Hornsea Project Three Offshore Wind Farm

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Hornsea Project Three Offshore Wind Farm

Received 22 July 2018
From Sarah Butikofer on behalf of Holt County Division

Representation

Hornsea Project Three Offshore Wind Farm
Application Ref: EN010080
Submission of Relevant Representation

I am writing as the County Councillor for Holt Division in North Norfolk, as such my area covers Weybourne, Kelling, High Kelling and Holt. I have been notified by Ørsted Hornsea Project Three (UK) Limited that, as of 08 June 2018, their application for Development Consent Order (DCO) in respect of Hornsea Project Three (HPT) has been accepted for examination by the Planning Inspectorate under the Planning Act 2008.

This letter forms my Relevant Representation and sets out a summary of the issues that in my role as a representative of the area I am most concerned about. It explains what I am most concerned about and consider especially relevant to my division in North Norfolk.

Principle of Development
Although not fundamentally opposed to the principle of renewable energy development in helping to tackle the challenges faced by climate change, I believe this area is taking too much of the pressure of national infrastructure development; particularly when previous projects in this area, and across the wider area of North Norfolk are considered. Onshore solar farms nearby at East Beckham and previous wind farm projects such as Dudgeon to name just two through this same area, should I believe be taken into consideration.

It is therefore essential to ensure that key design and construction decisions do not result in unacceptable or adverse impacts on residents or businesses within North Norfolk, ours is a unique and fragile economy and we simply cannot afford for it to be undermined. It is crucial that the important contribution that agriculture and tourism plays in the economic prosperity of the whole District and most importantly in these small villages is underpinned by the nationally and internationally recognised coast, landscape and biodiversity interests.


Keys Aspects of the Project Affecting Holt County Division
The proposed landfall site is once again at Weybourne Beach, with the inward cable route then passing inland through the villages of Kelling and High Kelling creating an 80m wide working corridor. The key design/construction decisions affecting Holt Division include:

• Choice of transmission system;
• Phasing of the Project and Associated Construction Timetable(s);
• Method and timing of bringing offshore cables onshore at Weybourne;
• Working Corridor of onshore cable route;
• Impact of construction traffic;


Choice of Transmission System - High Voltage Alternating Current (HVAC) vs High Voltage Direct Current (HVDC)
The final chosen method of transmission of electricity to the onshore gird connection location will have a fundamental bearing on the overall impact of the project. Whilst I recognise that Ørsted Hornsea Project Three (UK) Limited wish to keep their options open to using either HVAC or HVDC, this does currently present a very wide project envelope and increases the level of uncertainty for affected parties until such time as the final transmission method is chosen.

As the NNDC report states ‘Table 3.37 in Chapter 3 of the Environmental Statement seeks to compare the components involved in the different HVAC / HVDC transmission systems. It has been the understanding of the local Council NNDC since the pre-application stage that a HVAC system will require an onshore booster station, with a site identified onshore near to the village of Edgefield; together with an offshore booster station, at a yet unidentified location, within a search zone approximately 19-22 nautical miles offshore from Cromer.

However, table 3.37 creates uncertainty as to whether these booster stations are required with the reference that these components ‘May be required’. However, the accompanying comments within that table suggest ‘HVAC: onshore and/or offshore booster station required’

I completely support the view taken by North Norfolk District Council which says ‘it is important for there to be absolute clarity about the components required for each transmission type so that the worst-case scenario in relation to the HVAC option can be fully assessed. This is critical to ensure the impact of the development is properly understood and so that weight can be afforded by the decision maker as to whether one type of electrical transmission should be preferred over the other with the potential for the Development Consent Order to specify the transmission system to be used where there is compelling evidence to do so.

In the opinion of North Norfolk District Council, HVDC would result in the need for fewer buried cables and would have the least damaging impact on the district of North Norfolk when considering the project as a whole, particularly as this would negate the need for the booster station near Edgefield.’


Phasing of the Project and Associated Construction Timetable(s)
NNDC’s response is clear on this issue which is far from what we have seen from Ørsted, timing of this project has changed at every meeting I have attended. The notes below from NNDC’s report show clearly a potential 15 year window of construction, yet last week at a public meeting we were categorically told it was 8 maximum.

‘Section 3.8 of Chapter 3 – Project Description sets out the Construction Phasing if the Development Consent Order is granted. This is also set out at para 2.15 of the Development Consent Under Explanatory Memorandum in terms of maximum durations. It indicates that construction could commence 2020/21 and could take up to seven years if built out in a single phase or up to 10 years if built out in two phases, with a maximum period of six years between the end of the first phase and commencement of the second phase.

NNDC understands that the onshore elements of the proposed project would take three years to construct in a single phase but this could span a six-year period in a two phase scheme (assuming a three-year gap between phases). If reference is made to the DCO Explanatory Memorandum (together with the example two phase programme at Figure 3.39 (Chapter 3: Project Description) then the duration of the project could well exceed 15 years if a gap of six years between the end of the first phase and commencement of the second phase is allowed by the DCO.

