Norfolk Vanguard

Representations received regarding Norfolk Vanguard

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

SourceRepresentation - click on an item to see more details
Members of the Public/Businesses
Andrew Johnson
"The planning application does not take into full consideration of the impacts to the Necton and Surrounding rural community and the consultation process has been incomplete."
Members of the Public/Businesses
Barbara Penn
"My interest is as a local resident; trenches will be dug and cabling will run close to the village I live in. I am concerned for the environment, wildlife and for the impact this project will have on residents. I am a parish councillor."
Members of the Public/Businesses
Ian Harding
"The general emphasis would seem to favour a DC sub-station at Necton. Due to the extreme size of the buildings and the devastating visual impact they will have in open countryside I would ask that the inspectorate fully assess the effect of these buildings on the environment and examine what the difference would be should the sub-station be AC. We are being threatened with an extremely large amount of industrial clutter both now with what is proposed at the site in the future. Any action that can minimise the effect can only be beneficial to the countryside."
Members of the Public/Businesses
Jenny Smedley
"1. Vattenfall have failed to do a proper consultation. The only time residents were asked to make comments on choice of substation sites in Necton, it was to an invited audience only. The next day at the open meeting, people were not allowed to give an opinion. 2. Documents relating to the plane crash in Necton uncovered through the Freedom of Information Act shows that excavation could disturb contamination (including radioactive substance) and that any development must get special permission to use the land. Vattenfall have ignored this. 3. The PEIR states that the project is of too massive and scale for the area and cannot be mitigated because of its size. 4. Only one bat survey was carried out on the area and it revealed 2 rare species. 5. Vattenfall has refused to answer questions. 6. Our action group agreed to come to the table with George Freeman and Vattenfall to try and find compromise. Vattenfall refused to attend. 7. No compensation has been offered by Vattenfall to our village. 8. Vattenfall have provably misdirected at their presentations, to mislead opposition. Several people who said they worked for Vattenfall made statements, such as that Boreas would be 'very small', and 'add on', 'need not be worried about'. We know that all along Boreas was intended to match Vanguard in size. 9. Noise - Dudgeon/Statoil who built our current substation, have remained within the operational noise constraints applied by Breckland. However at 4.5 times the size of Dudgeon, it is impossible to imagine that Vanguard and Boreas can do the same, especially as the noise made by Dudgeon has taken up some of the permitted noise. 10. It has become apparent that all decisions were made prior to the consultation, so in fact the consultation has been a complete waste of time, as nothing we have said has had any apparent impact on Vattenfall's decisions. 11. We offered Vattenfall a feasible alternative site - that was more efficient, and more environmental, but they did not give it serious consideration. This has been proven by an email chain accidentally sent to me by the National Grid, which infers that in Vattenfall's response to our alternative suggestion they did not stick to 'factual aspects'. 12. Vattenfall are going to ruin a second farm by building an access road from the A47 through it to the substation site. Then come out of the other side of this site and cable all the way back almost to the A47, and then cross back to the other side of the site to the National Grid, in the process destroying Statoil’s mitigation. This circular route is most inefficient, and brings into play the plane crash site. 13. On paper it seems more efficient to put all infrastructure together and ruin just one area, but in practice the massive sizes proposed, show it isn’t efficient nor environmental. Whilst a village could deal with one project, placing three next to one village is inhumane. "
Members of the Public/Businesses
John Sings
"I contend that this project's route to market would serve Norfolk the better if it ran to Swardeston, Norwich and did not carve Norfolk in half on it's route to Necton. I believe it would be even more economical for Vattenfall."
Parish Councils
Little Dunham Parish Council
"This development represents an over expansion of the existing site. Whilst landscaping will ameliorate the impact of the low lying structures proposed on the 120 acre site , the large converter buildings will only be partially disguised and this is conceded by the applicants in their submission. This could be avoided by the applicants making the AC choice. The existing site uses AC transmission. If the application is allowed to proceed on the DC basis then this will represent an over-development of this agricultural area bearing in mind also the number of wind turbines that are in the locality."
Members of the Public/Businesses
Jenny Smedley on behalf of Margaret Woodall
"When Vattenfall first came to Necton with a presentation they led me to believe that we would not see or hear their substations, and that Boreas would be a much smaller addition. I have since come to realise that we will see and hear them, because due to being DC they will be so incredibly massive, as Boreas is now to be the same size as Vanguard! Vattenfall admit that the structures are too big for the area, and can’t be mitigated by planting, so why are they still coming? The construction noise alone, which could last ten years, was bad enough with Dudgeon, as was the light pollution. This will be several times worse! We will be going from a lovely agricultural village to an industrial site. We already have one substation and certainly do not need three. "
Members of the Public/Businesses
Mr John Reid
"Main points: Sub station being erected in a totally unacceptable place. No one at Vattenfall or National Grid has followed the guide lines set out in the initial planning applications. Meetings with the public have been a complete whitewash. Alternative sites and connections submitted by members of the public and others have been consistently ignored. Massive loss of prime agricultural land from the coast to Necton."
Members of the Public/Businesses
Mr N Warnes
"Quite simply, I wish to make a point of raising the issue as to whether this project is considered alongside other infrastructure projects so as to provide a joined up strategy. For example , we have other infrastructure requirements for electric vehicle charging infrastructure. If timing and opportunity is not taken to consider opportunities like this to implement significant infrastructure at say Necton, if not other sites along the cable route, then it would seem wasteful and isolated in its benefits to our community"
Members of the Public/Businesses
Patrice Baldwin
"This project is too large and disruptive for the area and will involve putting enormous wires under a beach that is particularly vulnerable to coastal erosion. I am concerned that with tidal scouring and surges, the cables could end up being exposed. It is also a beach of particular interest historically and anthropologically ( Happisburgh footprints) and the cables could damage possible future finds. The beach is the main tourist attraction in Happisburgh and this village (in an area of rural, socio-economic deprivation) relies on tourism for income. The traffic will be heavy for years and has safety implications, especially where it passes schools. The roads already have poor quality surfaces. The effect of vast cables carrying electricity close to homes could have detrimental effects on people's health. Vattenfall has not held public meetings. They have held 'drop ins' (not well advertised) that have enabled them to control and diffuse the opinions of the general public who have attended. Many residents did not know about the meetings, as there were no public posters in the village about them. When the local MP, (Norman Lamb) held a meeting, the room was overflowing onto the street. Vattenfall were invited to attend but were either not well informed or chose/were unable to communicate key information in a way that could be understood easily by the public. As an interested member of the public, I feel ill informed about this project still, despite attending 'drop in' meetings. Who/what is waiting in the wongs? Which country/owner will/might Vattenfall sell on this project to, once completed (pension fund companies)? How long is the working life of this project? What firm plans are there for dismantling it at the end of its working life? Why is Bacton not a suitable co-site, rather than damage Happisburgh (terrorist targets)? Bacton terminal is already an eyesore and not fully used now, so why not site it there? It seems expedient that the Vattenfall application was being compiled at the same time that the sea off Bacton was deemed a maritime protection area. The public should be be presented with real options for siting it environmentally and geographically. There were no real site options presented. Presumably, Vattenfall (a Swedish company) is driven by coming ashore at the English place that is most profitable for them. Happisburgh is an area of natural beauty and severe coastal erosion and they should make it a smaller project and site it elsewhere. A real public meeting should be held, advertised clearly and in the villages. The meeting should be led by well informed and communicative employees of Vattenfall. Putting out many technical folders on a table at a public drop in and letting the public dip into them, is not sufficient. It enables Vattenfall to say they made the information available, yet they know it is in a form and quantity that is undecipherable to most people. The glossy and sporadic 'newsletters' are carefully crafted propaganda, with little useful information. Vattenfall also rarely reply to emails. There is a veneer of communication and information but in reality, we have not been well communicated with or well informed and it feels as if we are being treated like fools and ignored."
Members of the Public/Businesses
Jenny Smedley on behalf of Stuart Higgs
"I am really concerned about the size of these structures as even Vattenfall admit in their PEIR that they will not fit in with the character of the area. Also, we are worried there will be more to follow. It seems our village could be bombarded now. We know there is contaminate soil (with radioactive substance possibilities) close to where they intend to build, but they have taken no notice of this, and seen very casual about it. We were never properly consulted by this company who have been ‘economical with the truth’ as if to lull us into a false sense of security on several occasions. "
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 England, Wales and Northern Ireland. 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 Vanguard offshore wind farm. Our interest in the project is that Vattenfall Wind Power Ltd 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 Vattenfall Wind Power Ltd for construction of the project. We therefore wish to follow the progress of examination of the project. "
Non-Statutory Organisations
Whale and Dolphin Conservation
"WDC have been engaging with UK and devolved government bodies and developers for several years regarding marine renewable energy and provide our advice regarding marine renewable developments and their impacts on whales, dolphins and porpoises (cetaceans). Due to the impacts of climate change on cetaceans, WDC supports the development of well-considered marine renewable energy. However we have serious concerns about the potential impacts of these developments both individually and cumulatively, have on cetaceans. WDC are particularly concerned that the construction of Norfolk Vanguard offshore wind farm has the potential to negatively impact cetaceans, in particular harbour porpoises and the integrity of the Southern North Sea SCI, for which harbour porpoise (Phocoena phocoena) are the qualifying feature. As Norfolk Vanguard offshore windfarm lies directly within the SCI, in both summer and winter habitat for harbour porpoises, our concern is that the windfarm construction will impact the SCI both alone and in-combination. WDC have concerns regarding the effectiveness of some noise mitigation methods and the SNCB guidance on noise management within mobile species marine protected areas (MPAs). The planned installation of all windfarms, as well as other activities within and adjacent to the SCI, have the potential to disturb the harbour porpoise population of the SCI and so should be taken into consideration. Our primary concern for Norfolk Vanguard Offshore Windfarm development surrounds the intense noise pollution resulting from pile driving for all cetacean species in the region. Should consent be granted, our key recommendations for this development are: • That pile driving is not used at all during construction; • That strict limits be placed on noise levels during construction, including cumulative noise; • That proven mitigation methods are in place around the source to mitigate the impacts of radiated noise levels; • That a robust impact monitoring strategy (Marine Mammal Monitoring Plan (MMMP)) is developed for the range of species that can reasonably be expected to be impacted; • That WDC is included as a consultee of the MMMP and that we are included in the discussions for the design of the MMMP as we have concerns regarding effectiveness of some mitigation methods; • A robust MMMP should include: shut-down when marine mammals approach within a specified distance of operations (mitigation zone); • That the monitoring strategy is appropriate to consider cumulative impacts of all developments in the region; • Ground-truthing of modelled noise assessment data should be undertaken; • Should any incident that results in mortality occur during construction, activities should be halted immediately until an investigation can be completed; • An assessment report is publicly available within a reasonable timeframe of construction completion."
Members of the Public/Businesses
Norma Albinson
"As a resident of Happisburgh I am deeply concerned about this application . The cliffs at Hapisburgh are very fragile and in the thirteen years we have lived here have seen the loss of cliff and property, only yesterday some one was injured in a cliff fall (3/7/18)… Living near Cart Gap Road I am also concerned about the us of this single track road by large construction vehicles and the ramp here provides beach access to not the RNLI life boat a d NNDC when they need access. The recent information throws doubt on the viability. Of wind energy, indeed when I have visited Great Yarmouth the ones there are more often than not out of action. Destruction f the beach and wildlife habitat, migratory Pink foot Geese flock in this area, potentially affected by actual turbines ."
Members of the Public/Businesses
Tony Smedley on behalf of Lorraine Gill
"My representations in objecting to Vattenfall's proposed development at Necton are:- 1. I am concerned about the negative impact this will have on the landscape and on the local wildlife. Vattenfalls PEIR Document states that it is too large for the location, and no amount of mitigation will be effective for the lifetime of the project, so it goes against the planning laws that say effective mitigation must be used. 2. Construction and operation will cause dust, noise and light pollution in an area that is designated as 'dark rural landscape'. 3. House prices will suffer because of the pollution and proximity of the sub-station. Prices have already been affected by the existing Dudgeon sub-station so we know it happens. Vattenfall’s ridiculously massive industrial site will make this situation worse. 4. Flooding of roads around Ivy Todd, Chapel Road and West End is an existing problem. Construction of the sub-station will make this worse. If this was a housing development in that same area it would never be allowed."
Members of the Public/Businesses
Jenny Smedley on behalf of Alan Wright
"My parents helped us buy our house in Necton. They actually thought they were helping me with my pension, believing that property was the best investment. But now prices are plummeting in Necton. We’ve been through a lot of stress as parents during the past few years and just wanted somewhere peaceful to help [redacted]and what better than a sleepy Norfolk rural village? Now we find we’re looking at an incredibly huge industrial build of up to 10 years. There will be pile-driving, more possible flooding (which won’t be known about for years, and VF tell us they would not hold themselves responsible if flooding occurs because we’d never prove it was their fault), and the dust and possible harmful emissions, to [redacted] in particular. Then there’s possible radioactive substance risk from a plane crash VF didn’t tell us about! The whole thing is a nightmare. We have had very little information – it all has to be searched for online and with 2 young boys time is not on our side for that kind of distraction. We just want a normal life. There must be somewhere less close to houses this could go. "
Members of the Public/Businesses
Jenny Smedley on behalf of Heidi Wright
"We waited specifically for a home in Necton to be closer to my husband Alan’s work. We finally found our dream home. It was a push to afford it but we managed. We moved the whole family away from the rat race in Birmingham and renovated our new home on the edge of Necton. We had been through the mill with [redacted] and thought here was an ideal place for [redacted] and local amenities. Then the whole Vattenfall project was dropped on us, potentially knocking thousands off the value of our home. (Many house owners since have had to lower their prices dramatically since this started). To have put all our hard earned savings into buying and renovating, to have that value undercut by the massive monstrosity being in such close proximity to our home is soul destroying. It is vast, ugly, potentially a lot higher than stated at first if they get the go ahead, and what harmful stuff what will this thing emit? There is a high population of children in this village. There’s the noise, the lighting at night, and what about years down the line, once the cables that run underground and have been humming away? They can’t tell us if it will affect us because they simply don't know."
Members of the Public/Businesses
Jenny Smedley on behalf of Maurice Woodall
"Vattenfall came into our lives in 2016. It was a shock, but they told us not to worry because they would listen to us all the way through the process. This is not happened. Most of what they told us has been misleading, and deliberately so it seems. All they did was continually ‘present’ us with what THEY had decided. Most of our comments were not included in the documents, and our questions were ignored. At the end of the day, for no apparent reason they have shown us what they have decided for the siting of the substations. Despite worries concerning plane crash contamination and a high possibility of flooding in the areas laying downwards from the site (the site is very high), our concerns from our previous substation build about useless mitigation, light pollution, noise and disturbance have been brushed aside by this very arrogant company. We read with dismay that on the whole this consultation has been ‘rubber stamped’ by local authorities, who seem to have no idea, despite us writing to them continually, that WE (the affected) do NOT think the consultation has been done adequately, and it appears our concerns are to be ignored. What was the point of this consultation as everything seems to have been agreed before we were even told about the proposal?"
