Hornsea Project Three Offshore Wind Farm

The views expressed in this page do not represent those of the Planning Inspectorate. This page consists of content submitted to the Planning Inspectorate by the public and other interested parties, giving their views of this proposal.

Hornsea Project Three Offshore Wind Farm

Received 20 July 2018
From Norfolk Coast Partnership


I am responding to the Orsted consultation on Hornsea Project Three of November-December 2017 on behalf of the Norfolk Coast Partnership, guardians of the Norfolk Coast Area of Outstanding Natural Beauty and the North Norfolk Heritage Coast.

Orsted plans show the cable coming ashore at Weybourne and heading south, crossing the A148 in the High Kelling area. In this area, the southern boundary of the AONB skirts the north side of Holt then runs eastward along the A148 road. Thus the onshore cable will run through a strip of the AONB between Weybourne and Holt, a direct distance of approx. 7.5km. The North Norfolk Heritage Coast designation stops at Kelling Hard, just to the west of the planned cable landfall. The AONB seaward boundary in this area is at low water mark and the Heritage Coast designation stretches seaward, with no official seaward boundary, so we also have some interest in the initial length of the offshore cable route.

In addition, this is a very environmentally-sensitive area with SPA, SAC, SSSI, EMS and MCZ designations involved or close by.

My comments relate to the potential effects of the development on the landscape quality of the Norfolk Coast Area of Outstanding Natural Beauty and North Norfolk Heritage Coast (referred to collectively as ‘the AONB’), with consideration also given to development beyond its boundaries where this may have impacts on the views from the AONB and indirect impacts on the landscape of the AONB. Other than these considerations, I have not commented on the impact of this windfarm and cable route outside of the AONB boundary. I have not assessed or commented on any impacts on the wider marine environment. I have not assessed or commented in detail on impacts on the wildlife of the area.

The current 2014-19 Norfolk Coast AONB Management Plan has a Policy (PC5) to ‘Support the development of renewable energy in the area in ways and locations that contribute to the area’s local economy and jobs and maintain its natural beauty.' However, the National Planning Policy Framework emphasises that the impact of a proposed development is an important consideration, including the cumulative landscape and visual impacts. It states that ‘Great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty’.

As renewable energy schemes, and particularly large wind power schemes, can have a highly significant impact on the natural beauty of the landscape, we approach each project on an individual basis.

We note that AC technology involves a wider cable route, more cables, use of an onshore cable relay station and/or an offshore station. Thus we suggest the use of DC technology is preferable. We suggest that the criteria for selection of AC or DC technology should be based on ‘best value for money’ rather than ‘least cost’, taking into a number of other factors including impact on the local area and community.

We question the decision to come ashore at Weybourne, given the long onshore cable route required to connect to the National Grid. We also question why the previous route, of the Dudgeon cables or Hornsea One or Two, cannot be reused or other collaborative ways of working be investigated to minimise local disruption.

It is apparent that the construction of the onshore elements of Hornsea Three
has the potential to impact on landscape and visual amenity. Orsted are proposing a number of measures to reduce the landscape and visual impacts, retain landscaping where possible and enhance and compliment landscape features going forward. It is requested that good communications are maintained with the Norfolk Coast Partnership and other relevant organisations to ensure that these measures remain appropriate and are effectively implemented.

We have identified a number of sensitive landscapes and habitats and request that the impact on these is minimised through careful planning and delivery. These sites include (working south from the landfall site):
• Weybourne Cliffs SSSI
• The shingle beach and shingle ridge, where its natural movement and profile should not be disrupted
• The reedbed and pond to the west of the beach car park – which the Norfolk Coast Partnership is seeking funding for a community project to restore
• Weybourne Beck (aka Spring Beck) – which has a published Catchment Management Plan (available from Norfolk Coast Partnership or Norfolk Rivers Trust)
• Kelling Heath SSSI – a valuable heathland landscape
• The Glaven River, running to its source near Selbrigg Pond – a rare chalk river with its northern stretch running through the AONB to the sea, of high ecological value and sensitive to pollution (e.g. run off during construction)

Orsted describe a range of measures to mitigate any effects on the area’s ecology (with specific reference to biosecurity, invasive species, protective buffer zones, trees and hedgerows, amphibians and reptiles, water voles, otters, badgers, bats, and wintering birds) and nature conservation for implemented prior to, during and post construction of the onshore elements of Hornsea Three, and the long-term management measures to be set in place for reinstated and enhanced habitats. It is requested that good communications are maintained with the Norfolk Coast Partnership and other relevant organisations to ensure that these measures remain appropriate and are effectively implemented.

