Joint response of Suffolk Coastal District Council and Suffolk County Council to Scottish Power Renewables Phase 4 Public Consultations on East Anglia One North and East Anglia Two Offshore Wind Farm Projects GLOSSARY OF ACRONYMS AADT Annual Average Daily Traffic AIL Abnormal Indivisible Load AIS Air Insulated Substation AONB Area of Outstanding Natural Beauty AQMA Air Quality Management Area AQS Air Quality Strategy BLF Beach Landing Facility BNL Base Noise Level CCS Construction Consolidation Site CEMP Construction Environment Management Plan CIA Cumulative Impact Assessment CIfA Chartered Institute for Archaeologists CL:AIRE Contaminated Land: Applications in Real Environments CLEA Contaminated Land Exposure Assessment CMS Construction Method Statement CTMP Construction Traffic Management Plan CRTN Calculation of Road Traffic Noise dB Decibels DBA Desk Based Assessment DCO Development Consent Order DEFRA Department for Environment, Food and Rural Affairs DMO Destination Management Organisation DMP Dust Management Plan DMRB Design Manual for Roads and Bridges EA1 East Anglia One EA1N East Anglia One North EA2 East Anglia Two EA3 East Anglia Three ES Environmental Statement ETG Expert Topic Group FRA Flood Risk Assessment GIS Gas Insulated Substation GVA Gross Value Added HDD Horizontal Directional Drilling HDV Heavy Duty Vehicle HER Historic Environment Record HGV Heavy Goods Vehicle LAQM TG Local Air Quality Management Technical Guidance LBCA Listed Building and Conservation Act 1990 2 | P a g e LCT Landscape Character Type LDV Light Duty Vehicle LGV Light Goods Vehicle LVIA Landscape and Visual Impact Assessment MMP Materials Management Plan NALEP New Anglia Local Enterprise Partnership NG National Grid NO2 Nitrogen Dioxide NPPF National Planning Policy Framework NPS National Planning Statement NSIP Nationally Significant Infrastructure Project O&M Operations and Maintenance PEIR Preliminary Information Report PROW Public Right of Way RAG Red, Amber and Green RMSE Root Mean Square Error RSPB Royal Society for the Protection of Birds SCC Suffolk County Council SCDC Suffolk Coastal District Council SCT Seascape Character Type SLVIA Seascape Landscape and Visual Impact Assessment SPA Special Protection Area SPR Scottish Power Renewables SPS Suffolk Preservation Society SSSI Site of Special Scientific Interest SuDS Sustainable Drainage Systems SWDP Surface Water Drainage Plan WEB TAG WEB Transport Appraisal Guidance WFD Water Framework Directive WSI Written Scheme of Investigation WWII World War 2 3 | P a g e RESPONSE OF SUFFOLK COASTAL DISTRICT COUNCIL AND SUFFOLK COUNTY COUNCIL TO PHASE 4 PUBLIC CONSULTATIONS BY SCOTTISH POWER RENEWABLES ON THE EAST ANGLIA ONE NORTH AND EAST ANGLIA TWO OFFSHORE WIND FARMS. INTRODUCTION 1. This document is a joint response from Suffolk Coastal District Council and Suffolk County Council (referred to as “the Councils” in this response) to Scottish Power Renewables (SPR’s) Phase 4/Section 42 public consultation on both East Anglia One North (EA1N) and East Anglia Two (EA2) windfarm projects. The direction and head line comments of the response were formally agreed in Cabinet meetings of the Councils, on 11 March 2019 by Suffolk Coastal District Council’s Cabinet and on 12 March by Suffolk County Council’s Cabinet. The recommendations the Cabinets supported were: 2. That the Cabinet is recommended to inform SPR that the Councils continues to support the principle of offshore wind as a significant contributor to the reduction in carbon emissions and for the economic opportunities that they may bring to ports in the NALEP geography that could support the construction and maintenance of the windfarms. Notwithstanding this position the Councils: a) Object to EA2 in relation to the significant effects predicted offshore by SPR on seascape, coastal landscapes, character and qualities of the Area of Outstanding Natural Beauty (AONB) and cumulatively with EA1N. The EA2 project will result in a significant change to the sea views from key viewpoints on the AONB coast with the horizon cluttered with turbines. An impact which will be continuously experienced along the coastline further exacerbated when viewed in combination with EA1N and other existing wind farm arrays. It is also recommended that the Councils express concerns in relation to the effects of EA1N on seascape, landscape and visual effects and objects in relation to the cumulative impacts with EA2 b) Object to the overall impact of the onshore substations of EA1N and EA2 individually and cumulatively on the village and environs of Friston, including on archaeological and heritage assets, landscape character, visual effects, noise and residential amenity. The development of the substation site will permanently change the character