Non-Statutory Organisations
Royal Yachting Association
"The RYA’s main concern relates to the cable landfall where the cable comes within the 10m contour and any resulting reduction in water depth. There could be issues where the cables cross other wind farm export cables and other inland waterways on route to the onshore Grid connection and the RYA should be consulted with respect to this. RYA maintains its position with respect to not seeing the need for operational safety zones for floating offshore winds turbines. The RYA respects the need for safety zones during construction, major maintenance and decommissioning as well as for manned structures during operation. "
Members of the Public/Businesses
Andrew Brown
"The proposed development will have a very detrimental affect on the local community. The proposed development is huge and not in keeping with the surrounding area. Vattenfall have admitted they will not be able to screen them, they will be so high. It will mpact on quality of life and severely affect house values. The community have already consented and supported the current off shore substation that is there - this is not a case of NIMBYism. There are other sites more suitable. Vattenfall have consistently ignored the views of the local community and there can be little trust that they will not continue to do so over coming years. There are two species of protected bats that will have their habitat destroyed. Vattenfall say they will erect new hedge areas for them - what happens to these protected species whilst this happens. Another example of a don't care attitude by the company. The proposed site is also questionable due to contamination arising from a previous military air crash. "
Members of the Public/Businesses
Jenny Smedley on behalf of Angela Campbell
"As a resident of Necton already subjected to the siting of Dudgeon Substation I was greatly concerned when told that another substation was to be built by Vattenfall adjacent to the existing one. Not only were they wanting to build Vanguard they also intended to build a further add on one - Boreas At the consultations given by Vattenfall we were led to believe that we would not see or hear either of the new substations – especially Boreas which would be substantially smaller than Vanguard. We were told that this would be possible due to substantial mitigation planting. At the consultations we were also told that Vattenfall did not know if the substations would be AC or DC. Questionnaires which were given out were designed basically to tick box each question so that Vattenfall could get the answers they wanted. Comments made by residents were basically ignored and not included in any of the documents. It now appears that Vattenfall have lied to us from the start. Vattenfall have now told us that Boreas will be the size of Vanguard. That they will be DC. That no amount of mitigation will hide the structures which are basically massive and far too big for the area. Necton and the surrounding villages will have to contend with years of construction noise, congestion on an already busy A47. Flooding issues have not been considered. The lives of the residents will be ruined from the beginning of this project and continue to be ruined for years to come. It would appear that the whole project had been rubber stamped and agreed by local authorities before the consultations took place. What was the point in it all? Those in authority have little regard for the lives of the residents it ruins. "
Members of the Public/Businesses
Brenda Dutton
"When the first substation was muted many people objected but we were told that we would not be able to see the substation over the trees to be planted. We are now informed that the substations will be much higher and consider that the we have all been duped in that original plans were misrepresented. This is not what we all accepted and that we will now have several more substations that will spoil the views from the village and affect house prices. It is just another case of the little people being bludgeoned in to accepting what the large companies want. We do not yet know if there will also be a detrimental affect on the health of the people in the village."
Non-Statutory Organisations
CPRE Norfolk
"CPRE Norfolk will be covering the following points in its written representation: - preference for an HVDC system as submitted for approval, rather than an HVAC system. - environmental/ecological concerns, in particular with reference to river valleys. - issues with connection to the National Grid. - impacts on the countryside."
Non-Statutory Organisations
East of England Energy Group (EEEGR) (East of England Energy Group (EEEGR))
"The East of England Energy Group (EEEGR) would like to go on record with its full support for this application from Vattenfall for the Norfolk Vanguard project. The East of England Energy Group (EEEGR) was launched on 29 March 2001 as a not-for-profit trade body to represent the energy sector and its supply chain in the East of England. We now have more than 300 member businesses. A complete list of member organisations can be viewed on our web site at https://www.eeegr.com/members-directory EEEGR’s core programmes and projects are geared towards the sustainable development of the energy industry in the East of England, to help it thrive. The East of England Energy Group (EEEGR) represents more than 300 members across the region, ranging from energy producers to supply chain companies. Our mission is to provide knowledge, support and opportunities to enable members to strategically grow their businesses. EEEGR is also a key voice for the sector, putting the region and its expertise on the radar of major international players and influential politicians at regional and national levels. EEEGR also has close links with educational and training institutions, through the Skills for Energy (SfE) programme. This programme helps to ensure students, courses and training facilities are tailored to meet the future needs of the energy industry. The UK is at the very forefront of the development of clean, renewable offshore wind developments providing the country with a critical advantage to develop the indigenous UK sector to become a major potential exporter of skills, knowledge, technology and equipment to the benefit of UKPLC. The Norfolk Vanguard project represents the latest in a number of offshore wind farms on the East Anglian Coastline helping to improve our environment through the reduction of carbon emissions, provide huge investment in the supply chain, infrastructure and assisting in the development of new, sustainable jobs for at least two generations of workers."
Members of the Public/Businesses
Edna Violet Greening
"We love the village of Necton. Have lived here for over 20 years and have been fortunate to look out onto open farmland - that is until the Dudgeon substation came into the village and blighted our view adding light pollution and noise.We were horrified to learn that yet another foreign company planned to come to Necton. After the 'Brexit' vote we were told by this government that we would have to be more self sufficient. How can concreting over, what will in total amount to 100 acres of prime farmland, be beneficial to this cause. If this proposal is allowed to ruin our village - and no doubt other companies are lining up to follow - this precious land will be gone forever and can only turn our village into an industrial site. The village of Necton is not a suitable site and if we are forced to have these monstrosities they should be housed away from view and not on precious farmland. Vattenfall have been evasive from the word go. During an earlier "Consultation"we were shown an illustration of the site and when asked what was that section behind the Vanguard Substation the reply was 'Oh that's just a small "add-on". The small "add-on" is in fact the Boreas Substation which we now find is as large as the Vattenfall Substation. There is also the proof of flooding in this area chosen. Residence have already had their homes flooded and we all have to ask ourselves would we like to open our door and be confronted by these ugly monstrosities? Norfolk is a beautiful County and ploughing through the heart of it with wide cable corridors is horrifying. There is awareness of an alternative site available for this Substation away from this highly populated village which Vattenfall have refused to even consider. HOW CAN THIS BE CONSIDERED A FULL CONSULTATION PROGRAMME! Further, there was a plane which crash landed in the area of Necton proposed by Vattenfall and they have been made aware of this fact. This land should not be disturbed because of the official findings of highly pollution to this area. To our knowledge Vattenfall have not responded to this fact and totally ignored the warnings."
Members of the Public/Businesses
Emily Ruggles-Brown
"The proposed development will have a very detrimental affect on the local community. The proposed development is huge and not in keeping with the surrounding area. Vattenfall have admitted they will not be able to screen them, they will be so high. It will mpact on quality of life and severely affect house values. The community have already consented and supported the current off shore substation that is there - this is not a case of NIMBYism. There are other sites more suitable. Vattenfall have consistently ignored the views of the local community and there can be little trust that they will not continue to do so over coming years. There are two species of protected bats that will have their habitat destroyed. Vattenfall say they will erect new hedge areas for them - what happens to these protected species whilst this happens. Another example of a don't care attitude by the company. The proposed site is also questionable due to contamination arising from a previous military air crash."
Members of the Public/Businesses
Julian Pearson
"1) The photograph taken at IP25 7EE used the presence of woodland to select this viewpoint.. whereas, less than 200m to the east, the entire development, along with the existing substation, would be openly visible in full. 2)Tall buildings could be designed with vertical gardens. Edgware road station is a perfect example, had VF actually put thought into it.. then those buildings could encircle the rest of the infrastructure, concealing that too.. their proposed mitigation planting would not be effective for at least 20 years, perhaps more given the larger buildings for the DC option. 3) There has been a complete lack of visuals of the intended infrastructure.. despite several asks.. they eventually flattly refused… just open landscape photos with lines on them 4) Lack of expert consultation on depleted uranium remains after military jet crash about 12 years ago right on that site… risks to construction workers, etc… 5) Choice of site despite other lower site offers VERY close by. they have ignored the expressed public concerns and dismissed alternatives (incl, 165 acres that would have accommodated all queued substation projects in a near-total-concealed location.. that was actually up for sale) 6) No details of national Grid expansion other than coloured squares.. each claim it is the others responsibility, so neither has done any consultation with the public about it. 7) Other substations queueing. When agreeing to the first substation, there was no mention of it automatically being site of choice for future substations.. the goodwill of the locals has been abused. 8) No reports on the drainage issue caused in the village by development here, due to run off. In short, I find their proposal (for the substation) poorly thought out and poorly designed and ask that if you permit this, that there are mandatory conditions that make explicit reference to the measurable acceptance criteria for any conditions they need to meet [redacted] "
Members of the Public/Businesses
Linda Smith
"my main concerns are :- Farmers here of over 50 years standing have told VF that if they destroy the field drains and concrete over such huge areas, they will inevitably cause flooding. Ivy Todd has only one tributary to take away all water and no mains drains. They have also chosen the HVDC option, which means a bigger, noisier project at this end, and may also cause radio, tv and phone interference. In any case this industrial site is not being put in a suitable area - on a high point it will be seen by 7 communities and will be visible for miles away. It will totally destroy this area one way or another. . "
Members of the Public/Businesses
Jenny Smedley on behalf of Roy Campbell
"When we first heard that Vattenfall were wanting to build another substation in Necton we were all greatly concerned as we had already been subjected to one already – namely Dudgeon. The residents were invited to a consultation where we were led to believe that our concerns would be taken into consideration. We were asked to complete questionnaires which basically gave Vattenfall the answers they wanted! There was no room for movement or for comments to be made on the forms. We were told that the NG had told them that they had to build there and there was no other option. We have later discovered that Vattenfall told NG that is where they wanted to construct – probably because it was cheaper as the infrastructure was partly in place due to Dudgeon already there. Vattenfall told us that apart from building Vanguard substation they intended to build a much smaller substation namely Boreas adjacent to it. We were also told that they hadn't decided on AC or DC as yet but it now transpires that there preferred option was always DC. This means the structure would be almost as tall as Norwich Cathedral and would be totally out of place in a village environment. All the residents’ concerns have been ignored. Especially the sighting of the plane crash and the subsequent contamination of the area. The disturbance of the air crash site could be a possible health risk to residents and the environment. Questions need to be answered. Where the removal of the topsoil and muck etc would be located to. The construction vehicles would add to the pressure of the already busy A47. How would Vattenfall disguise the structures as they say they would by planting of trees? We all know how long trees would take to grow. The sites will be visible for years. How do they propose to control flooding issues which Necton and Ivy Todd already suffer from? Vattenfall assured all residents that their views and opinions would be taken into consideration but effectively have been ignored. Why have they asked for our opinions if they had already chosen and decided already? They are treating us – the affected – with contempt "
Members of the Public/Businesses
Sharon Ruggles-Brown
"The proposed development will have a very detrimental affect on the local community. The proposed development is huge and not in keeping with the surrounding area. Vattenfall have admitted they will not be able to screen them, they will be so high. It will mpact on quality of life and severely affect house values. The community have already consented and supported the current off shore substation that is there - this is not a case of NIMBYism. There are other sites more suitable. Vattenfall have consistently ignored the views of the local community and there can be little trust that they will not continue to do so over coming years. There are two species of protected bats that will have their habitat destroyed. Vattenfall say they will erect new hedge areas for them - what happens to these protected species whilst this happens. Another example of a don't care attitude by the company. The proposed site is also questionable due to contamination arising from a previous military air crash."
Members of the Public/Businesses
Simon Nunn
"This structure is far too big to be accomodated at Necton, it will have a significant impact on the local landscape which can't be hidden with trees etc, it will have a severe negative impact on the village especially the houses close by If in the event of an accident or terrorist attack on the site many home and resisrnts will be affected with lives pit at risk It has been highlighted that alternative sites exist and more suitable for a construction of this size, Necton is NOT the place for this consyruction "
Members of the Public/Businesses
Tracey Nunn
"The proposed new build is far too big for this small village. It will be an eyesore that will be seen for miles around. In the case of a malfunction or terrorist attack this will be catastrophic to residents of this village. House prices will drop. This build will have a negative impact on this lovely village of Necton."
Members of the Public/Businesses
Alan Knight
"The proposed works may cut through the end of our property and run adjacent to it, therefore, the impact of HVDC smaller footprint may mitigate the impact on our ancient trees from reduced cable trench width. Additionally Cable Relay Stations would destroy the local environment and I welcome Vattenfall's decision to apply for an HVDC application. "
Members of the Public/Businesses
Deb Pender
"Destroying 100 acres by turning it into an industrial site is reckless. This site is a bad choice."
Members of the Public/Businesses
Gabrielle Joyce
"Throughout the consultation, information about size, long-term impact on local residential settlements and mitigation has been vague and inconsistent. At this late stage it appears that the applicant is seeking to install infrastructure across 55 acres and reaching 80 feet high. This is a dis-proportionate installation in such close proximity to residential hamlets and villages. This development will fundamentally change the character of this area from rural to industrial area, putting our communities at a distant disadvantage in terms of building sustainability, vibrancy and social well-being. The applicant has already stated that any visual mitigation will be inadequate. Such admission suggests that the site is not suitable. I am aware that alternate sites were suggested by local residents during consultation. I am not aware of any genuine attempt by the applicant to fully investigate such alternatives. The applicant’s transport plan for access on the A47 is not adequate for the level of long-term heavy construction, nor does it give adequate assurance to us (Necton residents) that our rural village roads will be protected (delays and/or closures along our stretch of A47 will result in increased traffic through the village). Flooding is a significant and ongoing risk for Necton and the scale of this development, converting from arable farmland with established ditches and underground streams to 55 acres of concrete will increase this flood risk. The applicant has not given adequate consideration of measure to avoid or manage this risk. "
Members of the Public/Businesses
Jenny Smedley on behalf of Jakki Harper-Lewis
"To rip out a km of mature hedges and trees is not environmentally friendly, nor is Vattenfall destroying the landscaping that Dudgeon put in to mitigate their substation. In my opinion Vattenfall have shown that they only care about making money and not about the environment, otherwise they wouldn't be chasing such an inefficient design, whereby they churn up far more land than they need to. They have given no regard to dangerous land contamination and even less to the comments of residents. There are several alternatives to cabling half-way across Norfolk (literally) for each substation, and allowing Orsted and Vattenfall to cross cables at Reepham shows no sense on the part of the National Grid. "
Members of the Public/Businesses
Jenny Smedley on behalf of Lesley Rose
"This will be the biggest onshore infrastructure for offshore wind farms in the world ie 3.6GW Vattenfall’s documents (PEIR Chapter 29 Table 29.18) says ‘scale and mass would appear at variance with the scale and character of the rural landscape. Despite extent of planting would be insufficient to mitigate the effect within the operational period.' It is also on one of the highest points in this area. Each of the two substations will be the size of 10 Norwich Castle Keeps, both in height and width, so in total 20 Castle Keeps. And that’s without the 1/3 of a mile of National Grid substations, which will increase from 4 acres to 22. And in doing so they will dig out a km of mature trees and hedging. These type of projects seem to be able to run rampage of planning issues that would stop anything else in its tracks. It's recently been discovered that they're going to dig right through possible radioactive substance from an F16 that crashed here. They don't seem to know or care anything about it. How can they be allowed to continue without a proper investigation? "
Members of the Public/Businesses
Tony Smedley on behalf of Lucy Mayes
"I am against Vattenfall building their Onshore Sub-station at Necton, for their proposed Norfolk Vanguard Offshore Windfarm, for the following reasons:- 1) The noise, dust and light pollution that will be created by the construction work that will take place at the sites of both Vattenfalls Norfolk Vanguard Onshore Sub-station at Necton, and also the associated extension work to the existing National Grid sub-station at Necton required for Norfolk Vanguard connection to the National Grid. 2) The noise and light pollution that will be created by both breakdown and planned maintenance at Vattenfalls sub-station and also the National Grids sub-station. 3) The size of the sub-station is too large for the intended location at Necton. Vattenfalls own Peir Document states that it is too large and out of character for the proposed location and no amount of screening mitigation will work during the lifetime of the project (25 years?) 4) I am concerned about health issues that may affect my 8 year old child, both during the construction phase and the operational phase of the sub-station. 5) I am concerned about the adverse effect on house prices in Necton that will be created by the sub-station being built here. 6) I am concerned about the adverse affect on wildlife in the area. Vattenfalls Peir document states 1 km of hedgerow will be removed."
