Norfolk Boreas

Representations received regarding Norfolk Boreas

The list below includes all those who registered to put their case on Norfolk Boreas and their relevant representations.

SourceRepresentation - click on an item to see more details
Local Authorities
Borough Council of Kings Lynn and West Norfolk
"The Borough Council of Kings Lynn and West Norfolk have no comment to make"
Other Statutory Consultees
Corporation of Trinity House
"Dear Sir / Madam We refer to the above application for development consent. Trinity House is the General Lighthouse Authority for England, Wales, the Channel Islands and Gibraltar with powers principally derived from the Merchant Shipping Act 1995 (as amended). The role of Trinity House as a General Lighthouse Authority under the Act includes the superintendence and management of all lighthouses, buoys and beacons within our area of jurisdiction. Trinity House wishes to be a registered interested party due to the impact the development would have on navigation within Trinity House’s area of jurisdiction. It is likely that we will have further comments to make on the application and the draft Order throughout the application process. Please address all correspondence regarding this matter to myself at [email protected] and to Mr Steve Vanstone at [email protected] Yours faithfully, Russell Dunham ACII Legal & Risk Advisor"
Other Statutory Consultees
NATS Safeguarding Office
"Dear Sirs, NATS has identified an impact from the proposed development and is currently engaged with the Applicant in respect of identifying mitigation measures. Accordingly, NATS En-Route LTD wishes to register as an Interested Party. Regards S. Rossi NATS Safeguarding Office"
Members of the Public/Businesses
Penelope Malby
"We own a very popular holiday let in Happisburgh. Boreas will have a huge effect on the tourism industry in Happisburgh. As a result we will lose custom. It will also affect the natural environment, the traffic, the noise levels, the pollution levels."
Other Statutory Consultees
The Coal Authority
"Further to the letter dated 12 July 2019 from Mr Graham Davey – Project Manager at Norfolk Boreas Limited. I can confirm that whilst part of the site falls within the defined coalfield, the site is within the defined Development Low Risk Area meaning there are no recorded risks from past coal mining activity likely to affect the development. The Coal Authority would request that the following wording is included as an Informative Note on any planning permission granted: The proposed development lies within a coal mining area which may contain unrecorded coal mining related hazards. If any coal mining feature is encountered during development, this should be reported immediately to the Coal Authority on 0345 762 6848. Further information is also available on the Coal Authority website at: www.gov.uk/coalauthority"
Members of the Public/Businesses
Jenny Smedley
"Whilst I respect that the Planning Inspectors do not usually consider the cumulative effect of planning applications, in this case the overlapping effects of 3 massive projects in Necton (substations for Dudgeon and its associated National Grid infrastructure, Vanguard and its associated National Grid infrastructure and now Boreas and its associated National Grid infrastructure) is so cumulatively as well as individually so destructive to Necton in both character and imposition that I hope these projects will be looked at in a cumulative manner."
Other Statutory Consultees
Maritime and Coastguard Agency
"The MCA’s remit for offshore renewable energy development is to ensure that safety of navigation is preserved and the UK's search and rescue capability is maintained whilst progress is made towards government targets for renewable energy. We would appreciate the opportunity to consider the project in line with MCA published guidance (Marine Guidance Note 543 and its annexes) throughout the examination phase."
Non-Statutory Organisations
National Federation of Fishermen's Organisations
"The NFFO is a representative body of the fishing industry covering England, Wales and Northern Ireland. We intend to examine the assessment of impacts to fisheries, both direct impacts on fishing businesses and any related impacts to the fisheries resource base. We are interested in maximising the scope for coexistence between our two industries and will consider provisions to achieve this end. We intend to pursue a statement of common ground with the applicant, which together with the applicant's documentation will then inform any detailed representation we wish to make."
Members of the Public/Businesses
Brown and Co on behalf of Necton Farms Ltd
"Necton Farms Ltd own land which has been identified as the site of the on-shore substations, for the Boreas and the National Grid connection sites. This representation sets out Necton Farms’ concerns for the project; The proposed substations will have an effect on the holding and Necton Farms’ business, both by way of land lost to the scheme, but substantially, too, by way of Injurious Affection to the retained farm. This is justified as follows; • Impact on Necton Farms’ farming business during construction; disruption to accessibility of the farm, irregular field shapes, land taken out of production for work to pylons. • Impact on the farm business due to decrease in farm size • Devaluation, in monetary terms, of the retained farm; which entails loss of amenity value of the farm, and decreased agricultural value due to the affects on the layout of the farm, changes in field shapes, accessibility of the farm. This representation is made to identify Necton Farms Ltd as an interested party in the Project."
Non-Statutory Organisations
East of England Energy Group (EEEGR) (East of England Energy Group (EEEGR))
"On behalf of the East of England Energy Group (EEEGR) we strongly support this application which will help the nation achieve its carbon reduction targets, provide investment in a post industrial seaside town, generate skilled and well paid jobs for two generations of employees and further promote the East of England as the epicenter of the offshore wind industry. As the trade representation and business development organisation for the energy sector in the East of England EEEGR is recognised by the New Anglia LEP (NALEP) as the 'sector lead' organisation for the vitally important energy sector in the region. The East of England is crucial to UK PLC in keeping the nation lit and warm with over 50 years of gas and nuclear production and now with 52% of the installed capacity in the UK off the East coast. The government have set a target to generate a third of the UK's electrical requirement from offshore wind by 2030 and this project is a vital part of that initiative and cements the region as the global exemplar and 'shop window' for the future growth of offshore wind. We fully support this project and would encourage the inspectorate to approve it."
Parish Councils
Brian Schuil
"As a Parish Council we will be making comments on any problems that could be caused to our Village in relation to extra traffic and cable routes close to our Village as we have done for the Orsted project and the Vanguard project."
Members of the Public/Businesses
Mrs G Watson
"I live around 200 metres from what was the proposed site for the cable relay station for this project. Although the applicant has repeatedly stated that this will now be a DC project and no relay station will be needed, I feel it is wise to keep up to date with the planning process. Especially when looking at the traffic movements and disruption expected in an almost exclusively rural area with small roads and no infrastructure. I live very close to the originally proposed Cable Relay Stations for the joint Boreas and Vanguard projects. We were delighted when Vattenfall publicly confirmed they are intending to pursue the DC option and discount the AC proposal and therefore won't need the intrusive, inappropriate and inefficient Cable Relay Stations, or the substantially larger cable trenches. However, I want to, and feel it is necessary, to continue to monitor progress. Although the Boreas proposal is part of a bigger project, it will be assessed by you in isolation and the public support for DC may not be as apparent now."
Members of the Public/Businesses
Alice Spain
"Although the Boreas DCO follows on from the Vanguard DCO, it acknowledges that the Vanguard DCO may not be approved. It may have to stand on its own merits. Two options are presented in the DCO, one with and one without Vanguard. Since options are presented, Vattenfall should also have considered the alternative route forward for connection into the National Grid that has already been debated in Parliament and is being seriously considered as a more environmentally appropriate solution to routing electricity from the sea-based wind farms off East Anglia onto the National Grid, the off-shore ring main (ORM). The timescale for this project is sufficiently long for acknowledgment that use would be made of an ORM instead of cabling to, and enlarging, the Necton Substation if the ORM is available in a suitable timescale and Vanguard does not go ahead."
Members of the Public/Businesses
Necton Substation Action Group
"This application is merely an extension to Norfolk Vanguard. One destined, if approved, to create an industrial site (by stealth) of in total of over 70 acres of very high substations in the centre of several rural communities, and each and every one will be badly affected by the industrialization of their area. This part of the project should therefore be looked at cumulatively with that of Dudgeon, Vanguard, and Boreas in the area of Necton, and Hornsea 3 in other areas, (together with National Grid extensions in each area) and should include them all in the examination, as the mass of each one contributes greatly to each of the others. This situation does not have a precedent and should therefore be treated uniquely by the Planning Inspectorate."
Non-Statutory Organisations
Rijskwaterstaat
"Rijkswaterstaat is the implementing agency of the Netherlands Government/Ministry of Infrastructure and Water Management. They advise the Ministry of Economic Affairs and Climate on licencing wind farms in the Dutch part of the EEZ. Special attention is paid to environmental impacts of wind aprks, also in acummulation with foreign wind parks and safety for shipping."
Parish Councils
Cawston Parish Council
"Traffic In Cawston We have concerns regarding the traffic impact through the village of Cawston. This relates to the fact that the B1145 through Cawston does not appear to have been fully assessed and therefore the sensitivity the village has not been addressed and appropriately mitigated. We also have concerns with regards properties adjacent to the B1145 and request further consideration is made of these. In particular, we feel that the impact of increased traffic movements on buildings, infrastructure, underground services, the environment and road safety, has not been given adequate consideration."
Parish Councils
Oulton Parish Council
"Oulton Parish Council (OPC) have an interest in the Examination of the Norfolk Boreas application, as the cable route, Cable Logistic Area and access routes will impact the residents and businesses of Oulton. Norfolk Boreas will form a continuation of work to be carried out by Norfolk Vanguard if granted a DCO by the Secretary of State, or a separate project if Vanguard does not progress. In both scenarios OPC need to be able to comment on any proposals or changes during the Examination process. The need to participate in the Norfolk Boreas Examination process is essential, as OPC has previously been fully engaged with Vattenfall in working party meetings and throughout the Examination process for Norfolk Vanguard, and would wish to continue doing so. Oulton, along with Cawston, is also in the unusual position of being significantly affected by the cumulative impact from Orsted Hornsea Three who, if granted their DCO, require their Main Construction Compound in Oulton and will be sharing the same access routes as Norfolk Vanguard and Norfolk Boreas during potentially the same time frame. Oulton Parish Council therefore continues to have substantial concerns about the impacts of increased traffic (especially of HGVs and low-loaders), noise and light, long working hours, and the cumulative impact with Hornsea Project Three."
Members of the Public/Businesses
Polly Brockis
"The proposed traffic corridor for installation of the wind farm cabling runs directly through the centre of our village, passing many sensitive receptors including the primary school, listed properties, the village graveyard and numerous businesses. This historic village is on an old undulating road with hairpin bends, restrictive width and lack of pavements. The corner of my house is actually on the edge of the road, there is no pathway outside our home to offer minimal distance between vehicles and our listed property. Proposals to restrict road width outside our home by making the opposite pathway wider, and therefore enforcing a one way at a time traffic flow will have a significant impact on how we can exit/ enter our property and closeness of vehicles to us. My concerns are mainly ( but not limited to) 1. The stability and safety of my home with consistent heavy traffic passing 2. The safety of my children, and all those along the High Street to move through the village with the proposed traffic levels and the associated noise/ pollution rise. 3. The effect this corridor will have on the whole village - bisecting it, restricting access to current amenities, reducing parking and stopping points which will impact on businesses and residential properties. 4. The cumulation of all of the above blighting our village. 5. Have ALL alternative routes been scoped? 6. Has the possibility of an off shore ring main infrastructure been fully explored?"
Members of the Public/Businesses
The Monk Family
"The planned cable route construction project will drive large volumes of traffic along the B1145 through Cawston village. This will have a devastating effect in a Conservation Area, including serious safety issues, impact on public health, the viability of local businesses and potential damage to property. The road is simply unsuitable for the proposed traffic. Alternative approaches are available but have not been properly considered. We support renewable energy initiatives in principle but feel that this should not be at the cost of riding roughshod over local communities."
