Somerset County Council, North Somerset Council, Sedgemoor District Council, West Somerset Council Hinkley Point C Connection Project Stage 4 Consultation - Technical Review Also incorporating transport comments on behalf of Bristol City Council and South Gloucestershire Council Issue | 29 October 2013 This document is without prejudice to on-going consideration and remains subject to review of further information that may be requested or received in relation to the eventual DCO application. With support from: Arup and JMP Somerset County Council, North Somerset Council, Sedgemoor District Council, West Somerset Hinkley Point C Connection Project Council Stage 4 Consultation - Technical Review Contents Page Abbreviations 0 Executive Summary 1 1 Joint Councils s42 Response 9 1.1 Introduction 9 1.2 Draft Development Consent Order (DCO) 9 2 PEIR and associated consultation material 10 2.1 Context 10 2.2 Content 10 2.3 PEI definition 11 2.4 Consultation 14 2.5 Programme 15 2.6 Alternatives 16 2.7 Policy Context 17 2.8 Methodology 17 2.9 Baseline 17 2.10 Impact Assessment 17 2.11 Mitigation 19 3 Design Commentary 21 3.1 The T pylon Option 21 3.2 Proposed Route Options 22 3.3 Temporary Construction Infrastructure 24 4 Preliminary Environmental Information Report and Topic Based Plans 26 4.1 Landscape and Visual Effects 26 4.2 Biodiversity and Nature Conservation 39 4.3 Ground Environment 45 4.4 Hydrology and Water Resources 48 4.5 Historic Environment 52 4.6 Traffic and Transport 57 4.7 Air Quality and Emissions 90 4.8 Noise and Vibration 93 4.9 Socio-Economics and Land Use 97 i | Issue | 29 October 2013 Somerset County Council, North Somerset Council, Sedgemoor District Council, West Somerset Hinkley Point C Connection Project Council Stage 4 Consultation - Technical Review Appendices Appendix A SCC review of access details Appendix B Road structures identified in North Somerset on the proposed construction traffic routes ii | Issue | 29 October 2013 Somerset County Council, North Somerset Council, Sedgemoor District Council, Hinkley Point C Connection Project West Somerset Council Stage 4 Consultation - Technical Review Abbreviations Abbreviations used commonly in this report are: ATC – Automatic Traffic Counter NPPF - National Planning Policy Framework AADT – Annual Average Daily Traffic NPS – National Policy Statement AONB – Area of Outstanding Natural Beauty NSC – North Somerset Council CIEEM – Chartered Institute of Ecology and OLE – Overhead Line Equipment Environmental Management CEMP – Construction (Environmental) Management PCBs – Polychlorinated Biphenyls Plan CSE – Cable Sealing End (compound) PEI(R) – Preliminary Environmental Information (Report) DCO – Development Consent Order PINS – The Planning Inspectorate, the National Infrastructure Directorate of PINS is referred to as the Examining Authority in this report DMV – Deserted Medieval Village PFRA – Preliminary Flood Risk Assessment DPD – Development Plan Document PRoW – Public Rights of Way EA – Environment Agency RoWIP – Rights of Way Improvement Plan EDFE – EDF Energy SAC – Special Area of Conservation EIA – Environmental Impact Assessment SCC – Somerset County Council EMS – European Marine Site SHER – Somerset Historic Environment Record ES – Environmental Statement SoCC – Statement of Community Consultation FRA – Flood Risk Assessment SDC – Sedgemoor District Council GLVIA3 – Guidelines for Landscape and Visual Impact SFRA – Strategic Flood Risk Assessment Assessment Version 3 HDV – Heavy Duty Vehicle SLA – Service Level Agreement HPB/HPC – Hinkley Point B station/Hinkley Point C SM – Scheduled Monument HRA – Habitats Regulations Assessment SNCI – Site of Nature Conservation Interest IDB – Internal Drainage Board SPA – Special Protection Area IfA – Institute for Archaeologists SPD – Supplementary Planning Document kV – Kilovolt or 1,000 volts. SSD – Stopping Sight Distance LCA – Landscape Character Assessment TA – Transport Assessment LIR – Local Impact Report TBC – To Be Confirmed LPA – Local Planning Authority WSC – West Somerset Council LWS – Local Wildlife Site ZTV – Zone of Theoretical Visibility National Grid – the Applicant 0 | Issue | 29 October 2013 Somerset County Council, North Somerset Council, Sedgemoor District Council, Hinkley Point C Connection Project West Somerset Council Stage 4 Consultation - Technical Review Executive Summary Somerset County Council (SCC), North Somerset Council (NSC), Sedgemoor District Council (SDC) and West Somerset Council (WSC), hereafter referred to as “the Joint Councils”, have commissioned a technical review of the draft proposals and Preliminary Environmental Information Report (PEIR) prepared by National Grid in respect of the Hinkley Point C (HPC) Connection Project. This technical