Members of the Public/Businesses
Paul Young
"This development is much larger than I understood from the consultation events. We already have two substations covering 16 acres and reaching 45 feet, which is clearly visible by 8 villages and hamlets, plus our major roads. Adding these two substations plus the National Grid support station will make this area known as an industrial rather than rural area, which will impact on our economic sustainability. Tourism is a growing economy, providing much needed diversification for our farming community and this potential ‘re-branding’ of our landscape will kill this economic opportunity for local people. The development is just too big for this area and will overwhelm it, with little or no opportunity to re-dress the balance. Further this industrial landscape will be isolated and unmanned, with no opportunity for local employment or local economy spin-offs such as infrastructure and other support services, catering and hospitality services, spare parts and local engineering support. National Grid have already indicated that they have capacity and may accommodate more connections at their Necton site. Whilst I fully support the need and urgency of moving to more renewable energy, development of sites must be sympathetic to the existing communities. In this case, I do not feel the existing, currently vibrant communities are being considered appropriately. "
Members of the Public/Businesses
Jenny Smedley on behalf of Phil Harper-Lewis
"Like most residents we thought we'd found a nice peaceful village to live in, with far reaching views and pleasant land undulations, which make Breckland a beautiful place. Our village has already been blighted by one substation and now we're expected to have another 2, 4.5 times the size of the first one. How can it be acceptable to put such a massive industrial structure right in the middle of several communities on the highest point in the area? Vattenfall's own documents say it's too big and cannot be mitigated by planting. The pollution and destruction this project will cause both offshore, and at landfall, and then for 60km across country, through hundreds of roads and rivers, hedges, gardens and farmland, to culminate in adding enough acreage at Necton to mean we will have a 48 football field size heavy industrial is unthinkable, and yet Vattenfall just steam-roller onwards without a thought for the destruction. An offshore ring main would solve all these problems and those of the windfarms to come. "
Members of the Public/Businesses
Jenny Smedley on behalf of Sheila Barlow
"I live on the far side of the village of Necton from this proposed development, however I witnessed the terrible noise and light pollution that was caused by Dudgeon during its construction. This project has been said by Vattenfall's own PEIR document to be too massive a scale for the rural landscape, and at 4.5 times the size of Dudgeon it will be! All of it will be visible from the A47 (including the National grid extensions) which is probably the road most used by tourists coming into the county, and once it is built is will dominate the landscape for miles around because they are proposing to build the substations on a high point in the area. With regards to operational lighting - there wasn't meant to be any from Dudgeon, but there is, every time they do maintenance. They light up the entire sky and this is designated an area of 'dark rural landscape'. Vattenfall have announced they will be back every summer for up to two months (so a sixth of every year) for 24/7 maintenance. This will upset all of us and none more so than those with holiday lets (which are NOT marked on VF's documents) and who rely of repeat trade from star-gazers. The simple fact is, this giant (the biggest onshore infrastructure for offshore turbines in the world) industrial project is not suitable to be placed in this kind of rural area, surrounded as it is by 7 villages. "
Members of the Public/Businesses
Jenny Smedley on behalf of William Barlow
"This project proposed by Vattenfall is not being placed in a suitable site. Just a few miles down the road, they could have stopped, near the same line of pylons and created their monstrous substations where there are no residents. They should never have continued about 5km more into the village of Necton. This village already has one large substation that is changing the character of this village, causing all kinds of pollution and causing house prices in the village to drop, because now, when someone has a house up for sale they are asked, how close is it to the substations, so even if the sale goes ahead a lot of money is knocked off the offer. If these two go ahead, it will completely devastate the village, the lives and the house prices. You will have written us all off if you allow it. Since the first meeting Vattenfall have told us things, designed to calm us, that have later been denied. We don't really know all the facts. To read their documents you have to have a fast computer connection and be computer literate, as you have to be to make this representation. If we want a copy of their documents to read on paper, we are asked for £7500 to get one. How is that the correct way to consult? "
Members of the Public/Businesses
E. A. R. Spain
"• Radiation risk from Danish Airforce plane crash on 11 December 1996 at Necton not addressed despite Vattenfall being informed of it (hydrazine, carbon fibre, depleted uranium). Potential high cost of remediation not included. Could disturb cleanliness of drinking water taken from local boreholes. Potential cancer cluster not investigated yet by Public Health England on the road near to the crash. Risk not disclosed to residents at the time. • The National Grid part of the substation was ignored by Vattenfall in their consultation. Their mockups did not include it and were of AC converter halls, not the 25 metre high DC buildings that can’t be mitigated now chosen. The consultation was therefore flawed. The scale of the photo-montages provided was too small to allow proper visualization and did not show what it will look like from my side of the village. They may have provided further information after the consultation because of our complaints, but the current substation is very visible from my upstairs windows and this one will be much wider and therefore more intrusive. Lights from maintenance at night is an on-going intrusion that will become worse. • The substation buildings don’t need to be so close to our village houses because a suitable alternative site is available, near no houses, closer to the coast, down the pylon line in the vicinity of Scarning. We were told by Ruari Lean (project manager for Vattenfall) “Necton or nothing” when we suggested this alternative. They gave no info to us on why Necton was chosen. They should be asked to provide proper reasons why Necton was chosen rather than a place with far less impact on Norfolk residents. The cable run would be significantly shorter so the costs should be significantly lower. • 63% households (80% people asked) in the village signed a petition against siting another substation close to Necton. Vattenfall did not address the opposition, other than to mention compensation. Nothing will compensate me for this intrusion into my life. The construction years of the project are far worse for residents than the operation years. We have already experienced it once. Road access from the A47 was high risk, noise was intrusive, particularly from reversing vehicles and lights at night were brighter than the brightest moonlight in my garden. • Vattenfall finally offered alternative site options to an invited-only audience and these turned out to be all close to the village. No questions were allowed during the meeting. No discussion was allowed on the potential alternative site. • I challenged Vattenfall on their noise abatement plans for their equipment. They had no information, had not carried out any investigation and said they would ‘make it work’. They did not appear to be aware of the ‘no noise-creep’ limits that would be applied both to Vanguard and the planned Boreas. It would be prudent to choose another site now if another site will be required to control the noise when Boreas is implemented. • Potential lighting hot spot not addressed "
Members of the Public/Businesses
Laura Philpott
"Concerns regarding the close proximity of the development to our home - approx 20metres. Impact on day to day living during development stage - care for my terminally ill mother at home as well as young son. Impact on local environment and wildlife. Unnecessary route of onshore cables given potential for offshore ringmain - massive damage to environment and wildlife, disruption to families, homes and businesses needlessly. Long term health and safety concerns of high voltage cables within metres of our home. "
Members of the Public/Businesses
Edna Violet Greening on behalf of Mr Greening
"We have lived in St Andrews Lane Necton for over 22 years now. From the rear of our bungalow we look out onto open farmland. However the other side of the hedgerow - and in our sights - we have the Dudgeon Substation. We have had noise and light pollution night and day. Apparently vital maintenance work needs to be carried out from 13th August and there will be noise and light pollution after daylight hours. I am now in my 80's am unwell and have recently started kidney dialysis. I certainly do not need the stress of knowing that there is a possibility that at least 100 acres of this precious farmland is under consideration for the Vattenfall/Boreas Substations. This should not be allowed. We need this precious farmland for our Country to be self-sufficient and this land should not be concreted over and lost forever. When this land is decommissioned will there be food processing plants, etc. for our grandchildren to view? Vattenfall have not been open and honest in their 'Consultations' i.e. how many, the size. Have chosen not to consider more suitable sites away from our village. Have apparently chosen to ignore the fact that following the unmanned plane crash in Necton the land should not be disturbed because of the high pollution levels. Therefore the very wide cable corridors they plan - not only for this area - but for the whole of our County should not be allowed to happen. "
Members of the Public/Businesses
Mrs L. Knightley
"Firstly the value of our houses will drop tremendously, people will not buy them with theses buildings right on their doorstep, as they are an eyesore. Secondly the disruption this will cause on the A47, goes without saying, we have enough trouble getting out of the village now. They have no regard for what anyone in Necton has to say,let alone Norfolk, Its all done by foreign Companies, who think they know best, well its not best for Necton, So please go and build your enormous towers elsewhere, instead of Blotting our beautiful Landscape, "
Members of the Public/Businesses
Richard Philpott
"Concerns regarding the close proximity of the development to our home - approx 20metres. Impact on day to day living during development stage - care for my terminally ill mother in law at home as well as young son. Impact on local environment and wildlife. Unnecessary route of onshore cables given potential for offshore ringmain - massive damage to environment and wildlife, disruption to families, homes and businesses needlessly. Long term health and safety concerns of high voltage cables within metres of our home. "
Members of the Public/Businesses
Sarah Greenwood
"I have two reservations about the landfall of the windfarm scheme at Happisburgh. 1) Vattenfall don't seem to be able to provide any proof that the work they plan to undertake will not harm the cliffs in anyway. The cliffs are extremely fragile and I am concerned that the work they will execute will speed up the erosion of the already fast eroding coastline. 2) Noise and disruption during building. Happisburgh is home to many retirees and elderly who will be at home all day when the work is going on. I'm concerned the noise levels will be unacceptable and go on too late into the night."
Members of the Public/Businesses
Andrew Matthews
"I oppose this planning application as I have grave concerns about the suitability of the site based on the RAF plane crash in the 1990's with radioactive substances being leaked into the ground. To add to this the site is very small for the size of the project leaving little space for mitigation. Also I have invested greatly over the past 17years into my property which is my pension fund, with a significant reduction in property prices due to the planning of these substations I will loose an enormous amount of money needed to secure a comfortable retirement for my wife and I. If a government pension scheme were to be reduced to this extent I have no doubt that it would be on headline news. The stress and concern that this has generated has affected my health and wellbeing, [I am highly asthmatic] and the dust and disturbance this build will create for the length of time proposed will leave me with a very poor quality of life. I feel this is best relocated to an area away from property and not removing ancient woodland, the lungs of our world, which reduces carbon as this substation is also aiming to do. "
Members of the Public/Businesses
Mrs Samantha Hagan
"I would hate to see another sub station appear in Necton. We already have one which is massive and I can't imagine how awful it is going to look if we receive another one here. I have never wanted to live in a built up area and I love being in the countryside. We are slowing losing our green land around our village. I understand that there was a choice of other fields somewhere near Wendling/Bradenham which haven't got properties near them so I don't see why the sub station couldn't be built there. Necton is a beautiful village with lovely rural walks; please don't ruin it for us! I also feel that this sort of thing will de-value our homes. Where will it all end? Are we going to end up totally surrounded by these massive monstrosities? NO! We don't want anymore here - Please Yours sincerely Mrs S Hagan"
Members of the Public/Businesses
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
Nina Matthews
"Due to the size and height of the proposed substations and impact on the quality of the peoples lives in this very small community with little to obscure the view and noise I feel it will dominate the area with irreparable damage to the landscape, wildlife and well-being of all the communities around it. As I understand an alternative sight has been mentioned with fewer properties affected I feel it would be better moved there. I have many concerns regarding the duration and noise whilst it's being built, the longevity of the technology in the build and reduction of our house prices, the impact of light pollution, noise pollution, health risks and wildlife, all of which are why as a community we have chosen to live in such a quiet, unspoilt area. "
Members of the Public/Businesses
Samantha Neville
"I will be lodging my objections to the site due to the location and size and the effect on the residents, environment, housing and the future."
Members of the Public/Businesses
Clive Pellett
"HOUSE PRICES: Have already fallen with the arrival of Dudgeon. They have dropped further with just the possibility of this project. What effect will it have if it actually happens? WILDLIFE: There does not seem to have been a reptile or hedgehog survey done on the substation site. BATS: There are at least 2 rare species of bats on the site. EXISTING HEDGES: They are going to remove 1km of mature hedging and trees to make room for the substations. "
Members of the Public/Businesses
Tracy
"I cannot believe that vatenfal and the government are allowing this to go ahead so close to small villages. Trees won’t cover it and there must be a better place that isn’t viasbls to villages and the road. It seems that no one takes the locals seriously "
Members of the Public/Businesses
Fraser Bateman
"The consultation by Vattenfall was flawed as they failed to explain why Zone 5 was excluded from the search zone. The site chosen is situated on one of the highest points in the locality and with HVDC selected the housing buildings will be visible from many surrounding points. Tree planting will be total inadequate to mitigate this as these buildings are 20-25m high. There are existing field drains that will be destroyed during the construction phase and no adequate study has been made of these or what the effect will be on flooding on adjacent land. Vattenfall have failed to notify residents of their right to make representations under this scheme, I found out by "accident". How are residents supposed to comment if they are not made aware of their rights or the method to use. "
Members of the Public/Businesses
Mrs Bass
"I think the proposal is far too big and will make a blot on the landscape. Plus the extra traffic will cause more problems with turning out of our junction than we already have. There won’t be any jobs for local people as it will probably be run online remotely. I can’t see why Necton was chosen as surely something nearer Yarmouth would be a better idea"
Members of the Public/Businesses
David Matthews
"Vattenfall have not conducted any meaningful consultation with the Parish Council, quite the reverse it the case. At their public meeting, there were 15 members of Vattenfall staff, they refused to allow questions and intimidated those attending. I wrote to the Project Manager immediately after the event stating these facts. In choosing the highest site in Breckland, means that a number of local villages, as well as Necton will have a permanent view of this construction. Vattenfall refuse to offer anything to the Necton community, other than stating that there will be education and job opportunities, alas few in Necton will benefit. Once the cable routes are completed, most of those impacted will return to some normality, for Necton we will have the blight on our community for ever. David Matthews Chairman Necton Parish Council"
Members of the Public/Businesses
Frederick Albert Thompson
"Why put such a large structure so close to Necton village when if as I believe, there are alternatives at other less disruptive locations. Near housing at Necton of such a structure with it's inevitable pollution of traffic, noise and light will be to the detriment of the locality."
Other Statutory Consultees
The Corporation of Trinity House of Deptford Strond
"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 statutory role of Trinity House as a General Lighthouse Authority includes the superintendence and management of 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 Houses 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. "
Members of the Public/Businesses
Katherine Jones
"The proposed site for the Vanguard substations is unacceptably close to the sizeable village of Necton for the following reasons: 1) The substations are out of proportion for the site chosen (too great an area covered) beside an expanding village. 2) The visual amenity will be reduced. The 25 metre high converter halls cannot be screened because they are so tall. 3) The noise of construction from the Dudgeon substation was very loud and extremely annoying for residents for a long time. Vanguard is a bigger project so will be an intrusion for a longer period of time, particularly with Boreas following on. 4) The lighting at night during construction and commissioning of the Dudgeon substation was so bright that it disturbed the sleep of residents. Breckland Council received many complaints. Vanguard will also be working anti-social hours. 5) There is an increased road risk from the additional traffic on the A47. There are already regular fatalities on the road from Necton to Dereham. 6) An alternative, isolated site is available along the pylon line with good road access nearby. This site should be considered."
Members of the Public/Businesses
Mrs Julie Keay
"Unlike the Protest Group (who do NOT speak for all the inhabitants of Necton) I am not against the proposal which is far enough away from the village to not cause concern. As an ardent environmentalist I fully understand the need for additional green energy. More discussion needs to take place but may I promote the idea of one of our oldest residents - create a nature reserve by the site promoting wildlife and conservation and help the residents of Necton by providing some sort of compensation (eg: cheaper electricity or more money into community projects perhaps) "
Parish Councils
Witton and Ridlington Parish Council
"I am registering the interests of Witton & Ridlington Parish Council. We are gravely concerned about disruption, noise, disturbance to wildlife and general access throughout the process."
