment and job creation are welcomed reference 6.1.28) identifies a high concentration of however it should be noted that further pressure construction workers and an extensive range of could be placed upon the labour market which relevant training and education courses in the may not have the requisite skills. This should be region. EATL believe that due to the following mitigated at an early stage. reasons there is likely to be a sufficient level of skilled labour to service the Project: East Anglia ONE Skills Strategy; The likely availability of East Anglia Applicant comments on relevant representations Page 3 East Anglia THREE Offshore Windfarm ................................................................................................. July,2016 Relevant Representation Comment EATLs Response One workers post completion of that project; The potential availability of oil and gas workers given the reduction in offshore activity related to the predicted depressed price of oil over the short to medium term; and The potential procurement of some specialist offshore construction skills from outside the area. While the project will use cabling ducts that are to EATL welcome the support of the councils to date be provided in association with East Anglia ONE, with regard to the use of ducts. EATL has the key issue of local concern relates to the committed to minimising impacts wherever subsequent implementation of the project. It could possible and the use of ducts will greatly either be constructed as a single or two phase contribute towards this goal. development which may or may not directly follow Since the submission of the East Anglia THREE the construction of East Anglia ONE. In the application further design work on East Anglia circumstances it could lead to a prolonged period ONE has been undertaken. As a result of this, it of disruption and on-going disturbance to local will be now only be necessary to install East residents and businesses. The District Councils Anglia THREE cables in a single cable laying are however satisfied that appropriate operation. Therefore, there will be no phasing of consideration has been given to the possible construction along the export cable route (offshore noise, vibration, and air quality impacts that might and onshore), although the option to phase arise during the construction and operational construction of the wind farm and the onshore phases of the project. substation will be retained. In principle, the intention to re-use temporary haul To the extent that temporary infrastructure may be roads and construction compounds associated retained between the East Anglia ONE and East with the implementation of East Anglia ONE is Anglia THREE projects, this will be dealt with supported, however this should not be at the through discharge of Requirements contained in expense of securing the long-term restoration of the East Anglia ONE DCO and does not therefore the land required for the cabling ducts. The gap in form part of the East Anglia THREE application. implementation between the projects, and potentially within the East Anglia THREE project itself, will need careful management. At the moment this does not appear to be adequately addressed. Suffolk County Council is the local highway Noted, EATL are in consultation Suffolk County authority and the District Councils would defer to Council with regard to highway and footpath its advice on the related highway and footpath matters. Applicant comments on relevant representations Page 4 East Anglia THREE Offshore Windfarm ................................................................................................. July,2016 Relevant Representation Comment EATLs Response diversion issues. The most significant and long lasting element of EATL recognise that landscape matters are a key the project involves the construction of the concern for the local communities surrounding the proposed sub-station at Bramford. While this substation. Since submission of the East Anglia element of the project would be constructed in Mid THREE DCO application, further detailed design Suffolk, the impact is likely to be more noticeable work has been undertaken on the masterplanning to people living and working in Babergh. Both for the integrated landscape scheme covering all District Councils therefore wish to secure substations planned for the area. These plans will significant on site landscape mitigation to reduce include substantial onsite landscaping and the the cumulative impact of the project upon the initial plans should be finalised in June 2016. surrounding countryside. In addition they would Prior to submission of the DCO application, EATL urge that the sub-station is constructed using stated the intention to undertake further landscape technologies that would allow for its height to be assessment to account for the ongoing kept as low as possible. masterplanning process. Therefore it is EATL’s intention to submit a revised assessment as part The mitigation proposals for the project are of Further Environmental Information. inextricably linked to those already consented for the East Anglia ONE sub-station on adjacent land. At this stage the District Councils remain concerned that the interplay between the two projects and a potential third project to the north has not been comprehensively considered. Discussions are currently on-going in relation to the discharge of the design and landscaping requirements for the East Anglia ONE project. Those discussions have been helped by the production of a strategic master plan which the District Councils would suggest should be used to inform the East Anglia THREE project rather than the other way round. At this stage further work is needed to understand EATL has committed to working with the local the impact of ash tree dieback (Chalara fraxinea) authorities to refine the mitigation necessary for on the existing woodlands which will help to adequate screening. This included a site visit with screen the impact of the East Anglia THREE local authority specialists on the 11th May