Members of the Public/Businesses
N2RS (No to Relay Stations) (N2RS (No to Relay Stations))
"I am a member of N2RS which campaigns for HVDC and on the broad, related issues of environmental impact in relation to the Norfolk Boreas and Norfolk Vanguard projects. Along with other members, N2RS will be engaged in the planning process as active attendees where appropriate and relevant. Other members of N2RS will will also be registering. Katie Taylor NORFOLK BOREAS N2RS (No to Relay Stations) is a local community action group established in April 2017 amidst concerns about the onshore infrastructure initially proposed to support Norfolk Vanguard and its sister project Norfolk Boreas - which are destined to have certain shared infrastructure and are therefore inextricably linked. Back then our communities faced the prospect of Vattenfall adopting an HVAC transmission system, which would have required cable relay stations near the coast and a 100 m wide cable corridor with significant and unacceptable impact on our homes, businesses (especially those concerned with tourism), landscape and wildlife. Although recognising the need for renewable energy and generally supportive of offshore wind N2RS were among the many voices campaigning for Vattenfall to commit to the more environmentally friendly HVDC transmission system. Following intense lobbying throughout the informal and formal consultations, Vattenfall responded to public opinion and to commercial challenges by making an unequivocal commitment to HVDC prior to the start of the PINS examination. This was warmly welcomed and it undoubtedly removed a great deal of opposition and shaped the extent and nature of public engagement from then on. Our group’s involvement in the PINS examination of Norfolk Vanguard was therefore to ensure that there would be no deviation from this important commitment and N2RS was amongst those, including the North Norfolk District Council (NNDC) and the Campaign to Protect Rural England (CPRE), who sought and received repeated and robust assurances on this subject. Vattenfall has always maintained that there would be advantages – both commercial and locally – to sharing infrastructure between Norfolk Vanguard and Norfolk Boreas and the company has confirmed that the HVDC transmission system relates to both ventures. Given that the plans before the Panel will not include a contentious HVAC transmission system, N2RS may not need to make further representations but we wish to have the opportunity to do so if necessary. Most importantly, we wish to emphasise and reinforce the significance of HVDC in this venture and to ensure the Panel is aware that the broad acceptability of Norfolk Boreas to many parties (as was the case for Norfolk Vanguard) is completely dependent on the adoption of HVDC. N2RS – which has around 1000 supporters - was always set up as a single-issue group focusing on the transmission system. Although the group shares the commonly held view that the adoption of the right technology is a key mitigator, it is also appreciated that certain communities will be expected to bear the brunt of the onshore infrastructure still required as well as the disruption caused by construction work. We empathise with those communities and still harbour concerns that the planning process cannot, in its current form, give a true picture of the impact of multiple projects, which are in various stages of planning - let alone those which are yet to be announced but appear to be on the horizon. The ultimate cost to our region should not be underestimated. Beverley Wigg Communications, N2RS [Redacted]"
Members of the Public/Businesses
Public Health England
"Thank you for your consultation regarding the above development. Public Health England (PHE) welcomes the opportunity to comment on your proposals at this stage of the project. We replied to earlier consultations as listed below and this response should be read in conjunction with that earlier correspondence. Request for Scoping Opinion 24/05/2018 Section 42 07/12/2018 We have no additional comments to make at this stage and can confirm that we have chosen not to register an interest with the Planning Inspectorate on this occasion. Should you have any questions or concerns please do not hesitate to contact us."
Other Statutory Consultees
Historic England
"Historic England (retaining the formal title of the Historic Buildings and Monuments Commission for England) is the government service championing England’s heritage and giving expert, constructive advice. We summarise our representation regarding this proposed project as follows: 1. The Applicant (Vattenfall) has explained that this proposed development should be preceded by Vattenfall’s Norfolk Vanguard’s development (presently subject to determination by Secretary of State). We understand that these two offshore wind farms are located near to each other and that both intend to connect to the Necton National Grid Substation (Norfolk). It is also understood that should Vattenfall’s Norfolk Vanguard secure the necessary consent that the transmission infrastructure for the two projects would be led by Norfolk Vanguard whereby enabling works for both projects to occur at the same time. 2. The archaeological assessments completed to date for this proposed development have revealed prehistoric landscape features and there is high potential for materials of archaeological interest to survive in-situ. We also provide notification that a historic wreck site identified within the proposed project development boundary 'Xanthe' (see ES Chapter 17 – Offshore and Intertidal Archaeology and Cultural Heritage) is now subject to consideration by Historic England, on behalf of Secretary of State for Digital, Culture, Media and Sport, to determine whether this heritage asset has national importance. 3. The proposed archaeological mitigation programme set out in the submitted DCO application should enable any subsequent programmes for survey data acquisition, use of avoidance measures and analysis post-consent to be delivered in accordance with an archaeological Written Scheme of Investigation (WSI), as informed by an Outline WSI: Archaeology and Cultural Heritage (Offshore) (DCO Document 8.6) submitted as part of the DCO application. 4. The assessment of cumulative impact to both potential heritage assets and to the setting of heritage assets and historic seascape character identifies a number of relevant matters, in particular how such matters are considered project-by-project. A key factor is how the accumulation of information derived from development-led archaeological assessments might increase knowledge and understanding. It is therefore noted that the Applicant offers the commitment to make data generated available in support of a strategic study. A key aspect of a viable mitigation programme is therefore the satisfactory completion of archaeological analysis programmes, within defined time periods, to accepted professional standards with publication and access through public archives. 5. Archaeological matters in relation to the on-shore cable route from the landfall to the proposed electricity substation location will also have been covered by Vattenfall’s Norfolk Vanguard project. Any variation to the archaeological programme arising from the Boreas scheme will be considered by the Local Authority’s specialist archaeological advisor and Historic England as appropriate. 6. The impact of the sub-station upon the setting of designated heritage assets has also been discussed with regards to Vattenfall’s Norfolk Vanguard’s scheme and there are no further matters arising with regards to this application."
Members of the Public/Businesses
Helen Savage
"I would like to put in my opinion regarding the Vattenfall wind farm in Norfolk. I am a resident at Cawston. The wind farm lorries will cause disruption, noise and pollution to our small village. The lorries will pass directly outside my home I share with two small children. We currently have lorries coming pass to service the winery and this causes the house to rattle and shake, which is very upsetting for the children. I walk the children during the week to the school. The lorries will cause safety concerns for crossing the road. I would like for it be noted that I strongly disagree to the lorries coming through the village and would like for you to consider an alternative route for the lorries. Kind regards Miss H Savage"
Other Statutory Consultees
Cadent Gas Limited
"Representation by Cadent Gas Limited (Cadent) to the Norfolk Boreas Offshore Wind Farm DCO Cadent is a licensed gas transporter under the Gas Act 1986, with a statutory responsibility to operate and maintain the gas distribution networks in North London, Central and North West England. Cadent’s primary duties are to operate, maintain and develop its networks in an economic, efficient and coordinated way. Cadent wishes to make a relevant representation to the Norfolk Boreas DCO in order to protect its position in light of infrastructure which is within or in close proximity to the proposed DCO boundary. Cadent’s rights to retain its apparatus in situ and rights of access to inspect, maintain, renew and repair such apparatus located within or in close proximity to the order limits including should be maintained at all times and access to inspect such apparatus must not be restricted. The documentation and plans submitted for the above proposed scheme have been reviewed in relation to impacts on Cadent’s existing apparatus located within this area, and Cadent has identified that it will require adequate protective provisions to be included within the DCO to ensure that its apparatus and land interests are adequately protected and to include compliance with relevant safety standards. Cadent has intermediate and high pressure (major accident hazard) gas pipelines and associated below or above ground apparatus located within the order limits which are affected by works proposed. As a responsible statutory undertaker, Cadent’s primary concern is to meet its statutory obligations and ensure that any development does not impact in any adverse way upon those statutory obligations. Cadent is discussing a form of protective provisions with the promoter based on those agreed in relation to the Norfolk Vanguard DCO and hopes to reach agreement shortly. Cadent wishes to reserve the right to make further representations as part of the examination process but in the meantime will continue negotiations with the promoter with a view to reaching a satisfactory agreement."
Other Statutory Consultees
Highways England
"HIGHWAYS ENGLAND (“we”) has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the Strategic Road Network (SRN). The SRN is a critical national asset and as such we work to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity. We like to get involved for any transport assessment hearing or session, where A47, the part of strategic road network, is involved either with construction traffic or HGV movements."
Members of the Public/Businesses
Vanessa Long
"As a resident of Ivy Todd, I'm concerned at the large scale infrastructure being proposed so close to the village of Necton. We already have the Necton National Grid Substation and are awaiting the decision from the planning inspectorate on the Vattenfall application. All the same issues outlined in the previous planning applications still apply to the next phase of the development the Boreas planning application. The main point being the over development of the site, when more suitable locations exist within Norfolk."
Members of the Public/Businesses
Alison Shaw
"I am a resident of Oulton Street, Oulton, in Norfolk. I am also a parish councillor, but I wish to be registered as an Interested Party in my own right, so that I can make representations on my own behalf, if necessary or appropriate during the Examination process. I have significant concerns about the impact of the construction of the onshore cable route for Norfolk Boreas, especially in the event that Norfolk Vanguard does not go ahead. As the developer is siting not only a major Mobilisation Area in Oulton, but also the Cable Logistics Area (CLA) for the entire project, my concerns centre around a massive increase in HGV traffic, long working hours (including overnight), noise, lights, and low-loader deliveries to the CLA. I also have major concerns about the effect on me, my family and my community of the cumulative impact of the fact that Orsted's Hornsea Project Three is also siting in our village its Main Construction Compound, which will be operating over the same time period as Norfolk Boreas. Hornsea Three will have a devastating impact on the quality of life of local residents for a period of anything up to 8 years."
Local Authorities
response has attachments
Broadland District Council
"We will be commenting on the onshore elements of the proposal including the onshore cumulative impacts as a result of the previous proposals for the separate Hornsea Three and Norfolk Vanguard offshore wind farm projects. The District Council will be submitting comments at all stages of the examination process in respect of Ground Conditions & Contamination, Land use & Agriculture, Noise & Vibration, Air Quality, Human Health, Cultural Heritage, Landscape & Visual Impact, Tourism & Recreation and Socio-economics. The other onshore elements of the proposals will be considered by Norfolk County Council. Issues of particular concern at this initial stage are the cumulative impacts of construction traffic on the villages of Oulton and Cawston and their surrounding areas; the visual and environmental impacts of the respective cable corridors crossing at a point north of Reepham and the visual and environmental impacts of the proposed hedgerow and tree removals along the cable corridor."
Members of the Public/Businesses
Tony Barnett
"The proposal is fundamentally flawed with regard to its method of assessing health and welfare impacts. My detailed representation will do the following: (1) present a methodological critique; (2) discuss the evidence presented with regard to human health and welfare; (3) present a point by point discussion of critical aspects of the environmental statement and its appendix; (4) provide a glossary of terms particularly with regard to the concept of disability adjusted life years."
Non-Statutory Organisations
UK Chamber of Shipping
"The UK Chamber of Shipping is the primary trade association and representative body of the UK shipping industry with some 200 members across the maritime sector. Our points in relation to the application will be focused on the impact to commercial navigation of ships and safety of life at sea of mariners, detailing the safety of navigation, environmental, and economic perspective of the UK shipping industry."
Members of the Public/Businesses
Diana Lockwood
"I wish to register as an interested party regarding Norfolk Boreas, after following VF Norfolk Vanguard DCO application. I have grave concerns for private individuals who will be forced to live in close proximity to the substations, if permission is granted. Necton is too small and is unsuitable.I have grave concerns for the future mental and physical wellbeing of these individuals who will be forced live with these monstrosities on their doorsteps. My own family will be particularly seriously affected, [Redacted] . I have grave concerns for the environment and the legacy that will inevitably be left for future generations to have to live with. There does not seem to be any research available which has studied the possible negative health issues which could arise. I have grave concerns that the substations are likely to become redundant in terms of technological progress, within their construction lifespan. When eventually the substations do become redundant, there will be permanent ugly scars swathed across the county to be lived with. Why do we need this? It is so short sighted and is just a horrendous short term plan, which has nobody's best interests at heart and will not supply enough power to close down present plants. I have grave concerns as to why an offshore ring main cannot be constructed to significantly reduce the catastrophic invasion to the land and residents lives'. I have grave concerns as to how the consultation period was handled by VF, and have first hand experience of the very unfortunate and inadequate and insulting meetings, drop ins, emails, website information and direct dialogue with VF. I cannot find any valid reasons as to why Necton was chosen as a suitable location for the world's largest substation construction. It simply is not good enough, and not adequately explained. It feels like an experiment. I have NO reason to believe in this project either personally or in terms of proof of the short and long term benefits to UK or the planet. Thank you sincerely Diana Lockwood"
Members of the Public/Businesses
Steffan Aquarone
"I intend to highlight the effects of increased vehicle movement on myself, my community and our surrounds if Norfolk Vanguard does not proceed to construction and Norfolk Boreas proceeds alone. I also intend to make representation regarding community compensation."
Members of the Public/Businesses
Clive Searson
"As the residents of [Redacted]. We would like to register our interest in this project as it is going to affect our daily lives. We are unhappy that no one has contacted us about this matter. We will be raising our objections in due course Kind regards Clive Searson"
Parish Councils
Corpusty and Saxthorpe Parish Council
"The Parish Council is very concerned about the impact on the physical and mental health of the residents in this community arising out of the increased traffic movements associated with the construction of the infrastructure."