Clarity over Construction timetabling is a matter that NNDC would seek to be considered further, as part of the examination process, in order that any adverse impacts of construction in a single or two phase programme can be properly understood and appropriately managed for the benefit of residents and businesses within the District. The possibility of any extended construction window (certainly if it was to extend over 15 years) would be considered totally unacceptable to NNDC and local communities most of which are dependent on the tourism economy and the Council believes that the examination should explore how the project, and any grant of DCO, could reduce the maximum construction envelope down to an acceptable level. This may include specifying a maximum gap between the end of the first phase and commencement of the second phase.

In respect of a two-phase scheme it will be important during the examination to understand which components will be installed in the first phase which may help to reduce any future adverse consequences during the second phase. For example, in a two-phase construction the Environmental Statement does not appear to give consideration as to whether cable ducting could be laid for all of the development in phase one which would help reduce the adverse impacts of having to re-open or dig new trenches to lay cables for phase two. By laying ducting, a simpler cable pull through process would be possible in phase two which would help reduce disturbance impacts and speed up project completion. It would also help reduce the impacts from construction traffic in phase two by reducing the need for vehicles bringing imported stabilised backfill material over a wide time period (see section Impact of Construction Traffic). Completing the majority of trench works in phase one would also allow time for soils to recover and reduce the length of time taken out of agricultural production.

The Council believes the examination panel will also need to satisfy itself that the benefits of any landscape mitigation works planned in phase one are not damaged or undermined by a protracted phase two timetable which may include re-opening trenches. It is important that all mitigation works are delivered at an early stage so as to make the impact of the works acceptable in planning terms. Any phase one mitigation landscaping damaged or requiring removal during phase two would take time to recover and so may not deliver the level of mitigation expected over the planned lifetime of the project.’


Method of bringing offshore cables onshore at Weybourne
It is essential that construction works on the beach are done ‘out of season’ as far as possible to mitigate the impacts on local businesses totally dependent on the tourist trade in the area for survival. This area forms part of a larger project by NNDC ‘The Deep History Coast Project’, to bring tourists into the area out of season to help sustain these communities. Any works done in this area must be fully mitigated to minimise beach disruption for users, in terms of noise, access and visibility. It is completely unacceptable that Ørsted have so far failed to respond to concerns already raised by NNDC as reported below.

‘At the Preliminary Environmental Information Report (PEIR) stage, NNDC advised that:

‘Whilst the method of construction in the nearshore/landfall location needs to be considered further and in more detail, initial consideration is that a Horizontal Direct Drilling (HDD) approach would prove to be the least likely to have impacts on nearshore processes during construction and would be preferred. This should (in consideration with other marine environmental factors) be at an extent where HDD exit points have minimal impact on nearshore coastal processes. Likewise buried cabling as identified in the reports would be preferred to minimise impacts to coastal processes with low profile protection being the secondary position.

Impact of the proposed cables on tides and, in particular, waves and the influences this may have on coastal sediment transport are important factors that the Environmental Statement will need to include and PEIR seems to be making progress in covering these important issues’.

Some nine months after the PEIR response from NNDC it is disappointing that Ørsted are still discussing the possibility of open cut trenching techniques to bring the offshore cable onshore to the Transition Joint Bays (TJBs). Para 3.6.12.23 of the Environmental Statement Project Description refers to Open cut installation requiring beach closures of up to one month per cable. It is understood there would be 6 offshore cables using HVAC transmission or there would be 4 offshore cables (plus one HVAC cable) with HVDC transmission. This would suggest potential beach closure of up to six months in the worst case HVAC scenario.

The District Council therefore believes it will be very important for the examination to establish and understand the impact of nearshore works, the timing of works and how impacts on public footpaths and rights of way, including public access to the beach, for recreation can be managed without significant detriment to amenity. The associated economic impact of beach closures therefore needs to be properly assessed and mitigation considered as part of the examination process.

The examination stage will also need to consider the impact of open cut trenching on the Weybourne intertidal area (including effects on the Marine Conservation Zone, adjacent Site of Special Scientific Interest and nearby Special Area of Conservation) so that, where the evidence can justify it, the scope of the project is narrowed down to exclude inappropriate trenching techniques in any subsequent grant of DCO.

Based on the evidence seen to date, NNDC remains firmly of the view that HDD techniques (long HDD drill) should be used to bring the offshore cables onshore as this will have the least damaging impact on the nearshore (especially with a two-phase project), will result in fewer adverse impacts on coastal processes and will reduce the potential to destabilise the cliffs at Weybourne compared to open trenching techniques. ‘


Working Corridor of onshore cable route
Ørsted have for some time made clear that the working corridor of the onshore cable route would typically be 80m wide - consisting of a 60m central section comprising three no. 5m wide and up to 2m deep trenches (tapering to 1.5m at base) either side of a 6m wide haul road. Each side of the cable corridor would include additional 10m wide strips of land on which topsoil and subsoil would be stored. Figure 3.32 within the Environmental Statement Project Description shows an indicative layout (albeit it appears to only show 12 cables rather than the 18 cables required for the 6 circuit HVAC worst case scenario).