Members of the Public/Businesses
Tony Smedley on behalf of Richard Gill
"I object to the proposed sub-station development by Vattenfall on the grounds that its location, on one of the highest points in the area, will totally ruin the character of the villages of Ivy Todd and Necton. This goes against Breckland’s planning advice. The noise, dust and light pollution caused by its construction and operation will cause a decrease in house prices, which while not strictly against planning regulations is a sign that all kinds of inappropriate developments being allowed to run roughshod over rural farmland. The presence of the existing Dudgeon sub-station recently built at Necton has already caused house prices to drop. Vattenfall have said no amount of mitigation can hide the sub-station. This is in apparent contradiction of Breckland Councils Area Plan policy for developments. In addition I am concerned that there will be an increase in flooding of roads in the area which could lead to properties being flooded (as does already happen)."
Members of the Public/Businesses
Tony Smedley on behalf of Tom Gill
"1. My family home is in Ivy Todd, and I am shocked and concerned that such a large development might be permitted there. Any visitors to the village instead of seeing quiet rural lanes, and tranquil undulating countryside, will instead see giant 80 feet high buildings blotting out the views of ancient woodlands and causing a terribly negative impact on the local wildlife. The area has been found (by Vattenfall) to have at least 2 rare bat species, and no reptile surveys seem to have been done there. 2. The PEIR Document shown to us states that it is too large for the location, and no amount of mitigation will be effective for the lifetime of the project. 3. Construction and operation, over TEN years will cause dust, noise and light pollution in an area that is known and visited by tourists as a 'dark rural landscape'. The light and noise pollution will be made worse by Vattenfall coming back every summer (as they say) for up to two months and carrying out maintenance 24/7. 4. Flooding of roads around Ivy Todd and sometimes in houses is already known. Construction of the sub-station and covering field drains with another 55 acres or more will make this worse."
Members of the Public/Businesses
Christine Howard
"The following things need to be considered: My main concern is the massive size, because it breaks Breckland’s planning rules. It’s just too big to be hidden. This leads to the following massive problems: That house prices will drop - who would want to live near such a place! The possible radioactive substances they will dig up if they put it where they say. (Where a military jet crashed in 1996). Possible increased flooding in Ivy Todd. Light pollution. Traffic. The level of noise this will create. Health issues for children with Electromagnetic fields. All of the above concerns I would strongly believe show that they cannot build there."
Parish Councils
East Ruston Parish Council
"East Ruston Parish Council, as one of the parishes directly affected by the proposed pipeline, intend to make submissions regarding road closures, traffic management and arable land disturbances. We are pleased that there will no longer be any relay stations in our parish but none the less there will still be a considerable upheaval which we intend to monitor and report on. "
Other Statutory Consultees
Scottish Power Renewables
"This is a relevant representation submitted by ScottishPower Renewables (SPR) on behalf of East Anglia Three Limited, East Anglia Two Limited and East Anglia One North Limited (“the Project Companies”). SPR (on behalf of the Project Companies) may wish to participate in the Examination of the Development Consent Order (DCO) application for Norfolk Vanguard. Specifically, SPR may wish to make representations in relation to cumulative and incombination issues. SPR reserve the right to make further comments through the Examination process including, but not limited to, seeking protective provisions within the Norfolk Vanguard DCO. "
Members of the Public/Businesses
Better broadband for East Ruston (BB4ER) (Better broadband for East Ruston (BB4ER))
"Better Broadband for East Ruston (BB4ER) is a group which has been set up for over 18 months initially to lobby for a better broadband service for our community. On recognising that our rural area would be left behind in relation to obtaining an adequate broadband service fit for purpose now and most definitely in the future we have now embarked on a community broadband initiative. The aim is to provide a full Fibre to the home service for all that want it, to provide Gigabit upload and download speeds at an affordable price. The enterprise would be owned and run by and on behalf of the community. We have been discussing with Vattenfall the potential of them installing fibre optic cable in their trench as part of the community benefits that will ultimately form part of their proposals. We have presented them a costed feasibility study and had a series of meetings to progress the matter. Installing this Fibre optic cable would allow communities along the Vattenfall route to access to backhaul that would be provided by our own local community scheme thereby allowing other communities to benefit from similar broadband connectivity to that set out above. The rural area of North Norfolk is currently very poorly served by access to Fibre connectivity. This proposal presents a unique opportunity to help remedy this situation and therefore benefit a large swathe of Norfolk Norfolk and in particular the communities who straddle the Vattenfall trenching operations. Presenting this proposal at the formal examination stage would provide an opportunity for the planning inspectorate to consider whether there would be any planning issues associated with the practical delivery of this initiative. It would also allow some further public debate relating to the broadband proposal."
Members of the Public/Businesses
John Clarke
"I believe the sub station should be sited further away from the population even if it cost more for Vattenfall to create a remote site because the environmental and health impacts are unknown. Just because Vattenfall have decided Ivy Todd is the cheapest and the most convenient site site does not mean the village should pay the high price of having it located on their doorstep. Increasing jobs for people in Yarmouth and Lowestoft does counter balance the negative impact to the local people who are living with a substation in their back yards driving down their house prices and impacting their standard of living. "
Members of the Public/Businesses
Lorraine Clarke
"I live in a village close to the proposed site. I am seriously concerned about the damage to the village environment and its wildlife should the development proceed. I’m very concerned about the impact of the substation on the environment which Vattenfall does not fully understand now and niavely considers to be safe, but in years to come as science develops it could prove the opposite and we learn more about the dangerous side effects who fully knows how a substation so close to a village with families and young children could be affected? Humans built ‘safe’ buildings using asbestos and mundic years ago and both are now considered extremely dangerous to humans. Who in good conscience could say this sub station is entirely safe so close to a village without any doubt of future side effects? Just remember the Erin Brockovitch case in the US - someone needs to stop and think now while we can still can. "
Other Statutory Consultees
Cadent Gas Limited
"Representation by Cadent Gas Limited (Cadent) to the Norfolk Vanguard 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 Vanguard 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 low or medium, 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 the potential impacts on its network with the promoter however adequate protective provisions for the protection of Cadent’s statutory undertaking have not yet been agreed between parties. 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. "
Members of the Public/Businesses
Glenn Berry
"We have concerns over traffic movement for land fall site road closures Land fall on one of the fastest eroding coastlines in UK What happens about the industrial legacy of the land fall site and cable joint bays at the end of the project. "
Members of the Public/Businesses
James Bellingall
"A large amount of Norfolk causing years of disruption to traffic will be caused by the digging of 2 enormous trenches for the feeds from the wind farms to their connections into the National Grid. The fact that these feeds cross near to Reepham means that the amount of disruption would be less if the connection points were swopped over. The total length of the combined trenches would be reduced by between 20 and 30 Kms."
Members of the Public/Businesses
Jeff Shalloo
"1 This project is going to ruin the local village of Necton and the surrounding countryside due to the sheer size and magnitude of the structures. 2 The devastation of existing mature hedges along with the destruction that the laying of approximately 50 miles of cabling across the county will cause. 3 Along with the volume of houses being built and now this project how is the existing countryside going to cope with the level of flooding as seen by this last winter. 4 Who is going to be responsible for the protection of this soft target and the wider local population from terrorism because unless the counties police force is going to get a massive injection of funds they will not able to cope with a major incident. 5 The noise that this project is going to generate is going to be way outside acceptable levels for both the local people and wildlife. "
Members of the Public/Businesses
Mrs G Watson
"We live less than 200 metres from an original proposed site for a massive AC Relay Station, yet were left out of many important consultations and our home was not included at all in the publicity about affected neighbours and the proposed locations sent Norfolk wide. Although Vattenfall have promised they are now seeking permission for a DC system, meaning there is no need for an AC Relay Station beside our home, we would still like to follow the planning process and ensure there is no deviation from what we have read will be applied for, either pre or post planning consent. Secondly, the cable route is still close and our only road access will be heavily used for the infrastructure; for where the cables arrive onshore; and the digging and laying along a long section of the cable route. These are small, rural, quiet roads and not designed for such heavy use or large equipment. It is a peaceful, unspoilt, rural, agricultural area, with fragile buildings and we are worried about the impact of such a major, long term project, (noise, working hours, equipment, routes, damage, reinstatement, etc)."
Members of the Public/Businesses
Mrs S Shalloo
"1. Traffic: The main A47 arterial road through Norfolk struggles now on a day to basis with the volume of traffic, what on earth will this then be like with the amount of construction traffic that will be required to create this substation. Sat Navs do not always send traffic the recommended route, what impact will this have on Necton a small rural village. 2. House Prices: We have already seen a decrease in house prices in Necton and the surrounding villages with this proposal in place, it can only get worse if this project gets the go ahead. 3. Wildlife: The devastation of acres of countryside to lay the cables to the substation and then the acres of land claimed to build, will have a Huge impact on various wildlife habitats. Once this land is gone it cannot be reclaimed. 4. Norfolk is prone to wildfires in dry weather as can be seen in Swaffham recently (5 miles from Necton), this site will be surrounded by fields of dry crops. We only have a retained fire service not a full time one, who would deal with any major incident at this site? 5. Light pollution: Should this project go ahead it will have a huge impact on the sleep patterns of both humans and wildlife. Along with the impact that the ongoing noise of the substation will create that is not necessarily audible to humans but will effect species who use sonar to navigate. 6. F16 Plane crash: Concerns over radioactive risk due to the intention to run the cables through the site of the crash that has previously been classified as contaminated land. "
Members of the Public/Businesses
No to Relay Stations (N2RS) (No to Relay Stations (N2RS))
"N2RS outlines its position and areas of interest/concern below but may wish to make further points in the future - and it is our clear intention to be present and speak at future hearings. N2RS was established in April 2017 amidst concerns about the impact of major onshore infrastructure to support the Norfolk Vanguard (and Norfolk Boreas) offshore wind farms. Its main focus was on the choice of technology: HVAC technology would have required cable relay stations, replacing productive agricultural land and leaving a permanent industrial legacy near the coast in North-East Norfolk. Whereas HVDC technology would negate the need for cable relay stations, significantly reduce the cable width and reduce the impact for the majority of people along the cable route. N2RS and its supporters – including East Ruston Parish Council - worked tirelessly throughout the formal and informal consultations to raise awareness amongst the local community and encourage constructive engagement to ensure the project was fully debated by elected representatives the media and other interested parties. N2RS recognised the need for renewable energy but felt it must be achieved with due regard and respect for the environment, homes, businesses and wildlife. N2RS therefore called upon Vattenfall to adopt best practice at a corporate level, by committing to an HVDC transmission system – as the least environmentally damaging choice of technology for this and future UK projects. Vattenfall’s unequivocal commitment to HVDC has therefore been warmly welcomed by N2RS. As the Planning Inspectorate scrutinises the results of Vattenfall’s formal consultation, the strength of support for HVDC should become apparent and any deviation from this preferred system (pre or post consent) would undermine the planning process and would be totally unacceptable to the communities and stakeholders who have supported the HVDC route. The advantages of an HVDC are reiterated below • No cable relay stations will be required in unspoilt countryside near the coast • The cable corridor width will be reduced from 100 m to 45 m • The local landscape and countryside, which is key to the area’s character and its popularity with tourists, will be protected from permanent industrialisation. • Local wildlife (which includes many protected species) will no longer be threatened by loss of habitat due to cable relay stations. • Construction traffic, which would have impacted on nearby quiet lanes posing a real threat to tourism and to the quality of life of locals, will be reduced from eight years to two. • High-grade farmland will no longer be lost to cable relay station sites and disruption to farm operations will be reduced. • Ancient bridleways such as Munn’s Loke – the home of diverse wildlife and a much-valued local amenity – will not be lost or compromised. • Tourism businesses – holiday cottages, seaside parks, cafes and restaurants – will not be at major risk due to long term uncertainty, loss of reputation and loss of business or closure. Landfall at Happisburgh N2RS welcomes the commitment by Vattenfall to Horizontal Directional Drilling (HDD) at Happisburgh and its guarantee that the beach will not be needed for access. However, Happisburgh is facing major challenges due to rapid cliff erosion. Homes have been lost and others will be under threat if erosion accelerates at this current pace. Over time this threat will be extended to inland villages and even the Broads. An opportunity to make landfall at an existing site at Bacton (which we believe may now be deliverable with the HVDC option) has been lost. This was partly due to restraints set by the Marine Conservation Zone – but given that the MCZ has already been breached by gas pipes and that the seabed will presumably recover (as we are led to believe is the case with the land) N2RS is disappointed that the Bacton option was so quickly dismissed and this should be a line of enquiry during the inspection process. Additional points Although welcoming the HVDC decision and acknowledging the significant extent to which it reduces impact, the project will still affect some individuals and communities, especially where the cable corridor runs close to homes and businesses, where traffic is disruptive and where it connects to the Grid. N2RS submits that: a) Due regard should be given to homes and businesses which are still directly affected by the wider plans - and loss in property value and quality of life should be taken into account. It should not fall upon individuals to bear the brunt of schemes like this and those affected must be properly compensated. This would include owners of holiday businesses who will lose trade during construction and possibly suffer longer-term loss of reputation. b) The intrusion into the countryside should be kept to an absolute minimum and the developers should continue to liaise with local people to utilise their knowledge and experience so that homes, the quality of life of individuals, businesses and wildlife do not suffer unnecessarily. c) Vattenfall should continue to communicate with those who have expressed an interest in this project directly to inform them of major milestones and any aspect that will affect nearby communities – such as road closures and improvements. d) Once construction starts, local people should have an effective means of contacting the developer or project team especially in emergencies where for example there is evidence of harm to wildlife, flooding or other unexpected events. e) Vattenfall’s project team should recognise the importance of tourism and ensure wherever possible that works will not impact on the area during peak tourism periods. The impact on tourism businesses during construction and loss of reputation should be compensated. Finally, the rights of local people to enjoy their surroundings out of peak hours should also be respected. N2RS.org.uk "
Members of the Public/Businesses
Ray Pearce
"Due to the current licence for allocation of connection points to the NETS, held by National Grid (NG) plc, the allocation of planned connections from offshore developers is on "a first come first served" basis and not co-ordinated. The most expeditious routing to the NETS will not be utilised which will have a detrimental environmental impact for the on-shore environment. Norfolk Vanguard's cables are planned to cross with the cables from the Hornsea Three project but the combined impact from both projects, at the crossing point has not been fully examined, despite the potential for up-to 6GW of energy flowing through this point. Vattenfall have yet to divulge how they plan to engineer the crossing point or what the combined environmental effects will be. "
Other Statutory Consultees
The Coal Authority
"I have checked the site location plan against the information held by the Coal Authority and can confirm that whilst the area falls within the defined coalfield, it does not contain any recorded risks from past coal mining activity likely to affect the development. On this basis we have no specific comments to make."