Non-Statutory Organisations
response has attachments
Eastern Inshore Fisheries and Conservation Authority
"The role of Eastern IFCA is to “lead, champion and manage a sustainable marine environment and inshore fisheries” in our district, which extends from the Humber to Harwich, and 6 nautical miles out to sea. The proposed cable route for Norfolk Boreas Offshore Wind Farm will pass through the Eastern IFCA district. Therefore, given the potential impacts upon inshore fisheries and marine life, it is considered appropriate for Eastern IFCA to register as an Interested Party and to provide a Relevant Representation. Eastern IFCA will e-mail our Relevant Representation to the Planning Inspectorate. Within this representation, we have highlighted the need for offshore wind farm projects to be developed in a sustainable manner and have highlighted potential impacts of the proposal on harbour porpoises, Sabellaria reef, electrosensitive species and inshore fishery stakeholders. We have requested that all possible efforts are made to microsite the cable route for Norfolk Boreas around Restricted Area 36 of Eastern IFCA's proposed Marine Protected Areas Byelaw."
Members of the Public/Businesses
Jan Burley
"I would like to state that I am not opposed to off-shore windfarms. I am, however, very much against the method in which they currently connect to the National Grid. For Norfolk Vanguard and in this application Norfolk Boreas drilling under the very fragile cliffs at Happisburgh and then across arable land all the way to Necton, where huge Substations are to be built, is insane particularly as this also involves crossing over another Windfarms cables! With more and more of these off-shore windfarms being proposed it is imperative that an Off-shore Ring Main (ORM) is constructed to bring the electricity for all new windfarms ashore at an appropriate place for local connection to the Grid. In choosing Happisburgh as the Landfall site for the Vanguard and Boreas windfarms Vattenfall have taken the information in the “Shoreline Management Plan” as gospel. This document has already been proved to be flawed with it’s expectations of erosion at Happiburgh having already been exceeded. Vattenfall have refused to listen to any of the concerns of the residents / Parish Council in this respect."
Local Authorities
Norfolk County Council
"Norfolk County Council Comments on the Norfolk Boreas offshore Wind Farm and Onshore Supporting Infrastructure 21 August 2019 Norfolk County Council: Supports the principle of this offshore renewable energy proposal, which is consistent with national renewable energy targets and objectives, subject to: The implementation of appropriate highway; historic environment; and surface water conditions/requirements being resolved through the Development Consent Order. Overview Comments The principle of this offshore renewable energy proposal is supported as it is consistent with national renewable energy targets and objectives, subject to the detailed comments below being satisfactorily resolved with the applicant. Grid Connection and Electricity Supply Issues It is felt that Vattenfall should work with National Grid and UK Power Networks to consider options regarding the potential to feed electricity into the local transmission networks. Socio-Economic Issues The County Council welcomes the inclusion within the draft DCO of a Planning Requirement, which will ensure that a Skills and Employment Strategy is prepared. Notwithstanding this the County Council should continue to work pro-actively with Vattenfall to demonstrate the economic benefits of using the Port facilities at Great Yarmouth for: • Construction; assembly and manufacture of wind farm components; and • Operations and maintenance. The County Council should also continue to work with the applicant to develop the creation of apprenticeships; work experience and internships. Wider Community Issues and Impact on Business The County Council welcomes the commitment towards establishing some form of community benefit and would ask Vattenfall to ensure all stakeholders/communities are made aware of such funds and have the opportunity to make appropriate bids. The reduction in the potential impacts and disruption to business as a consequence of using HVDC technology is welcomed, however, it is felt that Vattenfall should commit to providing appropriate compensation for businesses and communities adversely affected by the construction works. Commercial Fishing The County welcomes the revised/amended design of the above proposal and mitigation measures set out in the applicant’s ES. However, where there is likely to be a demonstrable impact (i.e. during: construction; operation and/or decommissioning) on commercial fishing affecting communities in Norfolk, it is considered that Vattenfall should provide appropriate compensation (i.e. disturbance payments) to those fishing businesses affected. It is understood that Vattenfall are prepared to provide compensation in appropriate circumstances. Local Highways Detailed discussions and negotiations will remain on-going throughout the application process, particularly in respect of construction traffic management plans; and other travel related planning. Notwithstanding these ongoing discussions, officers have assessed the traffic implications arising from both scenarios. Under Scenario 1 (Norfolk Vanguard proceeding) the County Council as Highway Authority does not have any additional comments to make to those made to the Norfolk Vanguard scheme and discussed at the Examination Hearings. However, in the event of Scenario 2 and the Boreas Scheme continuing as an independent project the County Council would need to repeat the concerns/issues raised to the Norfolk Vanguard scheme. Public Health The County Council would expect detailed matters relating to construction noise and local environmental health to be addressed by the relevant District Councils. Providing the District Councils are satisfied with the proposal in relation to the above matters, the County Council would not wish to raise any public health concerns at this time. Flooding and Drainage It is noted that the maximum land take areas for the construction of the project substation and National Grid (NG)substation extension and the permanent footprint of the NG substation extension have increased, which must be accounted for in any drainage calculations. It is also noted at for trenched crossing locations the cable will be buried a minimum of 1.5m below the bed level, as opposed to 2m in the trenchless crossing scenarios. Clarification of this minimum depth is required. It should be noted that where the proposals involve works to any ordinary watercourse (temporary or permanent) a consent will be required. The number of these, where applicable, should be determined and applications for block, or phased consents should be made to the appropriate authority, including the flood and water management team at Norfolk County Council or the Internal Drainage Board. Also, a number of access routes will need to cross existing ditches and watercourses and environmental permits and consents are likely to be required for each crossing point. All issues previously raised in the comments sent to the applicant in respect of the pre-application consultation in November 2018 still apply. All the above matters should be addressed by the applicant and covered through appropriate Planning Conditions / Requirements. It is understood that as part of the submitted DCO, Planning Requirements are set out which would enable the above matters to be resolved post consent through: (a) An agreed Operational Drainage Plan to be agreed with the County Council as LLFA and the Environment Agency; (b) Code of Construction Practice with specific reference to surface water drainage; and (c) Water Course Crossing requirements. Subject to the inclusion of these Requirements in the final DCO, the County Council does not have any objection to the proposal in terms of surface water drainage matters. Local Member Comments Response from Cllr Seward (North Walsham East Division): My comments are confined to that part of the application that goes through my North Walsham East Division i.e. from Happisburgh (where the cable pipeline comes onshore) to North Walsham. My comments reflect what I already submitted on the previous Vanguard application. The site south of Happisburgh village where the landfall takes place for both Vanguard and Boreas is in an area where there is ongoing and significant cliff erosion. There are no sea defences in place and none are planned. Vattenfall’s response to date has been that the cabling under the Cliffs is deep enough and the site where the cabling reaches the surface is far enough back from the cliffs to prevent any of it being disturbed by cliff erosion. This is unproven. There should be a Planning condition that appropriate sea defences are erected to protect the relevant cliffs from erosion. My understanding is that the laying of the cables for Boreas is in pipe work installed for Vanguard. There will however, still be some disruption to communities whilst this work is carried out. Hence there should be a contribution for ‘community benefits."
Members of the Public/Businesses
response has attachments
Paul King
"Please see attached."
Members of the Public/Businesses
Norma Albinson
"I live close to the fragile cliffs that Boras are planning to drill underneath and then apparently laying cables all the way to Necton despite what they claim this will endanger property, people's livelihoods and miles of untouched countryside. There is also lots of publicity recently about renewable energy not being as " green" as is claimed.. I ask respectfully you reject these plans"
Non-Statutory Organisations
The Wildlife Trusts
"Introduction: The Wildlife Trusts (TWT), with more than 800,000 members, is the largest UK voluntary organisation dedicated to conserving the full range of the UK’s habitats and species. TWT has engaged in the Norfolk Boreas Marine Mammals Expert Topic Group and as such, this representation mainly focuses on marine mammals. Comments on the Norfolk Boreas application: TWT has concerns regarding the impact of underwater noise from construction on marine mammals. In particular, we are concerned about cumulative underwater noise disturbance impacts on the harbour porpoise North Sea Management Unit and in-combination disturbance within the Southern North Sea SAC. - Assessment methodology Underwater noise management in the Southern North Sea SAC: Although we welcome that progress has been made on the assessment of underwater noise disturbance within the Southern North Sea SAC, TWT still has concerns regarding the proposed SNCB advice. The science underpinning the advice is weak and we believe the proposed approach will be difficult to deliver. Inclusion of fishing in all cumulative/in-combination assessments: Fishing has not been included in any cumulative/in-combination assessments within any chapters of the Norfolk Boreas application. As a principle, fishing should not be considered in any assessments as part of the baseline. It is a licensable ongoing activity that has the potential to have an adverse impact on the marine environment. This is supported in the leading case C-127/02 Waddenzee [2004] ECR I-7405, the CJEU held at para. 6. In addition, Defra policy requires existing and potential fishing operations to be managed in line with Article 6 of the Habitats Directive. This approach further supports that fishing is considered a plan or a project and therefore must be included in the in-combination assessment in line with Article 6(3) of the Habitats Directive. Following the commencement of judicial review proceedings by TWT against Dogger Bank offshore Wind farms, TWT was given assurances that fishing would be included in future offshore wind farm assessments. We have raised this issue with the Planning Inspectorate over several planning applications (Hornsea 3, Norfolk Vanguard) and have also raised the issue with Defra and BEIS. We make this case for all MPAs assessed in this application. - Assessment outcomes Marine mammals chapter: harbour porpoise: The cumulative impact assessment outlines in table 8.55 that between 14,043 – 16,579 harbour porpoise could be disturbed due to underwater noise impacts. This equates to 4 to 4.8% of the harbour porpoise Management Unit, which is of concern to TWT. Mitigation is required and as the impacts directly overlap with the Southern North Sea SAC, we agree that this can be delivered through the Site Integrity Plan (SIP). Southern North Sea SAC: TWT agrees that mitigation is required to ensure no adverse effect on the Southern North Sea SAC from underwater noise impacts. We are pleased that the applicant has committed to the production of a SIP and Marine Mammal Mitigation Protocol (MMMP) for piling. We are also pleased that the applicant has committed to a MMMP for UXO clearance post consent and that mitigation for UXO clearance has been considered in the SIP. There are a number of outstanding issues which means that TWT cannot conclude for the Norfolk Boreas application that there will be no adverse effect beyond reasonable scientific doubt on the Southern North Sea SAC. Firstly, the SIP lacks detail and therefore in its current form it is not adequate. More detail should be provided on the effectiveness of the proposed mitigation as outlined in the SIP. This should include referenced examples of how the implementation of mitigation will reduce underwater noise disturbance impacts within the Southern North Sea SAC. Noise modelling should also be undertaken to demonstrate the degree of noise reduction which could be achieved through mitigation. Secondly, we cannot conclude no adverse effect on the Southern North Sea SAC due to the lack of regulatory mechanism to manage in-combination underwater noise impacts. Defra and the Southern North Sea Regulators Working Group are taking positive steps to develop effective management for in-combination underwater noise impacts and TWT will continue to work closely with all stakeholders on this. However, as management mechanisms are currently not in place, we suggest the Planning Inspectorate and the Secretary of State considers what controls need to be put in place to ensure no adverse effect on the Southern North Sea SAC at this current time. - Development Consent Order – UXO clearance: We welcome that the Applicant has made reference to UXO clearance in the SIP and that a licence to undertake this activity will be applied for post-consent. However. UXO clearance is almost certain to take place post-consent and has the potential to cause an adverse effect on the Southern North Sea SAC without mitigation. Table 8.11 in the Information to Support the Habitats Regulations Assessment shows that PTS impacts could be up to 14.4km and currently there is little evidence to support the effectiveness of mitigation. To ensure site integrity, conditions analogous to those included for piling impacts should be included in the Development Consent Order for UXO clearance. In line with this, a draft MMMP for UXO clearance should be produced. It should also be made explicit in the SIP that the document is required to mitigate against in-combination impacts from both piling and UXO clearance. - Monitoring – Southern North Sea SAC There is a great deal of uncertainty regarding the impacts of underwater noise on harbour porpoise in UK waters; very few studies have been undertaken. Current monitoring included in Development Consent Orders for offshore wind farms is not fit for purpose to provide adequate information to confirm the effectiveness of mitigation methods. To provide more confidence, TWT recommends that all offshore wind farm developments should contribute funding and participate in the delivery of strategic monitoring. Developers all agree that a strategic approach to monitoring is the most effective approach but consistently highlight that a mechanism for delivery is lacking. - Post-consent engagement: TWT values the relationship developed with applicants during the pre-application stage. Due to the uncertainties regarding marine mammal mitigation and monitoring at examination, we wish to be named on any associated documents for consultation post-consent including MMMPs and Marine Mammal Monitoring Plans. We welcome being named in the SIP but request to be consulted rather than just be provided information throughout the development of the document post-consent. - Conclusions: TWT welcomes that significant progress has taken place over the past few months on underwater noise management in the Southern North Sea SAC. However, as a regulatory mechanism is still not in place to manage the in-combination effects of underwater noise disturbance impacts, we cannot agree that there will be no adverse effect on the Southern North Sea SAC. We appreciate that the development of the regulatory mechanism is outside the control of this examination, but we urge the Planning Inspectorate and Secretary of State to consider the risk associated with the lack of current management in the final decision and what extra controls can be put in place to ensure no adverse effect on the Southern North Sea SAC."