It would be very helpful at examination stage to understand the likely layout for the HVDC solution which it is understood would consist of 8 HVDC cables and 3 HVAC cables. This may result in a reduction in the number of trenches needing to be dug and would mean less soil disturbance, which would be welcomed, particularly when passing across currently active agricultural land. I like the Council believe there is currently a lack of clarity generally about the ‘best-case scenario’ with this project which it is hoped will be made clearer through examination.

Impact of construction traffic
Again the report by NNDC sets out a comprehensive view, however I should like to reiterate that as the County Councillor responsible for this area I am particularly concerned about the impact on our fragile infrastructure, and homes built on the very edge of roads with large vehicles and their associated vibrations passing.

‘Within North Norfolk it is assumed that the main traffic generators connected with Hornsea Project Three will come from construction traffic associated with:

• Bringing the offshore cables onshore at Weybourne
• Construction of the cable corridor; and
• Construction of the HVAC Booster Station (assuming HVAC transmission is used)

North Norfolk has many small and narrow country roads with restricted widths and limited opportunities for larger vehicles to pass each other. Traffic levels vary but tourism during March to October (heighted during the summer months especially near coastal locations) means that the timing of any construction works will be critical to minimising adverse highway impacts.

Volume 3, Chapter 7 of the Environmental Statement considers Traffic and Transport and Table 7.9 sets out the ‘maximum design scenario considered for the assessment of potential impacts on traffic and transport’ and Table 7.12 sets out the daily construction vehicle movements split out into construction staff and HGVs and Table 7.18 indicates the Impact of Hornsea Project Three Construction Traffic Flows including percentage change due to construction traffic (Maximum daily change) for HGVs and total vehicles. An Outline Traffic Construction Management Plan has been provided which seeks to ‘establish the principles that will be implemented by the principal contractors to minimise the adverse impacts associated with the transport of materials, plant and staff required for construction of the onshore elements of Hornsea Project Three offshore wind farm’

At the examination it will be important to understand the highway implications for the best-case scenario (assumed HVDC) and the worst case scenario (assumed HVAC) so that residents and businesses can properly understand the impact of construction traffic, where it is planned to go, in what volumes and for what duration. At present it is difficult to cut through the information presented in order to gauge an understanding of the different scenarios.

It is likely that focus in the examination will be on the accuracy of the figures presented including baseline date and expected traffic movements. In particular, within Table 7.12, Link IDs 1, 50, and 55 within NNDC area show no daily construction movements and no percentage changes. It will be important to understand how such commitments and mitigation strategies can be secured in any subsequent consent to minimise adverse effects on sensitive receptors, as well as consideration of whether delivery of equipment and cables should be outside of daytime hours when traffic volumes on these routes are highest.

Consideration will also need to be given to construction phasing and what will happen in the event of significant delay between first and second phases including construction compounds, temporary access routes and mobilisation works within North Norfolk.’

Landscape & Biodiversity Mitigation
NNDC recognise that Ørsted have undertaken desktop studies and Phase 1 Habitat Surveys together with site specific surveys in accordance with best practice recommendations in order to inform the baseline data which underpins Environmental Statement Volume 3, Chapter 3 – Ecology and Nature Conservation. Figure 3.2 (Sheets 1 to 5) set out the range of ecological constraints including, amongst other things, the location of Sites of Special Scientific Interest (SSSIs), County Wildlife Sites as well as data for Great Crested Newts, reptiles and bat activity. Figure 3.2 also sets out in some detail the intended locations for Hydraulic Directional Drilling including locations: A - HHD only, B – HDD with haul road over, C – HDD with haul road over or Open Cut, and D – HDD and ducting laydown. The Use of HDD section above identifies some issues to consider at examination stage regarding HDD types to be employed along the cable corridor route.

Section 3.10 of the Environmental Statement Volume 3, Chapter 3 – Ecology and Nature Conservation sets out Measures to be adopted as part of Hornsea Three and these are welcomed by NNDC and should be secured with any consent. It will also be important for Ørsted to set out and quantify landscape mitigation to offset the loss of hedgerows and trees which will provide the opportunity for both landscape and ecological enhancements sufficient to at least outweigh any adverse impacts.

Consideration will also need to be given to the timing of enhancement/mitigation works, particularly in view of the potential for the project to be split into two phases.


Summary
As I said at the beginning whilst I am not against the principle of offshore wind development it is critical to me and more importantly the people I represent, that if we are to take more of this national burden locally the project must be managed and delivered in a way that does not result in significant adverse impacts on local communities and businesses close to the landfall and along the onshore cable route.

Given the current size of the project envelope, NNDC has genuine concerns about certain aspects of the proposal and it is requested that these matters, as set out above, are taken forward as part of the examination stage so that there can be greater clarity about the proposals and confidence that an acceptable DCO outcome can be achieved for the residents, businesses and communities of North Norfolk.

Yours sincerely

Sarah Butikofer
County Councillor for Holt Division (Norfolk County Council)
District Councillor (North Norfolk District Council)