review has been prepared by Arup, JMP (traffic and transport) and SCC (historic environment) on behalf of the Joint Councils. The technical review relates primarily to the administrative areas of the Joint Councils. The Joint Councils have also worked closely with both Bristol City Council (BCC) and South Gloucestershire Council (SGC) in reviewing the consultation material. Traffic and transport comments in this report are made on behalf of BCC and SGC as well as the Joint Councils. This report has been prepared to help inform a response to National Grid regarding the draft proposals and PEIR for the HPC Connection Project. The PEIR precedes submission of an application for Development Consent by National Grid, which we understand is scheduled for early 2014. This report is intended to complement individual responses that may have been made or may be made by individual authorities and does not seek to prejudice those responses. Outstanding information and further structured engagement As would be expected for a PEIR document, additional baseline data and assessment material remains to be prepared prior to its incorporation into a formal Environmental Statement (ES) to accompany the application for Development Consent. A number of matters remain unresolved from earlier consultations and are identified again in this response. The additional information required includes: Photomontages from all agreed viewpoints but in particular for key views such as the crossing of the Polden Hills; A landscape scheme (as referred to in Schedule 2, Article 4 of the draft DCO) according with the principles set out in paragraph 2.8.11 of the National Policy Statement (NPS) for Electricity Networks Infrastructure (EN-5)1 and paragraph 5.10.20 of the NPS for Energy EN-12; An ecological management strategy (as referred to in Schedule 2, Article 10 of the draft DCO) and according with the principles set out in Section 2.7 of NPS EN-5; Ecological survey data and impact assessment of green route proposals for the 132kV undergrounding near Portishead; A Construction Environmental Management Plan (CEMP) (as referred to in Schedule 2 Article 11 of the draft DCO); A Transport Assessment (TA); 1 National Policy Statement for Electricity Networks Infrastructure (EN-5). Department for Energy & Climate Change, July 2011. 2 National Policy Statement for Energy (EN-1). Department for Energy & Climate Change, July 2011. 1 | Issue | 29 October 2013 Somerset County Council, North Somerset Council, Sedgemoor District Council, Hinkley Point C Connection Project West Somerset Council Stage 4 Consultation - Technical Review Access Details (as referred to in Schedule 2, Article 6 of the draft DCO); Construction Traffic Management Plan (as referred to in Schedule 2, Article 12 of the draft DCO); A construction method statement; Bat and otter detailed survey data; A robust assessment of the impacts on public rights of way (PRoW) including a route wide mitigation strategy and definition of path management proposals and the duration of RoW closures, supported by PRoW condition surveys; A footpath implementation plan (as referred to in Part 2, Article 17 of the draft DCO)(although it is recommended that this is extended to form a PRoW implementation plan); The proposed surface and foul water drainage system (as referred to in Schedule 2, Article 8 of the draft DCO) and in particular details of surface water management during construction and operation in areas of undergrounding; Confirmation of river crossing options (e.g. whether bridging or directional drilling) in areas of undergrounding; Detailed flood risk assessments (FRA) including specific detail in relation to topography, flood risk management, protection, resistance or resilience; Historic environment data as listed in PEIR Chapter 11, Paragraph 11.9; An assessment of the impact of temporary pylons; Clarification of actual tree and hedgerow loss; Substation site walkover survey data; Air quality assessment of construction traffic movements; Information regarding the methodology for assessment of tourism impacts; Effects on land holdings in areas of undergrounding; Additional business survey data; and A Health Impact Assessment (HIA). The extensive nature of the highlighted list, which includes key mitigation strategies that are referenced in the draft DCO, limits a full understanding of the environmental effects of the project at this stage. The mitigation strategies address the principle impacts of the proposals (e.g. in relation to landscape, ecology, transport, PRoW and construction activities). Ideally, these mitigation strategies would have been available for public comment as part of the PEIR, to enable a more complete understanding of the environmental effects of the project and the