Parish Councils
No name provided on behalf of East Ruston Parish Council
"East Ruston Parish Council was actively involved in the Vanguard and Boreas consultations and like most people in this area, we were extremely concerned about the infrastructure and width of the cable route which would have been needed if an HVAC (ie worst scenario) transmission system were to be adopted. We therefore welcomed Vattenfall’s early commitment to HVDC and felt that this was the best outcome which would create the least impact on local homes, businesses and environment. We would like to register as an interested party and would strongly oppose any suggestion that there could be a reversal to HVDC"
Members of the Public/Businesses
response has attachments
George Freeman MP
"I am writing to formally place on record my strong opposition to the application, in its current form, by Norfolk Boreas Ltd (on behalf of Vattenfall UK) to build the Norfolk Boreas Offshore Wind Farm. This follows my previous opposition to the application’s sister project, the Norfolk Vanguard Offshore Wind Farm, and I would request that all of my submissions then are taken into account now – as all the points raised become even more relevant with this second application. I continue to agree with the widespread assessment of the local community, along with their legal representation, that the pre-application community consultation has been inadequate and in places deliberately misleading. Designed to illustrate the proposed development from the most forgiving aspects, the visual representations, some of which contained significant inaccuracies, have been surrounded by complaint and confusion. The true scale of the proposals has not been sufficiently explained to locals, and attempts (by myself and others) to obtain more accurate information has been met with resistance – even after the decision (late in the day) to commit to HVDC rather than HVAC, and the serious implications of that. The applicant has merely stated that they have complied with legislation. In this vein, when any detailed queries/concerns about the proposals have been raised by locals, a generic set of FAQ style answers have, for the most part, been issued to answer them. My office and I have received similar treatment and, therefore, hugely sympathise with the belief that Vattenfall UK (both Norfolk Vanguard Ltd previously and Norfolk Boreas Ltd now) have paid little serious attention, if any, to the views and concerns of councillors, residents and businesses in Necton or the surrounding communities – instead providing deliberately vague and inadequate answers and information, and relying on their belief that the application will be ‘waived’ through irrespective of local opinion because of its national significance. This is of course not acceptable. You will be aware that I am not at all opposed to the location of the substation in Mid Norfolk – simply the siting. The decision to proceed with the site in question seems to be the result of an arbitrary selection process. Even when asked by myself, the applicant has been unable and/or unwilling to explain the reasons this site was favoured over others (including one nearby that was put forward by the local community themselves). They have instead referred me to their lawyers, who have simply stated that a process to determine the siting has indeed been carried out. Had proper consultation taken place, it would have become known very quickly that this site is completely inappropriate – situated on some of the highest land in the county and overlooking a number of settlements. The commitment to HVDC will further exacerbate the already significant visual impact of placing the development at this location, involving much larger structures approximately 25m in height. In addition, the site was the location of an F-16 fighter jet crash back in 1996 and there is a chance that hazardous, and potentially radioactive, substances may still contaminate the land today – despite a major military clean-up operation at the time. Construction could well disturb any remaining contaminants. All of this would further suggest that Vattenfall consider the consultation a simple ‘box-checking’ exercise for which they must go through the motions – never seriously taking into account the views and concerns of local communities. As we have consistently made clear, neither I nor the people of Necton and the surrounding villages are opposed to the principle of offshore wind energy or the necessary infrastructure to bring it onshore. However, we believe the community should be given a proper voice to help site and screen it correctly. (Indeed, I have consistently sought to lead efforts with them to broker an arrangement that all parties can support – as I did with the substation for the Dudgeon Offshore Wind Farm). Instead, this shambolic consultation has culminated in a wholly inappropriate set of proposals coming before the Inspectorate, and deepened anger and disillusionment from local councillors, councils and the community at the seeming lack of enforcement by the Planning Inspector of proper consultation. I look forward to submitting my more comprehensive Written Representation in due course."
Members of the Public/Businesses
James Smith
"As a resident of Happisburgh within close proximity to the HGV route and who regularly uses footpaths around the Happisburgh beach and cliff areas, including the proposed temporary construction site, I would like to register as an interested party. I am largely supportive of the proposals and believe, particularly for those living in an area most vulnerable to rising sea levels, generating sustainable energy and infrastructure is essential in the UK. I would like to lend a voice to those in the affected local communities who do support the project, despite some short-term disruption to us."
Non-Statutory Organisations
National Farmers Union
"IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019."
Other Statutory Consultees
The Crown Estate
"The Crown Estate manages property and rights which are owned by Her Majesty in right of the Crown. This portfolio includes around half of the foreshore and almost the entire seabed out to 12 nautical miles around the UK. Under the Energy Act 2004 and the Energy Act 2008, The Crown Estate also manages the rights over the continental shelf to offshore energy generation and the rights to carbon dioxide and natural gas storage and transportation (respectively). The Crown Estate requests to be registered as an Interested Party in the examination of the Norfolk Boreas offshore windfarm. Our interest in the project is that Norfolk Boreas Limited holds an Agreement for Lease from The Crown Estate for the area of seabed to be occupied by the project, and (subject to obtaining the necessary development consents) The Crown Estate will issue a lease to Norfolk Boreas Limited for construction of the project. We therefore wish to follow the progress of examination of the project."
Non-Statutory Organisations
CPRE Norfolk
"CPRE Norfolk is a county branch of the Campaign to Protect Rural England. As such it has been involved throughout the application process for Vattenfall’s Norfolk Vanguard proposals, and given that much of the infrastructure for both Norfolk Vanguard and Norfolk Boreas is to be shared, it is likely that the majority of CPRE Norfolk’s concerns will be addressed by the assurances that an HVDC transmission will be used for both projects. CPRE Norfolk has a clear preference for the use of HVDC as it sees this as a significantly less environmentally harmful system than HVAC, along with HVDC having less harmful impacts on the countryside. However, concerns remain as to what would happen if there are issues with the provision of a HVDC system for example due to problems with the supply chain for HVDC equipment, or HVDC technology. CPRE Norfolk seeks reassurances that if the current application is approved then it would not be possible for a change to a HVAC system without a new application for development consent being submitted to the Planning Inspectorate. In particular, the harmful impacts on landscape, environment and ecology would be much greater if an HVAC system were to be used due to the need for a wider cabling corridor and its associated construction works, and for a cable-relay station(s) on a greenfield site. In addition, CPRE Norfolk is very concerned about the potential impacts on residents and countryside: from the impacts of transport movements during the construction phase, particularly in and around Cawston; the harmful impacts of further construction of substations at Necton; the potential for contamination of chalk rivers and ponds in North Norfolk. CPRE Norfolk also notes, although this is outside the scope of this application, the disappointing lack of long-term planning that could have led to the construction of an offshore ring main, which would have made such multiple onshore cable corridors largely unnecessary, along with the resultant lack of high levels of disruption and potential harmful impacts to residents and countryside."
Members of the Public/Businesses
Glenn Berry
"I have concerns as the cable route is next to my property and the works could effect my business and home . I am also a resident of Happisburgh and I am concerned about any detrimental effect land fall may have on the village and people of Happisburgh given this village's record of erosion."
Parish Councils
Happisburgh Parish Council
"Happisburgh PC has the same concerns with Boreas as it has with Vanguard that is landfall is proposed on a coast that is internationally known to be suffering from major erosion and as one of the most faigel peasul of coast in the world. Happisburgh has just had a visit from the Climate Change Select Committee . Vattenfall state in their application the method of landfall as Horizontal Direction Drilling which is a open slurry circuit this could have the potential to blow out which could have a catastrophic and detrimental effect on Happisburgh. The only surveys so far for the drilling have been a few test bores of 18mtrs on the cliff top ,none on the beach or offshore. Happisburgh PC also has concerns with Works Traffic ,Working hours, and Damage to the local economy."
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mr Charles Sayer
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mr Cubit Siely
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mrs C B Hart
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Other Statutory Consultees
National Grid Electricity Transmission & National Grid Gas
"Representation by National Grid Gas Plc and National Grid Electricity Transmission Plc (together “National Grid”) to the Norfolk Boreas Offshore Wind Farm Order (“the Project”) National Grid wishes to make a relevant representation to the Project in order to protect its position in relation to infrastructure and land which is within or in close proximity to the proposed Order Limits. National Grid’s rights to retain its apparatus in situ and rights of access to inspect, maintain, renew and repair such apparatus located within or in close proximity to the Order limits should be maintained at all times and access to inspect and maintain such apparatus must not be restricted. The documentation and plans submitted for the above proposed scheme have been reviewed in relation to impacts on National Grid’s existing and apparatus and land interests located within this area, and National Grid will require protective provisions to be included within the DCO to ensure that its interests are adequately protected and to ensure compliance with relevant safety standards. National Grid Electricity Transmission National Grid Electricity Transmission has a high voltage electricity overhead transmission line and a high voltage substation within the onshore scoping area. The overhead line and substation form an essential part of the electricity transmission network in England and Wales. • 4VV (400kV) overhead line route - Norwich Main to Walpole 1 - Norwich Main to Walpole 2 • Necton (400kV) Substation National Grid Gas Transmission National Grid Gas has high pressure gas transmission pipelines and associated apparatus located within or in close proximity to the onshore scoping area. The transmission pipelines form an essential part of the gas transmission network in England, Wales and Scotland: Gas Transmission Pipelines: • Feeder Main 02 - Bacton to Wisbech Nene West • Feeder Main 03 - Bacton to Roudham Heath • Feeder Main 05 - Bacton to Yelverton As a responsible statutory undertaker, National Grid’s primary concern is to meet its statutory obligations and ensure that any development does not impact in any adverse way upon those statutory obligations. National Grid reserves the right to make further representations as part of the examination process but in the meantime is negotiating with the promoter with a view to reaching a satisfactory agreement."
Members of the Public/Businesses
Peter Soldan
"I live in Ridlington, less than 500 Metres from the proposed site for the Mobility Area, (11), on Happisburgh Road. I support the development of renewable energy to replace the use of fossil fuels. We are clearly consuming fossil fuels, formed over many millions of years, far too rapidly. Such development should use the approach with least negative impact on the environment. Vattenfall took a major step in this direction by discarding HVAC and adopting HVDC for power transmission from the wind farm to the National Grid. By removing the need for Relay Stations and reducing the number of cables to be installed from 36 to 8, this will reduce the operational and construction impact on North Norfolk and the Coastal/Countryside area very significantly. Very many residents were grateful and relieved when Vattenfall made this decision prior to the Vanguard DCO Submission. My primary areas of concern are: 1) The project (Vanguard and/or Boreas) should not be allowed to reverse the adoption of the HVDC transmission decision without a resubmission of the project to the Planning Process, including the Formal Consultation phase. For many Norfolk residents our representations would be very different if there was a possibility of an HVAC solution being adopted. Vattenfall have removed a very large number of objectors from this planning process by adopting the HVDC solution. This was obvious in the Vanguard Formal Consultation but not in the Boreas Formal Consultation. 2) The level of both HGV and construction traffic associated with the Duct Installation phase of the project and its impact on roads/villages which are not suited to this level of use. 3) The positioning and operation of the Mobility Area (11) on the Happisburgh Road east of Ridlington: a) The MA should only be used during the duct installation phase, b) security should be via passive sensors and cctv not illumination, to avoid the impact on local residents and wildlife (bats, owls etc) c) and it should be positioned much closer to the B1159 to reduce the impact on the Happisburgh Road which is not suited to 2-way HGV traffic. 4) The land fall should not be at Happisburgh without protection from further coastal erosion. The rate of erosion is such that the cables will be exposed during the wind farm lifetime and the jointing box will need to be protected. Better land fall options, with coastal defences, were rejected earlier because it was claimed they could not accommodate the HVAC requirements. With regard to Mobility Area (11), Vattenfall, at a meeting in the Witton and Ridlington village hall, stated that traffic would not be allowed to go through Ridlington village. We need to know what measures will be applied to ensure construction traffic is kept out of the village. Contractors/drivers may approach/depart through Ridlington village when Happisburgh Road becomes congested. This Mobility Area should be closer to the B1159 and access should be either direct from the B1159 or via the Running Road from the B1159, not via Happisburgh Road."