Parish Councils
Holme Hale Parish Council
"The choice of site is inappropriate, and other more appropriate sites have not been given due consideration. The size of the structures involved in this application are disproportionate to the rural setting/location, and it is unlikely that screening efforts will mitigate the impact on surrounding villages. Light pollution and noise pollution will have a severe detrimental effect on the rural landscape and nearby residents. Construction traffic will increase the hazards on the A47. The high number of accidents along this highway make it unsuitable for further extensive HGV useage. The sheer scale of the infrastructure, and the extensive industrialisation to be carried out, is totally out of keeping with the area. Immense environmental damage will result from this process, and this will be ongoing for many years. "
Members of the Public/Businesses
Kerry Murray
"I am against plans for any more developments of this type as I live very locally and don’t believe there’s been enough consultation no one knows of any health risks it’s destroying our countryside which is the reason we choose to live here!! From normal people’s point of view it’s just making the landowners a lot of money!! No one considers local people views and really can’t work out why Dunham one didn’t go ahead but Necton did something suspect about the whole thing "
Members of the Public/Businesses
A C H Pearson
"With reference to the planning application by vanguard number EN010079 I wish to entre my objection to this for the following, reasons substations to be built if permission is granted will cause harm to infrastructure and blight all homes in Necton area because of its size and position, as one substation has already been built another would completely destroy the area therefore I consider and apply for this planning application be denied"
Members of the Public/Businesses
Dr A E Daniels
"As a regular visitor to Necton, I have been very much aware of the visual impact of the substation close to Necton village. I’ve seen the recent publicity concerning two additional, much larger substations for the Vanguard and Boreas wind farms that are planned to be sited close to the current substation. In my opinion, the extent of these substations will have a significant negative impact on my (and many people’s) enjoyment of the rural nature of the village and it’s surroundings. I believe there is an alternative position for these larger substations which would have much less of an impact on its surroundings. I strongly believe the substations should not be sited close to Necton when a more appropriate site is available. "
Members of the Public/Businesses
Jeanette Webb
"When Statoil applied originally for the planning to erect the substation in Necton on the A47 there was no mention of making an extension or an additional 2 substations. Whilst the village understands the Government has commitments to supply green energy but how is this benefiting our village as it is going into the national grid. The substation is right at the side of the A47 and inspite of the attempts of screening it is an eyesore and has an impact on our environment especially as we are a holiday destination and a county of big skies. I am also worried about the impact of health and the risk of cancer and other illness'and the waste products from the electricity production going into the land and water table. This potential substation is surrounded by farming. Why cannot the substations be spread throughout the county? and not just all put in one place they will really be a blot on the landscape and I for one are really disappointed in this planning application and sincerely hope real consideration is given to the whole area and not expedient of shareholders of China, Norway etc."
Members of the Public/Businesses
Norfolk Coast Partnership
"I am responding to the Vanguard consultation of August-September 2018 on behalf of the Norfolk Coast Partnership, guardians of the Norfolk Coast Area of Outstanding Natural Beauty. I have had contact with the Vanguard project to date via: • Attendance at a drop-in session in March/April 2017 • Participation in the landscape expert topic group • Attendance at meetings where Vattenfall have given presentations • Posted consultation letter and memory stick My comments relate only to the potential effects of the development on the landscape quality of the Norfolk Coast Area of Outstanding Natural Beauty (AONB) and on the views from the AONB. I have not commented on the environmental or visual impacts of the turbines as we believe they will not be visible from the AONB. I have not commented on the local viewpoints closer to the proposed landfall site and/or the impact on the landscape outside of the AONB boundary. I have not assessed or commented on any impacts on the marine environment or on the wildlife of the area though, particularly bearing in mind the bat roosts in Paston Barn and their wider feeding corridors, I suggest that Natural England is consulted. The current 2014-19 Norfolk Coast AONB Management Plan has a Policy (PC5) to ‘Support the development of renewable energy in the area in ways and locations that contribute to the area’s local economy and jobs and maintain its natural beauty.' However, the National Planning Policy Framework emphasises that the impact of a proposed development is an important consideration, including the cumulative landscape and visual impacts. It states that ‘Great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty’. As renewable energy schemes, and particularly large wind power schemes, can have a highly significant impact on the natural beauty of the landscape, we approach each project on an individual basis. The Norfolk Coast Partnership thanks Vattenfall for early identification of the Norfolk Coast AONB and for the decision to come ashore outside of the area boundaries. Landfall is to the south of the AONB boundary at Bacton and none of the infrastructure runs through the AONB. We note that works require Rights of Way to be blocked, particularly the England Coast Path. We suggest that this should be undertaken in a way to ensure continuity for walkers, for the minimum time and with appropriate diversions clearly signposted. We thank Vattenfall for selection of HVDC technology, which will minimise the impact on the Norfolk Coast AONB. We anticipate that some of the construction and final infrastructure may be visible from the Paston area of the AONB and suggest that impact should be minimised, e.g. through good control of any site light pollution. We suggest that construction traffic should not use routes within the AONB to access the site. We suggest that the cable should be brought ashore in a way which does not alter/impede the coastal processes, e.g. of sand movement. Thus, we suggest use of remote drilling from out at sea coming up behind the cliffs rather than any disturbance to the beach, either during construction or project life. We suggest that the wider community and landscape should benefit from the project. We applaud Vattenfall stated commitment to use of local products, suppliers and contractors and hope that this is maintained through-out the project. We are interested in forming good, collaborative relationships with the businesses in our area and would welcome working with Vattenfall to deliver benefits to local communities and the local environment, e.g: • Vattenfall sponsorship of specific Norfolk Coast projects in the AONB • A Vattenfall/AONB grant scheme In addition, we recognise a very important gap relating to local children and young people, who do not receive information about the environmental importance of their local area or the opportunities available to them for a career in the environment sector. Some ideas for filling that gap include: • An education programme for local schools, teaching children about their local environment and also about the value of Norfolk’s protected landscapes. This could be combined with other topics, such as renewable energy. • An apprenticeship scheme, allowing local young people to gain experience in the environment sector. This could be combined with other topics, such as renewable energy. • An undergraduate/graduate scheme helping students to learn about the Norfolk environment and go on to gain their first jobs in the area/sector. "
Members of the Public/Businesses
Barbara Champion
"I have only lived in Necton for 8 months. The Vanguard project was not revealed to me on any of the searches carried out by my solicitor prior to purchase of my property and I suspect that I would not have continued with the purchase had I known of the massive substation (30 metres or so) that is to be built in the fields outside Necton. I consider that this project will have a devastating impact on the lives of the residents of Necton and on the environment. To put it bluntly, it will be a hideous blight on our lovely countryside and one wonders why a suitable place could not have been found in a rural location, where it would not impact on village life. I fear it will also have an impact on house prices and turn Necton into another Bacton of Norfolk"
Members of the Public/Businesses
Alison Cracknell
"I am objecting to the proposed Vanguard and Boreas substations to be built at Necton for these reasons. 1. we are a small village and will have 3 substations (70 acreas in all) on our doorstep, which will be unsightly on the landscape, cause disruption for several years, cause traffic chaos, disturb the peaceful nature of the area, cause light pollution, noise pollution. House prices have fallen already. Flooding is a serious concern. Wildlife and farming are affected. 2. Vattenfall have not communicated honestly and given accurate facts. 3. Other suitable sites have been put forward but ignored as possible alternatives 4. The proposed amount of energy to be produced is in no way proportionate to the extreme disruption across Norfolk."
Members of the Public/Businesses
Bernard Smee
"(1) The residents have been misled and misinformed regarding this project from the start. (2) On the onset of this project residents where informed that the present site plus one other was being planned. (3) Now it appears that an additional building is being planned, the whole site covering an area of approximately 55 square acres an 80 feet tall. A total blot and eyesore on the countryside. (4) Vattenfall have admitted that tree planting will not hide the site----what trees grow to 80 feet in a few years ??? (5) The noise level must surely be exceeding the environmental requirements to the detriment of the residents and wildlife. "
Members of the Public/Businesses
Edward Sharples
"I would like to insure that as part of the planning that proper provision is made for screening of the site from all aspects. This screening should be structured so that it provides both visual and also noise screening, it will therefore need to have both the height, suitable species make-up and physical density to ameliorate, to the greatest extent possible, the visual and noise impact of the site on the surrounding area (bearing in mind that the site chosen is on a ridge.) These measures should be commenced as early as possible before construction starts. There must also be an obligation on the site owners to maintain and improve them on an ongoing and continual basis."
Members of the Public/Businesses
Mrs Susan Smee
" Lack of trust- A)Either being fed the wrong information i.e.. lying. There are examples from various meetings. B) Drip feeding information when 'the bigger picture' would have been more honest and fair. The eventual size of these substations is much, much larger than the original proposal. Local communities should have been made aware of all potential developments at the beginning- instead this has been railroaded through with the local community on the back foot. C) Ignoring local community suggestions,(which were viable as stated by the National Grid) Vattenfall indicated it would consider these but did not. Reason? cost alone D) The size- over 70acres of substation could provide a security risk to the local population as well as taking over valuable farmland and peoples homes. E) Noise- it is difficult to see how with all the extra substations,National Grid extensions etc how this will not be a problem noise enforcements have been imposed on the area. F)Mitigation- demonstrated already on the existing site that this is the last project to be done. Consequently the area is surrounded by tiny saplings that would take years and years to reach the appropriate size. Future constructions have been altered and will be much taller, so tall that their presence will be evident for miles around- a real life 'blot on the landscape' and the mitigation (advised by local experts) of layered planting schemes of differing heights using native trees will be ineffectual. Vattenhall has recently admitted that mitigation in this case will not be successful, as the buildings will be too big! I submit this outline arguing that with such a track record, it is difficult to believe what ever is said or proposed and that the local population are not considered and that the greater good will prevail. "
Members of the Public/Businesses
Amanda Bullen
"I want to know more about what is intended to be built at Necton concerning land size and height, how this will impact visually on the local area and what measures are being taken to limit impact. I also want to know what financial contribution will be made to Necton for this massive construction being made here. If Necton is getting this development to appease other potential sites in Norfolk then the village should get some recompense!"
Members of the Public/Businesses
Ashley Christian
"With the building of new substations near necton can only mean more traffic for the area, in order to alleviate this, I believe vattenfall should invest in the roads around necton, particularly the A47. This road is already difficult to join, so a roundabout would be ideal to allow ease of access for the locals. This road is also very dangerous for the school children, having to cross a 50mph road during peak times. This would be a drop in the ocean for vattenfall, but would be a smart investment in keeping the residents happy"
Members of the Public/Businesses
Kevin Miller
"I believe that this development is in the best interests of the UK in providing clean energy for future generations. Whilst I live in the village which where the central hub and link to the National Grid are intended I believe it is far enough away from the village not to be a problem. The company are intending to ensure the site is properly hidden by a natural landscaping and as such are endeavouring to protect those few properties on the edge of the village from noise and light pollution. I believe the project should be approved so that work can properly commence."
Members of the Public/Businesses
Graham Cracknell
"I am a resident of Necton and want to register my objection to the proposed development of two more substations on the site near Necton village. My reasons include:- It will be an unsightly scar on the landscape near my village and consequently Necton now is affected by a drop in house prices, a name associated with 3 substations, an increased problem with traffic, several years of construction disruption and noise, more light pollution, wildlife affected and much more. Vattenfall have not conducted any investigations into alternative sites and in their dealings with the public have not been open and honest. Why can they not find a site closer to the coast? Vattenfalls publicity pretends to show that they have support whereas in fact they dont from a vast majority of people. "
Members of the Public/Businesses
Allan Stanley
"There's no economical or financial benefit to the people of Necton whatsoever and furthermore it was be of detrimental impact environmentally and visually and could adversely affect property values in the village. Necton does not want to become another blot on the landscape of Norfolk. "
Members of the Public/Businesses
Ann Lumsden-Bedingfeld
"I would like to register my wholehearted objection to the two new substations and National Grid extensions planned for Necton. The village will be swallowed up by these monstrosities running alongside it."
Parish Councils
Cawston Parish Council
"Vattenfall – Norfolk Vanguard Offshore Windfarm and Associated Onshore Cable Route Summary We have concerns regarding the traffic impact through Cawston. This relates to the fact that the proposed mitigation, given the increase in HGV traffic, does not appear to be adequate. We also have concerns with regards properties adjacent to the B1145 and request further consideration is made of these. "
Members of the Public/Businesses
I.B. Sharples
"1. That the noise levels be ameliorated (a) during construction as to times when work can be carried out. and(b) adequate screening by trees which is covenanted to be maintained permananently thereafter 2. The water discharge from the roofed or concreted areas be adequately stored and only released in the water courses in such a way as to prevent damaging surges lower down the water courses particularly after any period of snow or heavy rainfall. I.B.Sharples"
Members of the Public/Businesses
Denise Ann Axham
"The PIERS in incorrect as Vanguard have not done a full investigation or conveniently left out facts that they consider could be a threat of there submission being turned down. There was a plane crash in 1996 that farmers were unable to use the land for several years afterwards (told by the MOD) so what was the RAF plane carrying? Vanguard new nothing about this and if land is disturbed will there be a threat to ourselves in any way & Vanguard guarantee it? As the tallest station in the world why should it be so close to a village of more than 1700 people (not a Hamlet stated by Vanguard) Therefor re locate the substation to a place where there are very few if any people living close so we are able to have both what they and our village want. "
Members of the Public/Businesses
Diana Daniels
"Agreement with proposal Request that necton receive adequate compensation."
Members of the Public/Businesses
Robert Sutton
"To Whom it may concern, I am totally against the planned two new substations to be built at Necton. We already have a large substation why do we need to suffer two more? The new substations are going to be very large, unsightly and will blight the surrounding area. This will reduce the local property values which is a major concern for all. Increased construction and general traffic will further stretch the local infrastructure and roads. Please, please, please do not build these substations near Necton. Your sincerely, Robert Sutton"
Members of the Public/Businesses
Tracey Collett
"Concerns over the disruption to the village during the works- part of which is directly next to my home and land. What effect this may have on the already terrible coastal erosion here. "
Members of the Public/Businesses
Tony Smedley on behalf of Westbrooke Holidays
"Our holiday let business thrives on repeat business from star-gazers. Light pollution from the site could damage our reputation forever. Especially when they say that even after the build has been completed, Vattenfall are coming back every summer to do 24/7 maintenance for up to 2 months! Google maps will show the new substations (as they show Dudgeon now) and this will be very off-putting for holiday-makers as Vanguard and Boreas will be much closer to us than Dudgeon is. Flooding in Ivy Todd – the route to our business for tourists has become worse since Dudgeon started up. The clay soil they intend to cover in concrete has always relied on land drains to get the water away. We understand these land drains will be removed. There is only one small tributary that takes water away. If this floods more there is a danger of the Ivy Todd bridge being swept away. We also understand there is some radioactive substance risk right in the path of Vattenfall’s 400kV cable corridor, and that they are determined to dig it up regardless. This is very worrying indeed, and surely there must be an investigation into this before any permissions can be decided, for the sake of the health or residents. This project is far too big to be squeezed into this area, and even Vattenfall have admitted that it breaks Breckland Planning Regulations in this regard. There must be better, more suitable places to put this along the pylon line closer to the coast, without destroying so much farmland."