The Norfolk Coast Path National Trail and other circular routes, public rights of way and permissive paths in the area are well used by visitors and locals and any disruption and closure of paths should be minimised.

There will be particular disruption to users of the Norfolk Coast Path National Trail at Weybourne. Orsted recognise the sensitive nature and high usage of the beach and the coastal footpath and propose measures for allowing continued access. It is requested that good communications are maintained with the Norfolk Coast Partnership and other relevant organisations to ensure that these measures remain appropriate and are effectively implemented.

Relay stations
We thank Orsted for planning to site any relay stations to the southern end of the potential area for their location, i.e. outside of the AONB, and confirm that we would object if this changed to within the AONB as we consider that it would have a significant impact on the designated landscape.

We suggest that construction traffic should use carefully selected routes within the AONB, to minimise disruption, damage and pollution.

This area is important for tourism, with visitors valuing its natural wilderness and tranquillity, and all efforts should be made to minimise the visual impact and disruption of construction and operation.

Historic environment
The area is well known for its historic environment, including human remains, burial mounds/tumuli (on Kelling Heath and Fox Hill), listed buildings and scheduled monuments and it is important to deal with these sites sensitively, to minimise any impacts.

It is suggested that construction activity should be preceded by agreement of an appropriate archaeological written scheme of investigation, submitted to and approved by Norfolk County

Off shore infrastructure
If the AC transmission option is adopted, we recognise the potential effect on visual amenity of any offshore booster/compensator platform which would be visible near to the coast from important areas within the AONB. We propose that this impact should be properly assessed, including the cumulative effects of this and other existing infrastructure.

We suggest that the cable should be brought ashore in a way which does not alter/impede the coastal processes, e.g. of shingle/sand movement.

We are pleased that the offshore cable route has been selected to avoid impacts on the Cromer Shoal Chalk Beds MCZ and its chalk reef habitat and suggest that any impacts on the marine EMS, MCZ and SAC should be minimised.

Light pollution
We are particularly concerned about light pollution, both of the temporary works and of the permanent infrastructure (including any offshore relay station). We have recently had two Dark Sky Discovery Sites designated very close to this area, one at Kelling Heath Holiday Park and one at Wiveton Downs. These sites are designated because they meet specified low light levels and visibility of stars , with little light pollution. Accordingly, we request details of light levels for the temporary works and for the permanent infrastructure. We request that careful consideration is given to the design and use of lighting through-out the project to minimise any light pollution, e.g. through careful use of appropriate lighting technology, levels used and shielding.

The longshore economy is important to the Norfolk Coast Partnership and we suggest that any impacts on the local fishing industry, either those who are based at Weybourne itself or those who fish in the area affected by construction, is minimised.

We recommend use of local products, suppliers and contractors and hope that this is maintained through-out the project life.

We suggest that the wider community and landscape should benefit from the project and we note that Orsted has implemented community funding schemes in other areas, including an area at the western end of the Norfolk Coast AONB.

We recognise a very important gap relating to local children and young people, who do not receive information about the environmental importance of their local area or the opportunities available to them for a career in the environment sector. Some initial ideas for filling that gap include:
• An education programme for local schools, teaching children about their local environment and also about the value of Norfolk’s protected landscapes. This could be combined with other topics, such as renewable energy.
• An apprenticeship scheme, allowing local young people to gain experience in the environment sector. This could be combined with other topics, such as renewable energy.
• An undergraduate/graduate scheme helping students to learn about the Norfolk environment and go on to gain.

We request that the Norfolk Coast Partnership is involved in exploring possibilities for community benefit.