Non-Statutory Organisations
RSPB
"Norfolk Boreas Offshore Windfarm Development Consent Order Application Planning Inspectorate Reference: EN010087 Relevant Representation from the Royal Society for the Protection of Birds (RSPB) 28 August 2019 1. Introduction The RSPB supports the deployment of renewable energy projects, providing that they are sited in appropriate places and designed to avoid potential adverse impacts on wildlife. We are grateful for the constructive pre-application discussions that have taken place with Vattenfall in respect of this proposal, particularly through the Evidence Plan process. Whilst some methodological concerns remain, progress towards resolving a number of issues was made during the pre-application discussions for this project, and the examination of its sister project, Norfolk Vanguard. However, we continue to have significant concerns relating to project’s alone, in-combination and cumulative collision risk and displacement impacts. 2. Offshore ornithology impacts These significant concerns are regarding the findings of some of the impact assessments. As a result of the methodological concerns (set out below), the RSPB considers that the impacts have not been adequately assessed. Subsequent to the position taken by Natural England and the RSPB at the end of the Norfolk Vanguard examination, we consider that adverse effects on the integrity (AEOI) of the following Special Protection Areas (SPAs) and their species cannot be avoided: • The impact of collision mortality on the kittiwake population of the Flamborough and Filey Coast SPA (FFC SPA) in-combination with other plans and projects; • The impact of collision mortality on the gannet population of the FFC SPA in-combination with other plans and projects; and • The impact of collision mortality on the lesser black-backed gull population of the Alde-Ore Estuary SPA in-combination with other projects; and • The impact of operational displacement on the razorbill population of the FFC SPA in-combination with other plans and projects; and • The impact of operational displacement on the guillemot population of the FFC SPA in-combination with other plans and projects; and • The impact of collision mortality and displacement on the breeding seabird assemblage feature of the FFC SPA in-combination with other plans and projects. We also consider that it is not currently possible to rule out AEOI of the following SPAs and their species: • The impact of collision mortality on the gannet population of the FFC SPA from this project alone; and • The impact of collision mortality on the lesser black-backed gull population of the Alde-Ore Estuary SPA from this project alone It may be possible to rule out AEOI from the project alone if the Applicant is able to propose mitigation through raising the draught height of the turbines, which reduces collision risk. However, due to the level of in-combination collision risk, this project should be refused, subject to the considerations of alternative solutions, imperative reasons of overriding public interest and the provision of compensatory measures as set out in regulations 64 and 68 of the Conservation of Habitats and Species Regulations 2017. Currently the Applicant has not submitted any evidence on these further requirements and therefore unless evidence is provided enabling full scrutiny of it as part of the examination process, these derogation tests cannot be relied upon. In addition, we consider that insufficient evidence has been provided in the Environmental Statement to rule out potential significant impacts on the following (non-SPA) North Sea populations: • Cumulative collision mortality to North Sea populations of kittiwake and great black-backed gull; and; • Cumulative operational displacement to North Sea populations of guillemot, razorbill and red-throated diver. 3. Concerns regarding the assessment of collision risk Our concerns regarding the assessment process and evidence base are outlined below. (a) Apportioning of kittiwake collision mortality to FFC SPA We have concerns about the figures used for apportioning of collision mortality to FFC SPA and the evidence used to support this. The estimated proportion of kittiwake from FFC SPA used in the HRA is 26.1%, despite a recommendation from Natural England that apportioning should be 86% during the Norfolk Vanguard examination. Notwithstanding the Applicant’s unfounded criticisms of the FAME and STAR tracking of kittiwakes, which is dealt with below, the assessment does not fully take into account more recent tracking of kittiwakes from FFC SPA carried out in 2017, using lighter tags (<3% bodyweight) and following the birds for a longer period due to a novel attachment method. We therefore do not agree with the value used for apportioning kittiwake collision mortalities to the FFC SPA as it will considerably underestimate the actual impact. We recommend adoption of Natural England’s recommendation that apportioning to the FCC SPA should be 86%. (b) Criticisms of kittiwake tracking data The Applicant raises a number of issues with regard to the suitability of tracking data obtained as part of the FAME (Future of the Atlantic Marine Environment) and STAR (Seabird Tracking and Research) projects for use in the assessment. However, the Applicant’s report contains a number of misinterpretations and erroneous assertions. In particular: • It is claimed that the longest foraging trips from FAME/STAR kittiwake data were largely from colonies where the breeding success was zero or close to zero. This is incorrect. The longest trips were recorded from Flamborough and Filey, where breeding success was comparatively high over the time of tracking. • The claim that tagged birds were more likely to have failed is also incorrect. For the FAME and STAR data, where remote download tags were used, birds had to be re-caught when on the nest so were required to be successful, at least up until the point of recapture, in order to obtain the data. • Tagging conducted in 2017 used tags that were less than 3% of the birds’ body weight and observed longer foraging ranges. (c) Gannet avoidance rate Whilst the RSPB accepts the SNCBs’ recommended amendment to the gannet avoidance rate (AR) from 98% to 98.9% for non-breeding birds, we do not agree that this figure should be applied to the breeding season due to the lack of available evidence relating to breeding birds. As acknowledged in the BTO Review the SNCB advice is drawn from , the majority of evidence for avoidance behaviour of gannet is from non-breeding birds, and breeding birds, under the constraints of central-place foraging, will behave differently and potentially be subject to greater impacts from developments . As such, we prefer and recommend a more precautionary AR of 98% for the breeding season. (d) Lack of assessment of breeding seabird assemblage feature of FFC SPA Potential impacts on the breeding seabird assemblage feature of FFC SPA have not been assessed, noting that Natural England advised that this should have been assessed for Norfolk Vanguard and concluded that AEOI cannot be ruled out. (e) Consented capacity of windfarms The Applicant refers to projects in the in-combination assessment that have been built out to a lower capacity than that consented as a source of precaution within the assessments. This is an acceptable point for windfarms where the Development Consent Order (DCO) has been amended and therefore there is legal certainty regarding the reduction. However, where windfarms still have their original DCOs and therefore the ability to construct more wind turbines, it is not appropriate to do anything less than consider the full extent of those DCOs when considering in-combination/cumulative effects. ? (f) Mitigation of collision risk through raising turbine draught height As noted above, the RSPB recommends that mitigation is provided through raising the turbine draught height for the purposes of reducing the project’s collision risk when considered alone, and its contribution to in-combination collision risk. We therefore request that collision risk to key species for height rises up to and including 35m are modelled. 4. Notes Due to resource limitations, the RSPB regrets that it may not be able to attend the issue specific hearings covering ornithological impacts, mitigation and conditions, but will confirm this with the Examining Authority once dates and agendas are available. The RSPB reserves the right to add to and/or amend its position in light of changes to or any new information submitted by the Applicant. References Joint Nature Conservation Committee (JNCC), Natural England (NE), Natural Resource Wales (NRW), Northern Ireland Environment Agency (NIEA), Scottish Natural Heritage (SNH) (2014). Joint Response from the Statutory Nature Conservation Bodies to the Marine Scotland Science Avoidance Rate Review Cook, A.S.C.P., Humphreys, E.M., Masden, E.A. & Burton, N.H.K. (2014) The Avoidance Rates of Collision between Birds and Offshore Turbines. Scottish Marine and Freshwater Science Volume 5 Number 16, Report Published by Marine Scotland Science Cook, A. S., Humphreys, E. M., Bennet, F., Masden, E. A., & Burton, N. H. (2018). Quantifying avian avoidance of offshore wind turbines: current evidence and key knowledge gaps. Marine environmental research, 140, 278-288. Masden, E. A., Haydon, D. T., Fox, A. D., & Furness, R. W. (2010). Barriers to movement: modelling energetic costs of avoiding marine wind farms amongst breeding seabirds. Marine Pollution Bulletin, 60(7), 1085-1091."
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Thomas Love
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Non-Statutory Organisations
Whale and Dolphin Conservation
"The North Sea offers a variety of rich cetacean habitats. Whilst gaps still remain in our knowledge of the cetaceans which live year round or migrate through our waters, Norfolk Boreas lies within the Southern North Sea Special Area of Conservation (SNS SAC) an area of importance for harbour porpoise. Due to its location in the SAC, it is likely that the construction of Norfolk Boreas will negatively impact the harbour porpoise population of the SAC, particularly in-combination. These impacts have the potential to be long-term. As an SAC the Southern North Sea is a strictly protected site, designated under the EC Habitats Directive, with a specific Conservation Objective of “To avoid deterioration of the habitats of the harbour porpoise or significant disturbance to the harbour porpoise, thus ensuring that the integrity of the site is maintained and the site makes an appropriate contribution to maintaining Favourable Conservation Status for the UK harbour porpoise.” (JNCC, 2017). WDC is particularly concerned about the potential for cetaceans to be disturbed and displaced, including by the noise introduced into their environment. Noise will be produced throughout the life of the development, including construction, operation and decommissioning, and from associated vessel traffic. Norfolk Boreas is likely to impact cetaceans, and the harbour porpoise population supported by the SNS SAC in ways ranging from collisions to habitat displacement due to the effects of noise and disturbance. Our concerns are particularly related to noise especially during the construction phase as this is the stage where there is the greatest potential to negatively impact cetaceans. Noise pollution has the potential to displace animals and populations, interfere with normal behaviour and, at very high intensities, be physically damaging. All cetaceans are offered ‘strict protection’ under the Habitats Directive. Research has shown that pile driving during construction causes behavioural changes in harbour porpoises which leave the area during construction and in majority instances did not later return to their usual numbers. The longest running study into the effects of windfarms on harbour porpoises shows that ten years later, the population has only recovered to 29% of the baseline level. Even where areas have been recolonised, it is not clear if these are the same animals returning or new animals moving into the area, or if the animals are using the area in the same way. Harbour porpoise feed almost continuously to meet energy needs and are therefore highly sensitive to disturbance. Loud noises, such as pile driving, can cause them to be displaced from potential important feeding grounds. Additionally harbour porpoise can lose 4% of their body weight in just 24 hours from starvation. Given the importance of the Norfolk Boreas area and the SNS SAC for harbour porpoise, most likely as prime foraging areas, displacement from the area could be very significant. The combined effects of these developments with other industries operating in the marine environment, such as shipping and oil and gas exploration, are also largely unknown. Yet it is important that cumulative and in-combination impacts be adequately considered and our understanding developed. WDC recommend for Norfolk Boreas that: • Foundations requiring piling are not used; • Further assessments are made on alternative foundations to fully understand the potential impacts on marine mammals, and prey species; • To apply effective noise-reducing measures where piles of any sort are driven."
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Albanwise Ltd
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Bradenham Hall Farms
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Church Farm (Gimingham) Ltd (Church Farm (Gimingham) Ltd)
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Non-Statutory Organisations
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Diocese of Norwich
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Dr G Cubitt
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of E H Wenn (Happisburgh) Ltd (E H Wenn (Happisburgh) Ltd)
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Eni UK Limited
"Eni UK Limited is in a joint venture that holds offshore petroleum production licences in the vicinity of the proposed wind farm. We are keen to ensure our activities interface safely with those of Vattenfall, and that the siting of any wind farm infrastructure does not have a significant adverse impact on our ability to carry out those activities."