Members of the Public/Businesses
Leda N Hayton
"My family and I have lived in the rural hamlet of Ivy Todd, next to Necton, for 32 years and during that time we have enjoyed the benefits of life in a small community. The Dudgeon Substation was an unwelcome addition to the area but the residents tolerated it. It continues to be a nuisance to residents with noise and light pollution. However, we now find ourselves with the possibility of 2 monsterous further substations totalling 80 acre + on our doorstep. This will blight the community forever. The proposed structures are unsuitable for the location chosen by Vattenfall. They will be on a high point very close to the villages of Necton and Ivy Todd. Other more suitable locations have been suggested to Vattenfall but were rejected due to cost and other considerations known only to themselves. The so-called consultation period has been a shambles with numerous mistakes. The community has little faith in this process. I could go into detail about local petitions, MP involvement, wildlife and hedgerow destruction, traffic, possible terrorism threat, military plane crash land contamination, flooding issues with such huge structures near the Ivy River, property depreciation, visual pollution, etc. I might add to this that the landowner does not wish to sell his land. I would suggest that an alternative location be sourced with less disruption to citizens. I am convinced that there will not be any benefit of substance either financially or in terms of local employment from this build. Necton has been well and truly stuffed. "
Other Statutory Consultees
response has attachments
Natural England
"Dear Sirs Natural England is a Statutory Nature Conservation Body (SNCB) and as such provides nature conservation and landscape advice to regulators for NSIPs. Therefore we wish to be considered as an interested party in the Norfolk Vanguard NSIP examination. Due to the size of Natural England's relevant representations we have emailed them directly to PINS. We would be grateful if our email dated 31st August 2018 could be accepted as our RR. Thank you and kind regards Louise Burton Natural England Marine Senior Adviser"
Members of the Public/Businesses
Bryan Oldman
"The digging up of many miles of Norfolk countryside to lay cables is wasteful and disruptive. It would be better if these and the other companies intending to lay cables instead paid for the High Voltage National Grid to be extended to a convenient location in North Norfolk which would allow all current and subsequent planned North Sea wind farm cables to join the National Grid close to landfall. "
Members of the Public/Businesses
Jan Burley
"Connection to the National Grid should be done Offshore by Offshore Ring Main which I understand the National Grid agree is a possibility, thus no digging up of anywhere across the countryside would be necessary. This should be the way forward for all Offshore windfarms. I am seriously concerned about the impact this project will have on Happisburgh as the landfall site:- The running track goes right through the village cutting it in half and the outline management plan shows all but one road in the village will be stopped up; the remaining road is impacted by significant HGV movements. This is exacerbated by the fact that this is the first of two projects. The cliffs at Happisburgh are extremely fragile and Vattenfall have failed to alleviate concern about the impact drilling under them may have particularly the potential risk of flooding to the Norfolk Broads. "
Members of the Public/Businesses
Pauline Carter
"We don't want more disruption to the village and we already have a wind turbine on the A47. "
Members of the Public/Businesses
Mrs Paula Woodings
"Road closures that will effect our local area. Beach closures. Traffic congestion. Impact on our peaceful location. "
Members of the Public/Businesses
Andrew Lockwood
"During July 2017 I attended Vattenfall's Project Substation workshop displays. The experts on hand didn’t have local knowledge and found it difficult to answer specific questions about the Necton project. They could only comment in a generalised way, which was disappointing and concerning. Vattenfall were showing nearby residents a mock-up of visual impact, as seen from their homes. The closest residents are at Ivy Todd Farm, my in-laws, and are only approx. one third of a mile away. When I asked to be shown the projected view from Ivy Todd farm I realised they had left out the proposed National Grid Extension. I feel they should have been more honest when showing us what the potential visual impact would be; it was misleading or incompetent to leave out such a large structure. Vattenfall refused to look at alternative locations although other viable sites were suggested. The whole process left myself and many residents concerned and angry. Based on this alone I have no confidence in how Vattenfall will handle such a huge undertaking and what omissions and mistakes they could make along the way, especially as they do not seem to take local knowledge into account. If there are several hours of rainfall a tributary of the river Wissey running alongside the farm regularly floods. How can we trust that their construction, very close by, would not make this worse? I am also concerned about unnecessary damage to the local environments/habitats. In all of their consultations and literature Vattenfall never mention inefficiencies and what happens on still day/weeks when there is little wind, it only gives a one-sided argument which is not realistic and again misleads the community. I think property blight is another major concern, devaluating homes in Necton and making them more difficult to sell if a house move becomes necessary. As a part owner, with my wife, of Ivy Todd Farm this would have devastating consequences devaluing the farm and stopping farm diversification into a holiday let business as this relies on the tranquil rural nature of the area. "
Members of the Public/Businesses
Debbie Dunne
"The effects on a beautiful coastal village which is already fighting for survival "
Parish Councils
Necton Parish Council
"The Parish Councillors of Necton unanimously believe that given the constraints listed, the small rural parish of Necton is not a suitable location for this massive industrial development, which when completed will be the biggest of its kind in the world, and when viable alternatives exist. 1) Flawed public consultation: ? Insufficient information on the National Grid extensions ? Inaccurate inflation of distance to nearest property ? Incorrectly stating no other suitable connection sites. ? Allowing comments on 4 footprint options to just an invited audience. 2) Radiation Risk: Vattenfall claim ignorance of the 1996 Danish air force F16 crash site which lies central to their 400kV cabling, and the associated radiation substance risk warning (given to MAFF in 1996, NGR TF 894100). NCC informed Vattenfall of crash and radiation risk on 5 June 2018. Insufficient space exists for this development between protected archaeology and radioactive risk. 3) Flood Risk: Proposed site capped by thick layer of impervious clay. Run-off taken by a small tributary (Wissey) that historically and regularly floods the road and nearby properties and blocks the 4” culvert. Inadequately addressed. (NB Dudgeon already made this worse). 4) Breckland Noise Limit: We doubt the noise constraints required by statute can be met when the three sub-stations: Dudgeon, Vanguard & Boreas are working at full capacity. The elevation of the chosen site means noise mitigation measures will be difficult and expensive and suspect they will be ignored. Vattenfall refuse to build an earth bank. 5) Breckland and NP Restrictions: Vattenfall state the development is too massive to be screened from view, and does not fit into the rural landscape. (PEIR ref: Chapter 29 - Table 29.18) Vattenfall admit it will not comply with the Breckland Local Plan which states: “Development…should be of a scale and design that respects the character and rural setting of the settlement.” And “All design proposals must conserve or enhance the existing character of an area.” It lies on Grade 3 agricultural land so doesn’t comply with the NP Planning Framework 2012, which requires the loss of more than 20 hectares (approx. 50 acres) of BMV to be avoided if possible. 140 acres plus of BMV will be lost from arable use when all infrastructure and landscaping is complete (includes Dudgeon) Vanguard and Boreas alone mean 100 acres lost. 1) Four of the five holiday let/camping sites nearby ignored. 2) Two species of rare bats ignored. 3) Fire Risk: Inadequate measures against field fire risk to substations. eg firebreaks and fences. Adequate protection would increase the amount of land required. Approx. 200 field fires in Norfolk in 2018. 4) Terrorism Threat: This major project (the biggest of its kind in the world + Dudgeon) is an attractive target for terrorists; the nearby woodland makes this site difficult to defend. In consideration of these points, the Parish Councillors of Necton would like you to insist that Vattenfall and The National Grid choose an alternative site."
Members of the Public/Businesses
Patricia Lockwood
"Since my father passed away I own part of Ivy Todd Farm, Necton. My family have lived there since 1956. My mother is almost 83 and doesn’t want this very large, intrusive, overbearing industrial site in such close proximity. How can creating an industrial eyesore next to a village be acceptable? My brother and mother rely on our small 80-acre farm for their income, which is a struggle, and the potential opportunity of farm diversification into a holiday /leisure business would be lost. I feel that National Grid’s connection offer at Necton ensured the most economical and easiest engineering route and consequently Vattenfall have not fully investigated more appropriate locations further away from Necton. Vattenfall’s consultation didn’t give informative, truthful answers; it was manipulative exaggerating any positives which were not always applicable to Necton, i.e. creation of jobs and enhancing the area. At their invitation only workshop, July 2017, their representatives were flustered and not willing to let people ask questions, leaving residents very frustrated. Vattenfall gave poor projections of visual impacts and tried to show how planted screenings would disguise the site, initially missing out Dudgeon substation extension altogether, misleading residents. No mitigation measures of planted screening can hide the substations as they sit on high ground. Vattenfall would not commit to Ac or Dc so residents couldn’t understand the full implications of the proposal. I also question the accuracy of Vattenfall’s findings, their honesty and competency and I would like to comment on some of their reports and also relative legislation, acts and protocol. The substation would be built on agricultural land draining into the stream running alongside Ivy Todd farm which regularly floods, once coming through the house, so flood risk needs emphasising and given due consideration. The small distance of dry summer corn fields that join the substation area and Ivy Todd Farm could constitute a fire risk and my mother is also fearful of terrorism, having lived through the war. Residents have chosen to live a rural life, where industrialisation is not acceptable and neither is extra noise, both operational and during the 10 years of construction. Vattenfall’s site location could have been further away from the village but they did not research other locations which I feel is negligent. Even the National Grid’s “Horlock” rules advise avoiding populated areas when possible. Health and wellbeing of my family, and others, is paramount and this is already causing anxiety and depression; research cannot totally rule out health risks from such a vast field of EMFs. It seems Vattenfall will dig through a F-16 jet crash site where the ground was contaminated, possibly with depleted uranium. Several nearby residents including my mother and father have [had cancer, causing my father’s death], so we don’t want to live with the consequences of disturbing this potentially hazardous site. I would also like to comment on Human Rights and proportionality; Why should something so vast and out of context be sited next to a small community? "
Members of the Public/Businesses
S Bernard
"I object to the Norfolk Vanguard site as it too close to Necton village and surrounding villages, the size, scale, noise is too big. It will be an even bigger blight on the landscape, the current site can already be seen on approach to Necton which is a blight on the landscape. I believe an alternative site can be used but Vanguard do not want to spend any money to do this, Necton is too convenient for them. Instead of digging up acres of land from the coast to Necton I suggest a site should be found nearer the windfarms."
Members of the Public/Businesses
Scott Sidey
"The chief concerns that I would elaborate upon in future documentation would be; 1) The prospect of such an expansive, disruptive building site with all of its' noise and dust implications, potentially for years to come, threatening to be particularly stressful to immediate residents. 2) EMR issues from such a vast fully operational site and within sight of an expanding Primary School and Village. 3) Potential long term security risks from terrorist attacks, however unfeasible that may seem currently.. 4) A permanent eyesore amplified by an elevated position against a typically rural backdrop. 5) Changing the trajectory of the village towards more industrial use. 6) Increased flooding within Necton due to over-development of an agricultural site. "
Other Statutory Consultees
response has attachments
Environment Agency
"Dear Sir/Madam APPLICATION FOR A DEVELOPMENT CONSENT ORDER FOR THE NORFOLK VANGUARD OFFSHORE WIND FARM – SUMMARY OF RELEVANT REPRESENTATIONS. Environment Agency – Summary of relevant representations This letter provides a summary of the relevant representations submitted on September 2018. Code of Construction Practice (CoCP) We welcome the various undertakings in the Outline CoCP to consult with the Environment Agency. We consider that this should be expanded to other activities and also be reflected in the Requirements. We request that Requirement 20 in the Draft Development Consent Order includes a requirement that for each phase a code of construction practice and associated pollution control plans are submitted to and approved by the Environment Agency prior to works on that phase. Ground Conditions and Contamination We concur with the proposed approach and protocol to address unexpected contamination and waste soils but further consideration should be given to the following: • the impacts of mobilising existing contamination on excavation • the sensitivity applied to unlicensed household water supplies • more detailed assessment of potentially contaminated sites at Happisburgh, near North Walsham and Necton. • the impacts on shallow wells in close proximity excavations Water Resources and Flood Risk We have made comment in respect of the following: • crossing of Whitewater River and associated flood risk • that excavated materials must not be stored in the floodplain • shallow aquifer groundwater flow • consultation on private water supplies • monitoring schemes for pollution remediation and crossing schemes • errors/omissions noted for Map.1.Bedrock and superficial aquifers, Bedrock geology maps and WFD Compliance Assessment table 20.2 Onshore Ecology We have made comment in respect of the following: • the presence of a Sand Martin colony close to a SSSI • the importance applied to local and County wildlife sites • advice regarding fish passage at open cut trenched sites Consents and Licences required under other legislation We have made comment in respect of the following: • advice regarding environmental permits or disapplication required Protective Provisions The Applicant seeks to disapply various pieces of legislation (Article 43, Schedule 16, Part 7 of the draft Development Consent Order submitted with the application). We are currently considering our position in relation to the legislation which is relevant to the Environment Agency and the suggested draft protective provisions included in the draft DCO which accompanies the application. We will be responding to the Applicant on these issues in due course and will provide the Examining Authority with an update We trust that these comments are useful. Yours faithfully MRS BARBARA MOSS-TAYLOR Sustainable Places - Planning Specialist Direct dial 020847 48010 Direct e-mail [email protected] "
Members of the Public/Businesses
North Walsham Town Council
"The cable for the proposed Vattenfall Wind Farm passes through the northern and western edges of the Parish of North Walsham. The Town Council has an interest in the route for the cable, how it is to be developed and access to storage sites for the laying of the cable. The Town Council would, therefore, like to comment on these matters."
Members of the Public/Businesses
Adriana Marks
"If the construction site must be in Necton, every effort should be made to make the building as far away and as least visible as possible from the houses in the village. Whilst I fully support renewable energy, I do not want this to negatively impact on the village that we specifically chose to live in. "
Members of the Public/Businesses
Margaret King
"I would appreciate it if Vattenfall found an alternative site for their substation, as it seems to me to be a monstrous development to be constructed in between a cluster of Norfolk villages and 3 market towns, also the proximity to our homes is of great concern. When such a great receiver and distributor of electric current from our coast, has to be built within the area of less than a mile from the places we dwell, it doesn't seem at all the right thing to be doing. We are a small island, but I'm sure not so small that we have to have a substation built so close to our everyday living. This inspectorate should take it very seriously, with great steps taken to ensure that the area can cope with what Vattenfall and National Grid are expecting, and everything else that they will want to do in the years to come, beacause I just can't bear the thoughts of this area of our lovely Norfolk taken into industrial development to the point wher it can never be returned to the good productive land it is today. If it's a toss up between food or electricty, food is the winner, we cannot live without food. Having been in farming I've seen shortages and gluts and realise more than most how fragile our food production is, with an unpredictable climate, and with the prospect of more difficult overseas trade, this becomes an even more important consideration."
Members of the Public/Businesses
Richard William Woods
"That no consideration has been made regarding wildlife including bat habit. That no consideration has been made to a source of the River Wissey."