of the landscape and have significant visual effects with the setting of the village and the relationship between the historic buildings and their 4 | P a g e farmland setting permanently changed. The development will also introduce a noise source within an existing tranquil location which at the present noise limit set (35dB) would unacceptably increase the background noise levels; c) Are of the view the impacts on the cable route are predominantly capable of being mitigated in the long term but the Councils need to discuss with SPR the measures necessary to mitigate impacts during the construction period including the transport impacts. d) Register concern about both EA1N and EA2 projects in relation to the following matters: i) Loss and sterilisation of good quality agricultural land at Friston in order to accommodate the substations for the projects; ii) Impact on the Grade II listed building at Aldringham Court and its landscape setting from the cable route. e) Seek further information from SPR on both EA1N and EA2 projects in relation to the following matters: i) Impacts on air quality during the operational and construction phases of the projects, justifications for assessment scope and modelling results and cumulative impacts with Sizewell C; ii) Gaps in the information available on flood risk impacts and flood alleviation; iii) Noise sources on site including National Grid infrastructure and mitigation; iv) Highways modelling assessments and assumptions utilised, highways mitigation proposed and how this would be implemented and secured; v) Coastal processes associated with the cable landing point; vi) Ground contamination mitigation, vii) Ecology mitigation and justification for scope of assessments; viii) Archaeological surveys and results; ix) Impact of projects on heritage assets including assessment of coastal heritage assets; x) Socio-economic assessment assumptions and employment predictions, labour displacement effects, current skills shortages and mitigation strategies proposed; xi) Impact on tourism and recreation during the construction and operation phases and mitigation strategies; xii) National Grid connection infrastructure xiii) Cumulative impacts of the projects with other projects; f) Agree to work with SPR to identify the means by which the impact of the proposals can be mitigated and/or compensated if the developments do take 5 | P a g e place including the opportunity to achieve betterment in flood alleviation in Friston; g) Require SPR to work closely with other developers including EDF Energy and National Grid Ventures to consider how mitigation across the schemes can be combined to minimise the impact of the totality of developments in the local area; h) Seek a wider compensation package from developers and the Government that deals with the broader impacts on community, environment and businesses of this and other energy projects in the area. 3. At the time of writing the Cabinet reports the Councils were only able to provide high level comments and had not had the opportunity to look at all the detail contained within the consultation documents. This response therefore builds upon the contents of the Cabinet reports. 4. SPR has arranged a series of public information days which have been held on a combination of both weekdays and Saturdays and been timed to allow good access by the local population. In addition to the presentation boards which have been available at previous events, a flyover video of the whole offshore and onshore development area of the projects and a computer programme which provided modelled visualisations of the developments were available to view and utilise. As with the previous public information days there was limited information available to take away at the events. It is however accepted that hard copies of the Phase 4 documents were available to view on the day and have been made available at specific locations identified within the Statement of Community Consultation. 5. The Councils have received comments in relation to the relatively short consultation period provided for the Phase 4 consultation. The six week timescale in combination with the volume of information contained within the consultation documents has been a challenge for the Councils and local communities. 6. The purpose of the Phase 4 consultation is to provide Preliminary Environmental Information (PEIR) which sets out the proposals in detail and their potential impacts. SPR has made it clear that the two projects are completely independent of one another and although the consultations are occurring simultaneously, SPR will be submitting two Development Consent Order (DCO) applications, one for each project and it is understood two separate examinations will be held to consider