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Farnham Farms Ltd
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of G F de Feyter & Partners
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK)Ltd (Savills (UK)Ltd) on behalf of HBSH Pension Scheme
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Heydon Estate
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of L Padulli
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Other Statutory Consultees
response has attachments
Marine Management Organisation
"Good morning, Due to the word limit in this section, please refer to the email sent on the 30 August 2019 to the following email address [email protected], for the Marine Management Organisation's relevant representation. Should you have any questions please let me know. Kind regards, Rebecca"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mr & Mrs M Jones
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mr G Anderson
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mr G Hales
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mr J Carrick
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mr Kyle White
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mr M and Mrs J Ditch
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mr M Howell
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mr P Bunting
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mr P Mutimer
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mr R Baldwin
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mrs A Green
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mrs A Jones
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mrs P Hinton
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Non-Statutory Organisations
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of National Trust
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Non-Statutory Organisations
National Trust (WITHDRAWN) (National Trust (WITHDRAWN))
"The National Trust (“the Trust”) owns the freehold of 2000 ha of land, including a Jacobean Mansion, associated buildings, farmsteads and cottages, together forming the Blickling Estate (the “Estate”), to the west of Aylsham, Norfolk. The Trust operates a major visitor based business adjacent to the proposed cable route, supporting and promoting its conservation work. Vattenfall proposes to acquire new permanent and temporary rights over land within the Estate, including a 100m wide easement through 4.5km of the Estate. In 1942, pursuant to section 21 of the National Trust Act 1907, the majority of the Estate (including the proposed easement route) was declared “inalienable”. This status enables the Trust to live up to its core charitable objective of preserving places of historic interest and natural beauty for the nation, forever. Although it appears that none of the Trust’s interests are susceptible to compulsory acquisition under the DCO, the Estate is intended to be used for the purposes of the DCO should the Trust grant the necessary rights. The Trust does not object to the principle of the Norfolk Boreas Offshore Windfarm. However we do not support proposals that would seriously damage the integrity of any archaeological remains on the Estate, or that would seriously jeopardise the ability of the visitor business to function. The National Trust has three key concerns with regard to the proposed DCO: • The impact of the proposals on the little understood archaeology of the Estate • The impact of disturbance to the highways network and the consequent effect on our visitor based business • Use of National Trust land for part of the cable corridor. Archaeology The Trust has a duty to protect our heritage and all archaeology within its care. In and around the Blickling corridor there is great potential for prehistoric ceremonial and funerary activity. Around Silvergate and Abel Heath are a number of ring-ditches (likely representing Bronze Age funerary barrow monuments and a later prehistoric ceremonial monument); and a number of other probable prehistoric trapezoidal enclosures. Adjacent to the Oulton Belt of woodland, the corridor crosses an area of linear enclosure likely to be Roman or medieval field systems and activity. Around Silvergate, there is considered to be medieval settlement evidence and where the corridor enters the Estate boundary, there is a post-medieval brick kiln. The potential impact of development on archaeological remains in the Estate is very significant for the Trust. Our preference would be for long-term preservation of buried remains. Where excavation is necessary, the National Trust would like to ensure thorough preservation by record. The National Trust would also like to secure a method to ensure that this information is made available to visitors and the community in a way that enriches their experience and understanding of the Estate. The Trust welcomes acknowledgement by Vattenfall of the importance of archaeology to the National Trust within the Outline Scheme of Written Investigation (WSI) and the provisions it makes. In order to ensure that these are reflected in the final WSI the Trust would like to be a consultee along with Norfolk County Council and Historic England as set out in Condition 23 of the Draft DCO. Business Disruption Closure of or restricting access along the road between Blickling and Aylsham should be avoided as it would likely lead to the loss of business for the Trust. Where disruption would be unavoidable, any potential visitor income loss should be underwritten by the developer. To date the Trust has not received satisfactory assurances from the developer that disruption will be minimised and where disruption cannot be minimised, adequately compensated. Cable Corridor The National Trust notes that the Book of Reference refers to National Trust land and that part of the cable corridor will cross land owned by the Trust. This land is inalienable and is therefore not subject to compulsory purchase by Vattenfall. The Trust has been working with Vattenfall to secure a signed Option Agreement and Deed of Grant of easements for cables and access which covers both the Norfolk Vanguard and Norfolk Boreas off shore windfarms. However, at the time of writing these have not been completed. Therefore, a formal agreement for the use of National Trust land for part of the cable corridor remains outstanding."
Members of the Public/Businesses
Royal Yachting Association
"The only issues that concern the RYA in relation to this application would be an application for an operational Safety zone and failure to bury export cable to a depth that impacted upon the limits set for Chart Datum by the MCA methodology."
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Trustees of Salle Park Trust
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Trustees of Stinton Hall Trust
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Trustees of WM & SJ Bulwer Long 1983 Settlement
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of William Youngs & Son (Farms) Ltd (William Youngs & Son (Farms) Ltd)
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Other Statutory Consultees
Anglian Water Services Ltd
"Thank for you the opportunity to comment on the Norfolk Boreas Offshore Windfarm project. Anglian Water is considered to be a statutory consultee for nationally significant infrastructure projects as identified in the Planning Act 2008 and associated regulations. The following representations are submitted on behalf of Anglian Water as water and sewerage undertaker for the above site: Anglian Water is in principle supportive of the above project. Impact on existing assets: There are both existing water and water recycling infrastructure in Anglian Water’s ownership within the onshore cable route. These assets are critical to enable us to carry out Anglian Water’s duty as a water and sewerage undertaker. We anticipate having further discussions with the applicant about the design of crossings of existing sewers and water mains required for the above project and the related Norfolk Vanguard project. Groundwater sources: We have been in dialogue with the applicant regarding the proposed crossings of groundwater Source Protection Zones which include public water suppliers in Anglian Water’s ownership within the onshore cable route and proposed crossing technique is appropriate subject to detailed design. The submitted application documents identify appropriate mitigation measures in relation to water resources and groundwater, subject to detailed design post consent. Protective provisions: We have previously requested the inclusion of specific wording for the benefit of Anglian Water as part of the Section 42 consultation conducted in 2018. It is noted that specific protective provisions have been included in the current version of the DCO (Schedule 17, Part 6 of the Draft DCO) as requested. Therefore we are supportive of the wording of the Draft DCO as submitted. Connections to water supply/public sewerage networks: Anglian Water is not aware of any water supply or wastewater requirements made upon them for the above project. Should a water supply or wastewater service be required and once agreement has been reached, there are a number of applications required to deliver the necessary infrastructure as outlined in the Water Industry Act 1991. Should you have any queries relating to this response please let me know."
Members of the Public/Businesses
response has attachments
Caister Inshore Fishermans Association
"Please see attached."
Members of the Public/Businesses
Bidwells on behalf of Christopher S Wright
"IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, 2 but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 5 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be 6 minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. 7 Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Cruso & Wilkin on behalf of David Perry Warnes
"IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, 2 but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 5 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be 6 minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. 7 Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Ditch Household
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Other Statutory Consultees
response has attachments
Environment Agency
"The Environment Agency is a statutory consultee on all applications for development consent orders. We have a responsibility for protecting and improving the environment, as well as contributing to sustainable development. We have three main roles: (i) We are an environmental regulator – we take a risk-based approach and target our effort to maintain and improve environmental standards and to minimise unnecessary burdens on business. We issue a range of permits and consents. (ii) We are an environmental operator – we are a national organisation that operates locally. We work with people and communities across England to protect and improve the environment in and integrated way. We provide a vital incident response capability. (iii) We are an environmental advisor – we compile and assess the best available evidence and use this to report on the state of the environment. We use our own monitoring information and that of others to inform this activity. We provide technical information and advice to national and local governments to support their roles in policy and decision-making. One of our specific functions is as a Flood Risk Management Authority. We have a general supervisory duty relating to specific flood risk management matters in respect of flood risk arising from Main Rivers or the sea. Overview and issues of concern Our relevant representation outlines where we consider further work, clarification or mitigation is required to ensure that the proposal has no detrimental impact on the environment. Due to the length of our full response, which exceeds the specified word limit, we will send this by separate email. Our main concerns are in respect of the use of horizontal directional drilling (HDD) and safeguarding of affected waterbodies, the appropriate assessment of impacts and supply of data in respect of groundwater and contaminated land as well as an observation about Protective Provisions. Our principal concern regards river crossings and in particular the use of horizontal directional drilling (HDD). Whilst this method limits disturbance to a waterbody, it is not without risks to the environment, mainly the potential damage in the event of a bentonite breakout. This is of most concern where there is a potential impact affecting (but not limited to) the River Wensum due to its status as an SAC, SSSI and priority habitat. At present, and in the light of environmental incidents occurring since we commented on the Norfolk Vanguard twin project, we do not consider that the Outline Code of Construction Practice provides sufficient detail. We consider that the applicant should prepare site specific water crossing plans and assessment. We dispute the Applicant’s classification of Chalk rivers. We have identified issues in respect of contaminated land and groundwater where we consider that further study or detail is required, supporting study made available or corrections made. We have further advice in relation to mitigation for mammals within the OLEMS. We also request that the Applicant produces a statement on how net gain for biodiversity will be achieved. Please do not hesitate to contact me if you require any further information. We look forward to continuing to work with the applicant to resolve the matters raised to achieve the best environmental outcome for the project."
Members of the Public/Businesses
Equinor UK Ltd
"As the Norfolk Boreas is planned in such close proximity to Dudgeon Offshore Windfarm related cables and substation, Equinor, as current operator of the Dudgeon Offshore Windfarm asset, is a vested stakeholder and would like to declare an interest."
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Jones Household
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mrs P Riches
"Our client's concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS OFFSHORE WIND FARM PROJECT AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Boreas Agents (agents acting for NFU members and their clients on this project.) The agents represented are Savills, Strutt & Parker, Bidwells, Irelands, Brown & Co and Cruso & Wilkin (henceforth known as the Land Interest Group (LIG) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Norfolk Boreas Offshore Wind Farm Project order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Vattenfall and their agents. Heads of terms were sent out May 2018 and some of these have been signed by landowners who are in agreement to the principles of the scheme set out. But in the last few month further specific details have been requested in regard to the build for the voluntary agreements. Negotiations are still on going. 3.0 HVDC Cables and Converter Substation 3.1 It has been clarified by Vattenfall that they have and are applying for a DCO on HVDC cables and this will involve building a converter substation. The laying of HVDC cables should hopefully reduce the impact on land operations and farm businesses as the easement width required will be less and it is likely that only a small number of link boxes will be required which are situated on the surface of the ground. 3.2 Landowners are requesting further information on the converter substation which is to be sited near to the National Grid substation at Necton. We understand that the converter station is needed to convert the current from DC back to AC to enter the National Grid substation. Further information has been requested on the size of the proposed building, the height, what the building will look like and the external cladding. It is understood that the building may be 25m high. 3.3. At the present time the plans are showing for the new converter substation to be located at the top of a hill on a very prominent site near to Necton Wood. Further to a site visit on 10th September 2018 to look at the proposed elevated site, information has been requested on why such a prominent site position has been chosen as it will be visible particularly from the south and west. 3.4 Questions have been raised as to why the converter station is not being sited nearer to the National Grid substation on land lying to the north of the existing substation. This land lies lower down and is not as visible as the proposed location. 3.5 Vattenfall has stated that they have followed the Horlock Rules when considering site selection. Screening provided by land form and existing features should be taken advantage of and this is not the case with the proposed site. 4. Construction and Funding 4.1 Landowners from the start were notified by Vattenfall that they would be looking to carry out the project as two schemes Vanguard and Boreas. Vanguard is to be constructed first, with underground cables being laid in ducts. At the same time ducts will be laid to take underground cables for the Boreas scheme. Vattenfall has stated that they will need at least 2 years to lay the ducts and cables for Vanguard. There then may be a gap of a year before the start of the Boreas scheme. Further clarification is needed from Vattenfall on timings of construction and how and when cables will be pulled for the Boreas scheme. For example will working areas just be needed for jointing bays on the Boreas scheme? Landowners do not yet understand what the interference will be from constructing Boreas following Vanguard. 4.2 We first understand from Vattenfall that they did have the funding required for both schemes but confirmation on this is sort as during the examination of the Vanguard Scheme it became apparent that funding may be through CFD. 5. Cumulative Impact 5.1 Confirmation is sort from Vattenfall on whether a Cumulative Affect Assessment has been addressed of both of their schemes Vanguard and Boreas along with the Orsted Scheme Hornsea 3 which are programmed to be constructed at approximately the same time. Hornsea 3 is running north to south and Vanguard and Boreas running east to west. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 6. Jointing bays and Link Boxes 6.1 It is understood that some link boxes will be needed with the cables being HVDC cables and further clarification is sort on how many there are likely to be and the location of the link boxes. Link boxes do stand proud above ground level and so greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that all link boxes are located within field boundaries. 7. Field Drainage 7.1 Land drainage is one of the main issues which landowners and occupiers are concerned about on this scheme and some detail has been agreed in the heads of terms and we have not yet seen the wording that we would like included in the draft CoCP for Boreas. 7.2 LIG and NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement. As yet this has not been agreed. 8. Soils 8.1 As above the treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited detail has been provided to landowners and occupiers. Again LIG and NFU would like certain wording to be agreed and highlighted in an outline soil management plan as part of the CoCP. It is important that soil reinstatement and aftercare is specified. Further information will be needed to show what measures will be put in place to bring the soil back to its condition and quality before the works took place. An after care plan should be included in a code of construction or soil management plan. 9. Flood Issues 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Therefore there is concern that retained land may flood during the construction works. 10. Dust/Irrigation/Private Water Supplies 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? Further if any private water supply is affected a temporary and permanent supply will be needed. 11. Access routes to the Order Limits 11.1 At the present time Vattenfall has provided details of access routes it would like to use to gain access to the working strip. Issues have been raised by some of the agents that some of the access routes are not actually physically possible on the ground due to differing ground levels. In some instances there are better access routes available to reach the working strip but Vattenfall as yet has not engaged in agreeing viable access routes. 12. Request to Attend Hearings and make Representations 12.1 The NFU and the Vattenfall Agents known as LIG intends to lodge full Written Representations in due course and request to make oral representations at the compulsory acquisition hearing or any other hearings which may be held. 12.2 LIG represents approximately 60 clients who own or lease land affected by the DCO. A full list of names and addresses are available if requested. The members and clients have not been listed on this representation due to data protection. Each landowner or occupier has submitted an outline representation highlighting specific issues to the business and has made reference to this outline representation which highlights the main issues of all landowners concerned. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 23rd August 2019. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK BOREAS PROJECT DEVELOPMENT CONSENT ORDER 201 [...] AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STEONLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor"
Non-Statutory Organisations
response has attachments
Natural England
"The overall position of Natural England In relation to SPAs and SACs, the assessment provisions of the Conservation of Habitats and Species Regulations 2017 (and Offshore Habitat Regulations) require that a competent authority may only agree to a plan or project of this nature after having ascertained, on the basis of an appropriate assessment, that it will not affect the integrity of the site(s). By this it is meant that such a plan or project may be granted authorisation only on the condition that the competent authority is convinced, beyond reasonable scientific doubt, that it will not adversely affect the integrity of the site(s) concerned . On the basis of information submitted, Natural England is not satisfied that it can be concluded beyond all reasonable scientific doubt that the project would not have an adverse effect on the integrity of the: • Alde-Ore Estuary SPA and Ramsar; • Flamborough & Filey Coast SPA; • Greater Wash SPA; • Outer Thames Estuary SPA; • Broadland SPA and Ramsar • Haisborough Hammond and Winterton SAC; • Southern North Sea SAC; • River Wensum SAC; • Paston Great Barn SAC; NB: Many of the terrestrial SACs listed above are underpinned by SSSIs and therefore have overlapping interest features and supporting habitats. In addition to the lack of certainty of adverse effect on the European sites listed above Natural England believes that the ES does not provide the competent authority with sufficient information to make a decision in relation to the EIA Regulations in relation to red-throated diver, gannet, kittiwake, guillemot, razorbill, puffin, herring gull, lesser black-backed gull or greater black-backed gull. Please see our email dated 30.08.2019 with the full text of our Relevant Representations and Appendices 1-6 for further details."