Members of the Public/Businesses
Colin King
" The proposed Vanguard substation site at Necton poses some problems in my opinion. Vattenfall and Orsted are developing offshore wind farms of similar scale, at the similar time, and in the same region. The cable corridors could be shorter if they exchanged their substation locations. The Necton site in 1996 was subjected to a F16. plane crash, with all the associated contamination problems. It was decontaminated at the time with the understanding the soil would not be disturbed below 1m. Vattenfall were unaware of this, until just before submitting their application. Vattenfall disregarded 3 holiday let businesses, and 2 caravan sites in Necton, also walkers and dog walkers, rating them as of negligible value. The Necton site is on high ground, regarded as a lightening strike area. The soil is deep clay, in arable production, only because of it's extensive land drain network. The drainage water all passes through Ivy Todd, sometimes flooding the road and houses. All Dudgeon's substation runoff is handled by this small stream. Vattenfall intends to add theirs to the same stream. We, I assume have riparian rights to the stream, as it's on our boundary. We at Ivy Todd Farm, had a visit by 2 Vattenfall representatives. They suggested tiered tree planting between the substation, and our land. No planting appears on any diagrams or maps in the application. We would value an agreement regarding noise restriction over our land, which we told the representatives, is intended for a future, recreational diversification project. No alternative sites have been described, as less suitable than the Necton connection point. Two alternative areas, (Fransham and Scarning) directly back along the cable corridor, were described to Vattenfall, one with a technical report. the Scarning land was for sale, and the Fransham land owner was willing to sell. With no alternatives, the Necton site must work, no matter how many problems are discovered. Background noise levels appear to have only been monitored for 24 hours. The size and effect of the Borias project is being omitted from the application, although the cable corridor is being constructed to cater for both developments, to make both schemes commercially viable. At the consultation drop-ins, alternative connection points, other than Necton, were not for discussion. Any detail regarding sound suppression, or water runoff control etc. were not available, because design detail is not initiated, until a DCO. granted. A few moments, with a poor image, on a TV monitor is the only representation you get, of what you are going to live with. No hard copies to take away, no models, no large scale pictures, or pictures of existing examples. The site has substantial archaeology to be avoided, and an ancient wood with associated rare bats etc. Vattenfall states an output of 1.8 gigawatts, without qualifying, weather this is a theoretical maximum, or the actual usable output after a sensible load factor of 38% has been applied. Vattenfall uses a 1.8 gigawatts output many times to justify shortfalls in the project. "
Local Authorities
Norfolk County Council
"Norfolk County Council Comments on the Norfolk Vanguard offshore Wind Farm and Onshore Supporting Infrastructure 7 September 2018 Norfolk County Council: (a) Supports the principle of this offshore renewable energy proposal, which is consistent with national renewable energy targets and objectives, subject to: 1. The holding highway objection set out in the report being satisfactorily resolved; 2. The implementation of appropriate highway; historic environment; and surface water conditions / requirements being resolved through the DCO; and 3. The detailed comments set out in this report and in the Appendix (below) being addressed through the DCO process. (b) Supports the use of HVDC technology which removes the need for an additional HVAC Booster / Cable Relay Station near Happisburgh. 1. Substantive Comments Overview Comments 1.1. 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 Issues 1.2. Comment - the County Council welcomes the decision by Vattenfall to pursue a HVDC solution which removes the need for additional onshore infrastructure (cable relay station) in North Norfolk and reduces the potential environmental impact associated with the cable route by narrowing the cable corridor from 100m to 45 m. Electricity Supply Issues Comments 1.3. 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. In addition the County Council will continue to work with the Local Enterprise Partnership (LEP) through the TRI - Local Energy Strategy (endorsed by this Committee in July 2018), in order to lobby central government to make legislative changes to overcome the obstacles to secondary inter-connection raised above. Socio-Economic Issues Comments 1.4. 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 windfarm 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 Comment 1.5. 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. 1.6. 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 Comment 1.7. 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 Highway - key Issues Comment 1.8. It is felt that the applicant needs to find a different site for their main compound. However, if they wish to pursue their chosen site then they will need to: (i) provide a scheme of permanent off-site highway improvement works comprising carriageway widening along the entire route from the compound to the main road; and (ii) demonstrate that such a scheme is capable of overcoming the issues previously identified by PINS. In the meantime it is felt that a holding objection on highway safety grounds should be raised to the inclusion of this site. 1.9. At the time of writing this report the County Council’s highway officers are still carefully assessing the supporting documentation in respect of the above matters and will make appropriate comments under delegated officer powers and feed these back to the Planning Inspectorate within the prescribed consultation period. This may include, where appropriate: (a) Raising any necessary holding highway objection in the event that highway safety is deemed to be compromised; and/or (b) Seeking Planning Conditions (Requirements) to be attached to the DCO in order to overcome any highway issue. Wider Strategic Highway Issues Comments 1.10. (a) Vattenfall need to satisfy Highways England with regard to the safety of their proposed access at Necton onto the A47(T). Impact upon driver delay along the trunk road network will also be assessed by Highways England. (b) Vattenfall should work closely with Highways England and Norfolk County Council (Highway Authority) to ensure the proposed cable route does not fetter any future plans for the dualling of the A47(T); (c) Vattenfall are asked to ensure that their underground Cable Route does not fetter any future highway improvement schemes in Norfolk and that where any reinforcement or diversion is needed to the cable route as a result of such highway works, that Vattenfall will be responsible for any upgrades or diversion of the cables and will fully meet the costs of these works. Minerals and Waste Comment 1.11. Norfolk County Council in its capacity as the Minerals and Waste Planning Authority does not object to the Proposed Vanguard Wind Power Project provided that the applicant continues to work with Norfolk County Council regarding the mitigation of impacts on the Mineral Safeguarding Areas. Flood and Drainage Issues and Comments Comment 1.12. The LLFA welcomes that sustainable drainage systems (SuDS) have been proposed for the project where permanent above ground infrastructure is proposed to mitigate against additional impermeable surfaces creating an additional risk of flooding. The LLFA have considered the submitted documents and are pleased to see that strategies have been supplied for the sub-station and the National Grid sub-station extension study areas. The cable corridor has not been considered in the post construction drainage strategy due to the fact that the cable would be below ground and reinstatement to pre development state would mitigate the potential for increased runoff. 1.13. It is noted that Greenfield run-off rates and volumes have as yet to be agreed with the LLFA. This will need to be considered during detailed design stage. 1.14. It should be noted that where ordinary watercourses are to be crossed by open cut, or any other temporary works are proposed as part of this project are likely to affect flows in an ordinary watercourse, then the applicant would need the approval of Norfolk County Council. The County Council would appreciate early consultation on the number of such crossings of Ordinary Watercourses and the required timeframes for approval. This will enable the team to have adequate staffing resources in place to ensure approvals are not unduly delayed and for and issues to be identified. It should also be noted that other ordinary watercourse crossings would need consent approval from the relevant Internal Drainage Board (IDB). In line with good practice, Norfolk County Council seeks to avoid culverting, and its consent for such works will not normally be granted except as a means of access. Such approvals are separate from planning and temporary mitigation methods may be required while cable laying is undertaken. 1.15. Norfolk County Council appreciates that these are initial drainage proposals, however, ideally these matters above (covering infiltration testing and drainage design) should be clarified prior to determination, to ensure that the site has a deliverable surface water drainage strategy. In particular there is no maintenance or management strategy supplied with the application and the LLFA have had to assume that the applicant will take responsibility for maintaining the drainage for the lifetime of development. The LLFA recognise this is a strategic application and is being determined by the Secretary of State as the Planning Authority and to ensure the best possible drainage strategy is developed Norfolk County Council would ask that the attached condition / requirement (see Appendix 1) is integrated into any final DCO consent. Additional technical LLFA will be sent under delegated officer powers to the Planning Inspectorate along with the above comments. Landscape Comments 1.16. It should be noted that landscape issues are ultimately a matter for Breckland District Council to comment on as the Local Planning Authority with their own adopted Local Plan policies covering landscape and other environmental matters. 1.17. While it is accepted that the onshore elements of Norfolk Vanguard have the potential to impact the landscape and visual amenity, measures have been “designed-in” to minimise these impacts. It is also noted that the location chosen has been selected to minimise visual impact, particularly in relation to the Substation and the National Grid Substation Extension, where existing vegetation and landform have been used to intercept views. 1.18. The decision by Vattenfall to pursue a HVDC option in terms of its cable route has, as indicated above, taken away the need for a cable relay station / booster station close to the Norfolk Coast (near Happisburgh). This option is welcomed in terms of minimising the impacts of this development on the landscape in North Norfolk. Public Health Comments 1.19. The County Council would expect detailed matters relating to, for example construction noise; local environmental health; and any other potential contamination issue, to be addressed by the relevant District Councils and/or other statutory body such the Environment Agency. 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. Appendix Response to Norfolk Vanguard DCO Application - Detailed Comments Public Rights of Way 1.20. It is noted that the onshore cable route intersects with Public Rights of Way (PRoW), including National and County Trails, at 45 locations. Mitigation for impacts on users of the PRoW network is in the form of embedded (‘designed-in’) mitigation and method statements. Comment 1.21. Norfolk County Council welcomes the use of HDD underneath some of the particularly heavily-used recreational routes (long-distance trails), particularly at landfall where the cables will intersect with the England Coast Path. HDD is also proposed for cable-laying across two further Trails managed by Norfolk Trails, namely Marriott’s Way (twice) and Paston Way (both these sites are also designated County Wildlife Sites at the crossing points). This approach should result in negligible disruption to users of these Trails. It is noted that HDD is not proposed at the crossings of two further Norfolk Trails, the Wensum Way and Weaver’s Way, nor the majority of the crossing points of the general PRoW network. 1.22. Mitigation for impacts on the majority of the PRoW and Trails network will be addressed by two documents: A Public Right of Way Strategy, and a Code of Construction Practice (CoCP), draft versions of which have been submitted with the DCO application. The Council believes these documents should result in appropriate measures to manage impacts in relation to cable-laying. In relation to the discharge of the DCO requirement for the CoCP, the documents refer to liaison with the “relevant local planning authority” (e.g. CoCP, section 4; paragraph 71; p 16). However, when it comes to matters relating to PRoW and Trails, it is felt that the County Council as the Highways Authority should be the relevant local authority to agree the management of PRoW. 1.23. The County Council welcomes the intention of the applicant to liaise with the PRoW Officers and Trail Officers over short-term temporary diversions of PRoW or other potential impacts. This will be important in reducing the burden on NCC in managing matters relating to the PRoW network with regards to the cable-laying works. The County Council also welcomes the approach for providing advanced warning of works that would affect PRoW. Where Norfolk Trails would be affected, it would additionally be helpful if information could be provided for inclusion on the Norfolk Trails website. Ecology 1.24. The involvement of the County Council with regards to ecology has been with onshore works only. Representatives from the Natural Environment Team have been involved in the onshore Ecology Expert Topic Group (ETG). 1.25. The Ecology Chapter of the ES (Chapter 22) and the onshore Ornithology Chapter (Chapter 23) describe the ecological baseline and assess the impacts resulting from the onshore infrastructure requirements. The design of the scheme contains “embedded mitigation” for ecology. Where “additional mitigation” is required, potential impacts on terrestrial ecology will be delivered as described in the Outline Code of Construction Practice (OCoCP) and the Outline Landscape Ecological Management Strategy (OLEMS). The final detail of the mitigation and enhancement measures will be provided through one or more Ecological Management Plans (EMP) which will act as a single document for all ecological mitigation considerations on site. Comments 1.26. The County Council welcome the above approach and agree the content of the outline CoCP and the OLEMS. In the second document, it is stated that “Norfolk Vanguard Limited will work with the relevant local authorities to ensure appropriate resourcing is in place to monitor compliance with the provisions of the OLEMS, and the plans and schemes of which it forms the basis”. The Natural Environment Team of the County Council would wish to be involved in this process. 1.27. The County Council welcomes the use of HDD where cable routes intersect with County Wildlife Sites. It is noted that a running track will still be necessary at the Wendling Carr CWS, but the need for this was discussed at the ETG meeting and is further described in the ES. The County accept that this approach is needed and believe the proposed mitigation is appropriate. 1.28. The County Council has previously raised concerns about the following matters, which have now been addressed: • The constraints on access for ecological surveys: The OLEMS states that due to access constraints only 50% of the onshore project area was subject to ecological field surveys, and only 40% of the ponds. It is noted that the use of the Norfolk Living Map to ‘fill-in’ data gaps at this stage, but recognise field surveys of the currently un-surveyed locations will be necessary post-consent, and these surveys may lead to further mitigation at specific locations. • Insufficient survey effort of CWS: At an early stage of the scoping process, the County Council advised that surveying of CWS close to the cable corridor was necessary (ETG meeting Jan 2107). This was accepted by Vattenfall and the surveys were completed. The results of those surveys are included in the ES. • The suitability of the bat surveys to enable delivery of appropriate assessments of impacts and therefore appropriate mitigation (ETG Meeting July 2017): Vanguard came back to the County Council on this matter with revised reports, and the County Council is now satisfied that the assessments are broadly valid and the proposed mitigation for is appropriate. It is noted that some surveys will still need to be made post-consent at locations where access constraints resulted in no or incomplete surveys (OLEMS, paragraph 68). It is also noted that during the design process, landfall has moved away from the key area of concerns for barbastelle bats at the Paston Great Barn SAC colony. Historic Environment Onshore Comments 1.29. Subject to the submission and approval of a revised version of Document 8.5 Outline Written Scheme of Investigation: Archaeology and Cultural Heritage (Onshore) to state that work will be carried out in accordance with the Norfolk County Council Standards for Development-led Archaeological Projects in Norfolk (2018), the County Council is happy to recommend that the following requirements are placed on the consent if granted; 1.30. A) No development shall take place other than in accordance with the submitted and approved Outline Written Scheme of Investigation: Archaeology and Cultural Heritage (Onshore). And, separately, B) The development shall not be operated until the site investigation and post investigation assessment has been completed in accordance with the programme set out in the archaeological written scheme of investigation approved under (A) and the provision to be made for analysis, publication and dissemination of results and archive deposition has been secured. Offshore Comments 1.31. The Offshore Historic Environment implications of the proposed development are considered in Chapter 17 of the ES (Offshore Archaeology and Cultural Heritage). The offshore historic environment below the low-water mark is not specifically within the remit of the County Council. 1.32. A decision has been made by Vattenfall to use a long HDD technique at the landfall of the cable route. As a result of this there will be no construction work, or resulting historic environment impact, within the inter-tidal zone on Happisburgh beach (where internationally significant archaeological remains of Palaeolithic date are known to exist). As such the County Council does not have any specific comments or recommendations to make on the offshore archaeology and cultural heritage of the proposed development. However, Vattenfall and their heritage consultants should continue to liaise with Historic England and other key stakeholders (e.g. Ancient Human Occupation of Britain) regarding any post-consent works. Lead Local Flood Authority (LLFA) Comments 1.33. The ES states that the crossing of ordinary watercourses would be by Horizontal Directional Drilling (trenchless) or open cut. Referring to Appendix 20.4 Detailed Watercourse Crossing Schedule Table 20.1 it is noted that it appears that the majority all Norfolk County Council ordinary watercourses are proposed to be crossed by open cut rather than Horizontal Directional Drilling for permanent works. If this is the case, or any other temporary works proposed as part of this project are likely to affect flows in an ordinary watercourse, then the applicant would need the approval of Norfolk County Council. The County Council would appreciate early consultation on the number of such crossings of Ordinary Watercourses and the required timeframes for approval. This will enable the team to have adequate staffing resources in place to ensure approvals are not unduly delayed and for and issues to be identified. It is also noted that other ordinary watercourse crossings would need consent approval from the relevant Internal Drainage Board (IDB). In line with good practice, Norfolk County Council seeks to avoid culverting, and its consent for such works will not normally be granted except as a means of access. It should be noted that this approval is separate from planning and temporary mitigation methods may be required while cable laying is undertaken. Proposed Condition/Requirement - 1.34. Prior to commencement of development, in accordance with the submitted Environmental Statement for Application for Development Consent - The proposed Norfolk Vanguard Offshore Wind Farm, detailed designs of a surface water drainage scheme incorporating the following measures shall be submitted to and agreed with the Secretary of State or his delegated approving body. The approved scheme will be implemented prior to the first use of the development. The scheme shall address the following matters: I. Detailed infiltration testing to be undertaken in accordance with BRE Digest 365 within the study areas for the sub-station and the National Grid sub-station extension for the design of SuDs features. II. If infiltration is not possible surface water runoff rates will be attenuated to the pre development 1 in 1 year rate (or 2 l/s/ha). Where applicable confirmation should be sought from the Internal Drainage Board that the proposed rates and volumes of surface water runoff from the development are acceptable. III. Provision of surface water infiltration / attenuation storage should be sized and designed to accommodate the volume of water generated in all rainfall events up to and including the critical storm duration for the 1 in 100 year return period, including allowances for climate change, flood event. IV. Detailed designs, modelling calculations and plans of the of the drainage conveyance network in the: • 1 in 30 year critical rainfall event to show no above ground flooding on any part of the site. • 1 in 100 year critical rainfall plus 40% climate change event to show, if any, the depth, volume and storage location of any above ground flooding from the drainage network ensuring that flooding does not occur in any part of a building or any utility plant susceptible to water (e.g. electricity equipment required at the converter / booster station and substation) within the development. V. The design of any drainage structures will include appropriate freeboard allowances. Plans to be submitted showing the routes for the management of exceedance surface water flow routes that minimise the risk to people and property during rainfall events in excess of 1 in 100 year return period VI. Details of how temporary works or temporary storage areas that will generate surface water runoff will be controlled to prevent a temporary increased risk of flooding. These details will also include what strategy/ plans will be provided to reinstate land to the pre-development state. VII. Finished ground floor levels of the converter / booster station and substation should have a freeboard such that all infrastructure is above expected flood levels from all sources of flooding, including fluvial flooding associated with the ordinary watercourse, tidal flooding and any above ground storage or flooding from the proposed drainage scheme. VIII. Details of how all surface water management features are to be designed in accordance with The SuDS Manual (CIRIA C697, 2007), or the updated The SuDS Manual (CIRIA C753, 2015), including appropriate treatment stages for water quality prior to discharge. IX. A maintenance and management plan detailing the activities required and details of who will adopt and maintain the all the surface water drainage features for the lifetime of the development. This will also include the ordinary watercourse and any structures such as culverts within the development boundary. Reason: To prevent flooding in accordance with National Planning Policy Framework paragraph 103 and 109 by ensuring the satisfactory management of local sources of flooding surface water flow paths, storage and disposal of surface water from the site in a range of rainfall events and ensuring the surface water drainage system operates as designed for the lifetime of the development. 