Other Statutory Consultees
Addleshaw Goddard LLP on behalf of Network Rail Infrastructure Limited
"This is the section 56 representation of Network Rail Infrastructure Limited (Network Rail) provided in respect of Norfolk Boreas Limited's application for a Development Consent Order (Order) which seeks powers to enable the construction of the Norfolk Boreas Offshore Wind Farm and onshore cable corridor (Scheme). Network Rail is a statutory undertaker and owns, operates and maintains the majority of the rail infrastructure of Great Britain. The Book of Reference (BoR) identifies plot 10/04 (Plot 10/04) as land owned by Network Rail in respect of which compulsory acquisition powers to acquire new rights are sought. The compulsory acquisition powers sought are described in the BoR as being the "acquisition of permanent new rights" (Compulsory Powers). Network Rail notes that the Compulsory Powers are sought in relation to operational railway land forming part of the operational railway being the Norwich to Sheringham Line. Network Rail objects to the inclusion of Plot 10/04 in the Order and to the acquisition of Compulsory Powers in respect of it. Plot 10/04 constitutes land acquired by Network Rail for the purpose of its statutory undertaking and, accordingly, this representation is made under section 56 and sections 127 and 138 of the Planning Act 2008. Network Rail considers that there is no compelling case in the public interest for the acquisition of the Compulsory Powers and Network Rail considers that the Secretary of State, in applying section 127 of the Planning Act 2008, cannot conclude that new rights and restrictions over the railway land can be created without serious detriment to Network Rail's undertaking; no other land is available to Network Rail which means that the detriment can be made good by them. Network Rail also objects to all other compulsory powers in the Order to the extent that they affect, and may be exercised in relation to, Network Rail's property and interests. In order for Network Rail to be in a position to withdraw its objection Network Rail requires: (a) agreements with the Applicant that regulate: - the manner in which rights over Plot 10/04 and any other railway property are carried out including terms which protect Network Rail's statutory undertaking and agreement that compulsory acquisition powers will not be exercised in relation to such land; and - the carrying out of works in the vicinity of the operational railway network to safeguard Network Rail's statutory undertaking. (b) the inclusion of protective provisions in the DCO for its benefit. Network Rail notes and welcomes the fact that there are protective provisions for its benefit in the Order and, if necessary, will provide detailed comments on, and amendments to, the protective provisions when it submits its detailed Written Representation. To safeguard Network Rail's interests and the safety and integrity of the operational railway, Network Rail objects to the inclusion of the Compulsory Powers and any other powers affecting Network Rail in the Order. Network Rail requests that the Examining Authority treat Network Rail as an Interested Party for the purposes of the Examination."
Local Authorities
North Norfolk District Council
"North Norfolk District Council (NNDC) has been notified by Norfolk Boreas Limited that, as of 04 July 2019, their application for Development Consent Order (DCO) in respect of Norfolk Boreas Offshore Wind Farm has been accepted for examination by the Planning Inspectorate under the Planning Act 2008. This letter forms the Relevant Representation of NNDC and sets out a summary of the issues that are considered to be relevant to the nationally significant infrastructure project as it passes through the North Norfolk district. Principle of Development On 24 April 2019, North Norfolk District Council’s Full Council agreed a motion declaring a Climate Emergency. With the motion the Council acknowledged; • The devastating impacts that climate change and global temperature increases will have on the lives and livelihoods of people around the world, including on the health, safety and wellbeing of North Norfolk residents; • The urgent need for action to be taken fast enough for there to be a chance of further climate change being limited to avoid the worst impacts of drought, floods and extreme heat; • The opportunity for individuals and organisations at all levels to take action on reducing carbon emissions, from both production and consumption; • The need to enable low carbon living across society through changes to laws, taxation, infrastructure, policies and plans; • The Council’s responsibility to help secure an environmentally sustainable future for our residents and in relation to the global effects of climate change. The Council resolved to; 1. Declare a Climate Emergency; 2. Engage and work in partnership with our partners in the public, private and community sectors, including central government to facilitate bold action to ensure North Norfolk is able to play its role in helping the UK to deliver against the commitments made nationally and internationally at the 2015 Paris Summit; 3. Prepare an Environmental Sustainability & Climate Change Strategy in line with this pledge, and, with our partners across the community, to develop an action plan and ‘route map’ to a sustainable, low carbon future for our community; 4. Launch engagement with the public to: • Improve “carbon literacy” of all citizens; • Encourage and support leadership on this issue in all sectors of society; • Obtain meaningful public input into the North Norfolk Environmental Sustainability & Climate Change Strategy and action planning; • Facilitate wide community engagement and behavioural change North Norfolk District Council is fully supportive of the principle of renewable energy development in helping to tackle the challenges faced by climate change. NNDC recognises the national importance of having a balanced supply of electrical generation including increasing renewable energy supplies from offshore turbines in helping decarbonise the UK’s energy sector. At a local level NNDC has made a significant contribution of its own through, amongst other things, the grant of planning permission for in excess of 150MW capacity of solar farms, with electrical output capable of powering over 40,000 homes, in North Norfolk. Whilst recognising the national importance of Norfolk Boreas Offshore Wind Farm (and sister Norfolk Vanguard project), North Norfolk District Council believes it is essential to ensure that key design and construction decisions do not result in unacceptable or adverse impacts on residents or businesses within North Norfolk, acknowledging the important contribution that agriculture and tourism plays in the economic prosperity of the District underpinned by the nationally and internationally recognised coast, landscape and biodiversity interests as well as significant heritage assets that help define the unique character of the area. Examination Process Throughout examination of the Norfolk Vanguard DCO, NNDC has sought to work constructively and proactively with the applicant and the Planning Inspectorate recognising the benefits of the proposal but also seeking to minimise any adverse impacts associated with the project within North Norfolk. By the close of the Norfolk Vanguard examination, many if not all of the issues raised by NNDC had or were capable of being addressed by the applicant and the Planning Inspectorate through the Development Consent Order process. NNDC recognise that, in addition to the consideration of two different scenarios outlined by the applicant dependent upon whether Norfolk Vanguard is taken forward, there are many overlapping considerations from the Norfolk Vanguard project which would also apply to Norfolk Boreas. The key issues associated with this project affecting North Norfolk include (inter alia): • Landfall methodology and ways to reduce the potential for coastal erosion; • Impacts from construction activities (including from continuous periods of operation) • Tourism Impacts - “Actual Tourism Impact of Negative Perceptions”; and • Landscape (including the need for a 10-year replacement planting period in North Norfolk) It is recognised that, at the start of the Norfolk Boreas examination, there is some catching up to do with the final positions set out for Norfolk Vanguard. NNDC would respectfully request that positions are updated by the applicant as soon as possible so as to avoid wasted effort by all parties interested in the examination. North Norfolk District Council look forward to being engaged in the examination / DCO process moving forward. Yours sincerely Geoff Lyon Major Projects Manager"
Other Statutory Consultees
Orsted
"Ørsted Wind Power A/S (Ørsted) has received notification that the Norfolk Boreas Offshore Wind Farm (Norfolk Boreas) has been accepted for examination. Please accept this as Ørsted’s representation that it has an interest in the Norfolk Boreas application, and wishes to be treated as an interested party for the purposes of the examination process. Ørsted (via project companies) is currently developing, constructing and/or operating Hornsea Project One, Hornsea Project Two, Hornsea Project Three and Hornsea Project Four in the former Hornsea Zone in the Southern North Sea. General and Project Need: In principle, Ørsted supports Norfolk Boreas as it will provide an important contribution towards meeting the UK government's renewable energy targets, and will enable the UK to continue its growth in the offshore wind sector. The UK is bound by national and international obligations on climate change and energy legislation. For example, the Energy Act 2013 makes provisions to incentivise investment in low carbon electricity generation, ensure security of supply, and help the UK meet its emission reduction and renewables targets. National planning policy is also supportive, with Overarching National Policy Statement for Energy (EN-1) supporting the requirements of the Renewable Energy Directive, with new projects urgently needed in order to ensure that this target is met (Paragraph 3.4.1) and with Offshore wind expected to provide the largest single contribution towards the 2020 renewable energy generation targets (Paragraph 3.4.3). Environmental Impacts: in general, Ørsted welcomes the findings of the cumulative and in-combination assessments as far as they relate to Ørsted projects. Whilst the siting of the Norfolk Boreas offshore array, export cable route and the onshore grid connection points do not physically overlap with any Ørsted project, some topics / receptors have been identified in the Norfolk Boreas to have the potential for a cumulative interaction with a number of Ørsted projects. Potential cumulative impacts between Norfolk Boreas and Ørsted projects have been identified for the following topic areas: ? Fish and shellfish* ? Marine mammals (Hornsea Three, Hornsea Four); ? Offshore ornithology (Hornsea One, Hornsea Two, Hornsea Three, Hornsea Four, Gunfleet Sands, Lincs, London Array, Westermost Rough, Race Bank) ? Commercial fisheries (Hornsea One, Hornsea Two, Hornsea Three, Hornsea Four, Race Bank Extension, Gode Wind 1, 2 & 3, Borkum Riffgrund 1 & 2; Borkum Riffgrund West 2, Horns Rev, Borssele 1 & 2); ? Shipping and navigation (Hornsea One, Hornsea Two, Hornsea Three, Hornsea Four, Borssele 1 and 2; and ? Aviation and radar (Hornsea One, Hornsea Two, Hornsea Three, Race Bank) Onshore, we have identified an interaction with our Hornsea Three project export cable corridor and the Norfolk Boreas cable corridor, which will cross at land north east of Reepham, Norfolk. The same cable route is proposed for Norfolk Boreas as is proposed for the Norfolk Vanguard project which is currently awaiting a decision from the Secretary of State and is expected in December 2019. There will also be an interaction on the local road network, in particular: • on roads close to the Hornsea Project Three compound proposed at the established hard standing area at Oulton Airfield as Norfolk Vanguard and Norfolk Boreas are proposing to utilise a cable logistics area on land to the south east of Oulton Airfield; and • on roads which will be used to access both onshore cable corridors Where the onshore cable route for the projects cross, or where there is potential for direct interaction on the local road network, Ørsted will continue to work with Norfolk Boreas: • To manage construction traffic impacts, Ørsted advocates consistent approaches to construction traffic management – we expect both projects to continue to work together and exchange information to ensure that an assessment can be made of the cumulative impact of both projects. • To manage impacts on public rights of way, Ørsted advocates consistent approaches to the management of Reepham footpaths FP18 and FP34. • To manage archaeological impacts, if required where the cable corridors cross, Hornsea Three advocates a consistent approach to targeted geophysical survey and trial trenching through a consistent approach to (Archaeological) Written Schemes of Investigation (WSI) being agreed with the relevant authorities prior to commencement of the consented works where the cables cross. Now that Norfolk Boreas has completed its Environmental Statement and has published its application, Ørsted is confident that any potential concerns with regard to cumulative and in-combination impacts can be readily addressed. To support this, Ørsted is in regular contact with Norfolk Boreas’ promoters, Vattenfall, at all levels of the project and has sought, and will continue to seek, to liaise on environmental matters. Ørsted reserves the right to make further representations throughout the forthcoming examination period. *Note: We have been unable to review the Fish and Shellfish chapter in full, as we have only been able to download the chapter up to page 87 from the PINS website (cumulative section starts on page 89)."
Members of the Public/Businesses
Patricia Lockwood
"Following Vattenfall’s Norfolk Vanguard DCO application I would like to also register as an interested party regarding Norfolk Boreas. My family home, [Redacted] , (where I am part owner) is the closest house to this proposed site. The location of Vattenfall's largest area of substations in the world has not taken into account a major factor, the human element. When siting these NSIPS, the only references I can find regarding population are shown as statistics in tables (Vanguard) and only discussed in limited, specific areas of research; I fear the same will happen with Boreas. The community of Necton and nearby Mid Norfolk villages have been woefully neglected, there is no holistic approach, there is no detailed overview regarding how people's lives will actually be affected. The close proximity to the village of Necton is causing many residents much distress not wishing to accept this industrialisation, totally out of character and scale for a small village, as part of their day to day lives. Negative effects include blighting the landscape, devaluation of homes, destroying income associated with tourism, damage to health due to stress and anxiety (continuing when substations are operational but also caused by the long, noisy construction phase), fear generated by threats of fire and terrorism, the effects from EMFs on such a large scale have not been fully evaluated, inevitable background noise e.g. crackle and hum and increased flood risk to Ivy Todd Farm and Necton. Obviously, climate change and the production of clean energy is of great importance to the nation/world but a new, vast expanse of industrialisation should not be created in rural Mid Norfolk. Norfolk’s character should be preserved for future generations, the habitats for many species, the natural landscape and rural amenity need protecting. Norfolk Boreas should connect to an offshore ring main or close to an already industrialised area and not come 60 miles inland to develop 70 acres of substations at Necton, amongst the small rural villages of Mid Norfolk."
Other Statutory Consultees
Water Management Alliance (Internal Drainage Board) (Water Management Alliance (Internal Drainage Board))
"I am writing on behalf of both the Norfolk Rivers Internal Drainage Board (IDB) and Broads (2006) IDB (two member Boards of the Water Management Alliance). The purpose of this response is primarily to avoid conflict between the planning process and each Board’s regulatory regime and consenting process (as per the Land Drainage Act 1991 and each Board’s Byelaws (created as per Section 66 of the Land Drainage Act 1991). The Board’s Byelaws are available on the Development pages of each Board’s webpage, accessible via www.wlma.org.uk. The development area is partially within the Internal Drainage District (IDD) of the Norfolk Rivers IDB, and in close proximity of the IDD of the Broads (2006) IDB. Furthermore the vast majority of the proposed development is within the watershed catchments of the aforementioned IDDs. Please see the relevant Board’s webpages for maps of each IDD. These maps also show which watercourses have been designated as ‘Adopted Watercourses’ by the Board. This designation is an acknowledgement that the watercourse is of arterial importance to the IDD. I note that the applicant has stated (DCO document 5.4, page 4) that Land Drainage Consent is required for structures in ordinary watercourses and permanent culverts, as per the Water Resources Act 1991. However this statement is partially incorrect. Land Drainage Consent is in fact required in the following circumstances as per the Land Drainage Act 1991 and the Board’s Byelaws: • Where the proposals include works (temporary or permanent, including trenched watercourse crossings) to alter an ordinary watercourse, consent is required under Section 23 of the Land Drainage Act 1991. If the site is within an IDD the relevant IDB is the consenting authority for these works. If outside an IDD, the County Council (Lead Local Flood Authority) is the consenting authority. • Where the proposals include works within 9m of a Board Adopted Watercourse, consent is required under byelaw 10 of the Board’s Byelaws. Byelaw 10 restricts works within 9 metres of drainage or flood risk infrastructure (including Adopted Watercourses), the principle aim being to ensure watercourses can be maintained by the Board now and in the future without restrictions being placed on the Board’s access. • Where a surface water (or treated foul water) discharge is proposed to a watercourse within the IDD (either directly or indirectly), then the proposed connection will require Land Drainage Consent in line with Byelaw 3. Any consent granted will likely be conditional, pending the payment a surface water development contribution fee, calculated in line with the Board’s charging policy, available online. The applicant also states that these consents would be sought as part of the DCO process. Please note that no applications for Land Drainage Consent have been received by either the Norfolk Rivers IDB or Broads (2006) IDB as part of the DCO process to date."
Members of the Public/Businesses
Nicola Banham
"Detrimental impact on my B&B. Integrity of my listed building (grade 2* built 1700) Pollution levels from continuous diesel HGVs trying to ass and backing up down the narrow High Street. Noise pollution for the same reason. Serious pedestrian safety problems due to narrow road and very narrow pavements and no pavements in some places. Children will not be able to safely get from the school to the recreation ground. On street parking removed without an alternative being given"
Members of the Public/Businesses
Andrew Lockwood
"I object to the Norfolk Boreas substation infrastructure being constructed at Necton as feel it should be connected to an offshore ringmain to protect mid Norfolk and the population of Necton."
Members of the Public/Businesses
WS Atkins International Ltd. on behalf of BBL Company VOF
"BBL Company looks forward to working with Vattenfall to put in place a Crossing Agreement to ensure the integrity of the BBL Pipeline and the crossing arrangement during construction and operation."
Members of the Public/Businesses
Clan Farms Ltd
"Our concerns on the farm would be the following:- 1. Access routes and how they will be managed. 2. Aftercare of the land with good compensation for up to and beyond a decade. 3. Communication with the farmer must be well planned and informative. 4. Concern about the link and jointing boxes - consideration to where they will be in the fields and again access rights. 5. Grave concern where the pipework will come in from the coastline and the added pressure that this may put on the already dangerous coastline at Happisburgh with high risk flooding of the area. 6. Timing of the Boreas pipework after Vanguard."
Members of the Public/Businesses
Colin King
"I would like to register the following concerns:       The Environmental Statement 6.3.29.1 states of the 3D model views112. "There are limitations in the accuracy of DTM data so that finner elements of landform may not be picked up precisely and may result in parts of the onshore project substation or National Grid substation extension, being more or less visible than shown.""Where descriptions within the assessment identify the extent of onshore infrastructure visible this refers to the illustrations generated and therefore the reality may differ to a degree from these impressions" 114. "The photographs and photomontages used in the assessment are for illustrative purposes only and, whilst useful tools in the assessment, are not considered to be completely representative of what will be apparent to the human eye."       I have had experience of this "fine landform element"error in the Vanguard application, which changes the view from 3/4 obscured to fully visible. I feel with my experience, and the applicants admission of accuracy limitations, that if this system is the chosen method of demonstrating visual impacts, it can not be relied upon to develop design detail requirements. A greater degree of error tolerance has to be built into the design by over concealing the development, instead of using the minimum specified requirements gained from this system's illustrative quality images. A safe and more sure method of mitigation with easier predictability, would be to lower the ground level a "degree", and form earth bunding, with planting around the site.       In my opinion, the appendix 4.3 Strategic Approach to Selecting a Grid Connection Point does not address the issue of the cable corridor lengths of Orsted's Hornsea 3 field running to Norwich and Vattenfall's Vanguard and Boreas fields running to Necton. If the proposed routes are followed (to overcome the suggestions that if the routes were changed they would be longer to avoid innumerable obstacles) up to the point they cross, and then their destinations were exchanged, a mile could be instantly saved. As these two modified routes are very curved, it is not unreasonable to think that there is massive scope to shorten the routes   substantially more.       The 1996 F16 plane crash in the vicinity of the Necton substation needs consideration, incase of redundant contamination disturbance, causing leaching into the aquifers.       Holiday and leisure businesses in Necton and Bradenham need identifying, and their true sensitivity value needs taking properly into account, including the effect on the attractiveness of close landscape.       The substation site drainage needs serious consideration, as all the drainage water passes through Ivy Todd and West End Bradenham, both with pinch points, flooding roads and properties. A description of how natural drainage would be reinstated after decommissioning should be provided.       I feel alternative substation sites should have been taken into the consultation, as the four foot prints were in the Vanguard consultation.       On a personal level, we need assurances, that the flow of the streams each end of our property will not be altered. The sound produced from the substation will not be detectable on our property, including over our fields, as we feel they are suitable for future leisure development, and feel it unacceptable to have this avenue affected in any way.                        Yours sincerely,  Colin King.        "
Local Authorities
Great Yarmouth Borough Council
"The Council is very supportive of the proposed Boreas scheme in principle. The proposed generation capacity of 1.8GW of low-carbon energy would contribute very significantly to the Government's renewable energy targets and the wider economic benefits to Norfolk would also be considerable, as identified in the ES. The port, town and borough of Great Yarmouth is, as is recognised in the application documentation, very well-placed to contribute to the wider economic benefits the scheme would generate. This includes especially through the potential use of Great Yarmouth port for windfarm construction and then operations & maintenance (O&M)activities - Vattenfall signed an agreement with Peel Ports in 2018 to reserve space for an operations base for both the Boreas and Vanguard proposals (subject to DCO consents being granted). Vattenfall has included a Skills and Employment Strategy Planning Condition / Requirement within the Boreas DCO, ensuring that there is a skills legacy to the project. The Council warmly welcomes this and recognises that this must allow for creation of apprenticeships, internships and work experience to benefit the wider economy and area. The Council does not have any particular comments to make on the onshore elements of the DCO proposal (as they fall outside the Council's area), save that the environmental and amenity impacts should be minimised and any opportunities to facilitate the use of the electricity generated within local electricity distribution networks (132 kv or below). In relation to potential offshore effects, the potential impact on commercial fishing operations is recognised in the DCO application (especially during construction) and the Council asks that Vattenfall continues the dialogue with fishing interests to ensure that any negative effects are minimised and mitigated."
Members of the Public/Businesses
Lucy Sheringham
"I intend to make objections against the Norfolk Boreas Project for the following reasons: - Environmental Impacts of Onshore Substation Location - Site Selection Process These points will be elaborated on in my future representations."
Members of the Public/Businesses
Paul Haddow
"I intend to make objections against the Norfolk Boreas Project for the following reasons: - Environmental Impacts of Onshore Substation Location - Site Selection Process These points will be elaborated on in my future representations."
Members of the Public/Businesses
VisNed
"VisNed represents the majority of Dutch demersal fisheries on behalf of five Producer Organisations from across the country. A considerable amount of our members' vessels will be affected by the development and operation of the Norfolk Boreas project since the array is planned on excellent fishing grounds. As such we would like to address the loss of fishing grounds for certain types of fisheries and the impediments for those that theoretically can still fish within the array and if cumulative impacts from other projects are correctly taken into account. Furthermore: - Approaches with respect to addressing any loss of earnings and the cost associated with any long-term loss of access to grounds and temporary relocation of static fishing gear. - Allowing for consultation on any cable installation plans and contingency arrangements to be applied in order to minimise the potential for any gear snagging risks to exist or emerge post installation. - Provisions to ensure that any temporary exposed cable assets located outside of safety zones are protected in situ through the use of guard vessels until installation has been completed. - Post-installation trawl surveys in order to verify that fisheries can resume safely. - Liaison during construction and operational fase."