1.35. NB Further detailed technical comments will be sent to both the applicant and the Planning Inspectorate. Additional LLFA Comments Summary of Local Flood risks in the vicinity of the site • The project has been split into study areas, Landfall – Onshore cable route including access routes and mobilisation areas, Onshore project substation and National Grid substation extension and overhead line. • There are areas at risk of surface water flooding within the study area boundary 1 in 1000 (0.1% annual probability) flood event as shown in the Environment Agency’s Risk of Flooding from Surface Water (RoFSW) maps. • The onshore project landfall, substation and National Grid substation extension are located in Flood Zone 1 of the Environmental Agency Flood Zone Risk Maps, which is classified as land with a low risk of flooding (less than 0.1% chance of flooding in any year). The majority of the onshore cable route is located within Flood Zone 1, however there are a number of locations at which the onshore cable route intersects areas of Flood Zone 2 and 3. • The British Geological Survey (BGS) maps identify the bedrock underlying the onshore project area as Chalk to the west and Neogene and Quaternary Rocks to the east, overlain by superficial deposits of till (Diamicton), glacial sand and gravel, clay, silt and sand alluvium, and Crag Group (sand and gravel). • A number of Source Protection Zones (SPZs) are identified within the onshore project area, with both inner and outer zones of the SPZ areas extending across the eastern section of the onshore cable route. • No infiltration testing has been carried out at this stage. Geotechnical investigation should be undertaken to determine whether material on this site has infiltration potential in line with the SuDS hierarchy. This information should be representative of on-site conditions. If material is found to have infiltration potential, detailed infiltration testing should be undertaken in line with BRE 365 : • The flood risk study areas include a number of catchments associated with EA designated main rivers and IDB/local authority ordinary watercourses including the River Bure catchment, the River Wensum catchment, and the River Wissey catchment. Mitigation measures have been identified including a commitment to trenchless crossing techniques for a number of sensitive watercourses, sediment management, construction drainage, and implementation of best practice measures. • The flood risk study area crosses a number of existing field drains, ditches and irrigation channels which may require consents for works to ensure that any flood risk is not adversely affected. • The site passes through the several IDB areas for the regulation of ordinary watercourses where consents may be required. • There are no LLFA records of incidents of internal or external flooding on or adjacent to the study areas. However it should be noted that our records only cover the period of 2011 to the present day. Summary of assessment of Flood Risk and submitted drainage proposals The Flood Risk Assessment / Drainage submitted with the Environmental Statement, has been assessed against the National Planning Policy Framework (NPPF), Planning Practice Guidance, the SuDS Non-Statutory Technical Standards (NSTS) (March, 2015) and the policies of the adopted Norfolk Local Flood Risk Management Strategy as follows: • The Environmental Statement has made an assessment of local flood risk issues and identifies all sources of risk for the main catchment areas and study areas, both during construction and the operation/maintenance of the scheme. It has also considered the cumulative effect of other proposed schemes. • The Environmental Statement drainage strategy states that the SuDS discharge location hierarchy will be followed (soakaway testing will be carried out to determine the feasibility of infiltration or evidence for not discharging via infiltration).(Volume 2 Appendix 20.01 20.10.1 (194)). This should be demonstrated at detailed design. • Greenfield run-off rates have as yet not been agreed with the LLFA. This will be required at detailed design. • Post construction the controlled runoff rate will be equivalent to the greenfield runoff rate. The resultant storage / attenuation volume provided will be sufficient to ensure that during the 1 in 100 year event plus an allowance for climate change there will be no increase in runoff from the site. • Description of SuDS component elements: It is stated that a pre-construction Surface Water and Drainage Plan will be developed, agreed with regulators and implemented to minimise water within the working areas, to ensure ongoing drainage of surrounding land and that there is no increase in surface water flood risk. This will assess the current and proposed runoff rates, volume of storage required and the proposed approach for discharge of water from the site. However no detail is currently provided in the ES. During construction, the cable route will be bounded by drainage channels (one on each side) to intercept drainage from within the working corridor. Additional drainage channels will be installed to intercept water from the cable trench. Where water enters the trenches during installation, this would be pumped via settling tanks or ponds to remove sediment, before being discharged at a controlled rate into local ditches or drains via temporary interceptor drains. Depending upon the precise location, water from the channels will be infiltrated or discharged into the drainage network. Some form on contingency plan will be required to be considered for any significant rainfall event. Post construction the surface water drainage requirements for the National Grid substation extension and onshore project substation will be dictated by the final Surface Water Drainage Strategy. Changes in surface water runoff as a result of the increase in impermeable area from the onshore project substation and National Grid substation extension will be attenuated and discharged at a controlled rate equivalent to the greenfield runoff rate. The resultant storage / attenuation volume provided will be sufficient to ensure that during the 1 in 100 year event plus an allowance for climate change there will be no increase in runoff from the site. An attenuation pond with a volume of 4,050m3 (approximate dimensions of 58m x 58m x 1.2m) has been allowed for at the onshore project substation to provide sufficient attenuation to greenfield runoff rates into the closest watercourse or sewer connection. The full specification for the attenuation pond should be addressed as part of the detailed design. • Trenchless crossings are to be used at key watercourse crossing locations. At other crossing locations it is proposed that open cut techniques are utilised to cross the watercourse. • The applicant has not identified exceedance routes for flows in excess of a 1 in 100 year rainfall event. This will be expected at detailed design stage. Consideration should be given to the expected depth/velocity of flood water to quantify any potential risks to people and property in the event of exceedance of the drainage inlets. This should be provided at detailed design. • A maintenance plan has not been submitted as part of the DCO at this stage. Consideration needs to be given to the ongoing management and maintenance of all drainage features over the lifetime of the development. A maintenance plan identifying the required actions and responsible owners should be submitted to ensure that all parties understand their responsibilities. This includes all drainage infrastructure, such as pipes and tanks, permeable paving within the curtilage of the station sites, as well as the ordinary watercourse and any structures such as culverts within the development boundary. We recommend that further information is requested. Summary of alignment to relevant Non-statutory technical standards for sustainable drainage systems S2 . The FRA states that the post development 1:1 year run off rates will be equal to the calculated greenfield rates for the sub-station sites. This should be determined during detailed design. S4/S6 – The information provided indicates that runoff volumes will not increase post-development by limiting to 2l/s/ha or QBAR whichever is the greatest. This should be maintained during detailed design. S7 – The FRA does not include calculations to show that there will be no flooding on site from the proposed drainage scheme for the 1:30 plus climate change rainfall event. S8 – At this stage the FRA does not state what protection will be provided to prevent flooding of any utility plant (e.g. sub station electrical infrastructure) during the 1 in 100 year rainfall event. Essential equipment throughout the sites is recommended to be set above the anticipated flood levels to ensure that the substation operates during a significant rainfall event. S9 – At this stage the FRAs have not identified exceedance routes for flows in excess of a 1 in 100 year rainfall event. Consideration should be given to the expected depth/velocity of flood water to quantify any potential risks to people and property in the event of exceedance of the drainage inlets. This will be expected at detailed design stage. Additional Comments agreed at Norfolk County Council’s Environment, Development and Transport Committee on 7/9/18: (a) Hedgerow Comment - The County Council would ask that maximum possible replanting / mitigation of hedgerows is undertaken after works are carried out in respect of the cable route and any other onshore development resulting in the potential removal of hedgerow. (b) Coastal Erosion Comment – The County Council would ask that sufficient safeguards and mitigation measures are put in place where the offshore cable route makes landfall to the south of Happisburgh (as a planning requirement), in order to ensure the onshore infrastructure does not exacerbate existing coastal erosion in the area. (c) Highway Access The County Council will address all local highway issues arising from construction by seeking suitable planning requirements (conditions), in particular with regard to updating the outline Construction Traffic Management Plans. In addition the County Council will expect the developer to: (A) enter into a legal agreement with the Highway Authority to ensure any damage is rectified; (B) set up local stakeholder involvement group/s to enable any traffic issues arising during the construction phase to be discussed and resolved. "
Members of the Public/Businesses
Penelope Malby
"I believe that Happisburgh will be affected long term by the Vanguard & Boreas projects, and that the damage done to the village will never recover. The erosion of our cliffs has been enormous over the last 50 years and is not slowing down. Drilling underneath these cliffs is not going to be wise, there have been several cliff falls in the last year and regularly metres of cliff are disappearing. Other issues include noise, potential flooding, archaeology, wildlife on and offshore, pollution for residents, loss of income. Air quality in North Norfolk is generally good, but if this project is passed this will no longer be the case with the amount of HGV and traffic passing through all of our narrow lanes. So many of our cottages and houses are built right on the roadside, we just cannot cope with this level of traffic. Happisburgh has been chosen as landfall because we have no protection on this tiny part of coastline, we are a small vulnerable Norfolk village versus a Swedish Govt company. Traffic in the area will be unbearable, including HGV vehicles 24 / 7. Residents of the village will not be able to get from one end to the other, and all footpaths will be closed. Tourists will stop coming, because our tranquil peaceful village will no longer be the attraction it is now. Happisburgh Lighthouse is the only privately owned working lighthouse in the UK and brings many tourists to the village. It is open to the public and monies raised goes to the upkeep of the lighthouse. Archaeological finds, including 'The Happisburgh Handaxe' and the Happisburgh footprints, both evidence of early Paleolithic activity here. A Parish owned car-park which is self funding and raises money for the village, RNLI lifeboat station and souvenir shop, historic pub with separate coffee House and carvery, village shop, fish shop and cafe are all part of a thriving community who welcome tourists, year round, whilst staying a quiet, beautiful place for its residents to live. If Vattenfall are allowed to go ahead with this project, it will be the end of village life for Happisburgh. "
Members of the Public/Businesses
Stephen King
"I am writing about my concerns regarding the Vanguard/Boreas substations. I am often in Necton visiting family and am concerned at the prospect of a 100 acre site so close to houses in the village; there are approximately 2000 residents in Necton, this is not a suitable site for such a large development. There is not sufficient evidence that Vattenfall have put adequate effort into finding alternatives which would not impact the local population – particularly as there is a site near Scarning and Wendling which is not close to residents, would use the same pylons, require a shorter cable distance and is also supported as an alternative site by National Grid. Vattenfall's choice of grid connection point has not taken account of the local situation and environment. The secretary of state should not agree to this project going ahead in this location without adequate investigation into acceptable alternatives and sufficient justification for the site chosen, neither of which is currently the case. "
Members of the Public/Businesses
Victoria Spain
"As a frequent visitor to my parents’ house in Necton, I would like to register a strong objection to the negative aspects of the planned Vanguard and closely following Boreas substations. These are huge at 100 acres, compared to the size of the village which has 2,000 inhabitants and could not be considered small. The site selected for these substations is very close to the houses in Necton and Ivy Todd. There is an alternative site in the Scarning / Wendling area which would have less effect on Norfolk residents as there is no village nearby. The cable run would be shorter so there would be less effect on the environment. It is along the same pylon run so there should be a very good reason why it has not been used instead of Necton. Vattenfall have provided no reason why this site has not been investigated at all as an alternative. National Grid have a process for selecting connection points to the grid which they followed. However, in this instance, their procedure was inflexible and took no account of either the local environment or local residents. For a project of this physical size, National Grid and Vattenfall should look at their siting holistically, rather than following set procedures that may not be in the best interests of the wider community and environment. The planned Vanguard and closely following Boreas substations will be huge and out of proportion for a site so close to Necton and Ivy Todd houses. National Grid have confirmed that there is a suitable alternative site and this should have been investigated by Vattenfall with reasons for not using it given in the DCO. This has not been done and should be done before the DCO is accepted as complete. Many thanks, Victoria"
Members of the Public/Businesses
Derek Pinner
"Although green energy is the way forward,sitting of the relevant structure is important to the environment. As such the Nection receiver station is inappropriate on the grounds of size and location. It will destroy the landscape because of the size. Air pollution will be increased as a result of construction traffic and the effect it will have on the local community. Also there must be concerns regarding health and safety, with the noise and light pollution the site will generate, especially any fussing noise the site will generate. In addition what effect will this have on other services, such as services to domestic dwellings."
Members of the Public/Businesses
Diana Lockwood
"This will be the largest development of it’s kind in the World. The chosen location feels so ill considered. Why is this being placed so close to homes, especially at Ivy Todd. My own family living at Ivy Todd Farm will be severely, negatively affected, with the proposed 70 acres being 500m from the house. Our MP George Freeman has visited our farm and has shown concern at the proposed location. PEIR document says the scale does not fit in with rural location. Other locations with less impact on individual’s lives (identified & submitted) do not appear to have been fully explored. HVDC option means a bigger, noisier project. No regard has been given to the possible negative physical, psychological health implications of living with 10 years of construction work in close proximity, then with the permanent massive structure looming over residents, who have lived with unspoiled (apart from Dudgeon construction) views, beauty and appreciation of the area. Also possible health threats from EMF. Ivy Todd is already a high volume Cancer cluster. Noise monitoring only appears to have been carried out for 24hrs. In 1996 a Danish F16 crashed at Ivy Todd. VF was not aware of this until NCC advised them on 6th June, and of possible radioactive substances. If VF’s corridor cable trench is run through this crash site, what possible hazardous contamination may be disturbed. VF advise that there is no health risk and in the event that there was, they would deal with it. Unacceptable. It has been incredibly difficult to obtain information first hand which is Necton/Ivy Todd relevant re our fears, questions. We are referred to VF website for answers. There is no specific section for Necton. Website is generic/not transparent. We feel misled and intentionally under-informed. Meetings/drop ins have been shambolic. ‘Mitigation’ is a word levied by VF. NO amount of mitigation will disguise this monstrous animal from view from my family farm. It will be devastating. No adequate visual projections have been provided by VF. PEIR says massive efforts won’t be enough to screen the project within the life of the project. The stream in Ivy Todd is the only tributary to take away rain water. With huge concreted areas being proposed, the stream which already floods will not cope. Riparian Rights? In all of their consultations & info, VF never mentions  inefficiencies and what happens on still days/weeks when there is little wind. A spokesperson from VF has already agreed that technology will have moved on/improved during the 10yr build, and the plant will become redundant. We, however have to live with this permanent scar. Is it even sustainable? If this goes ahead, we hope there will be due consideration to residents massively affected by blight, inconvenience, distress, devaluation, in our case lost opportunity for the farm’s intention to diversify into holiday lets. The current beautiful views will be obliterated. Other leisure businesses in the villages have been disregarded as of’ negligible value’. Threat from terrorism is a real concern. "
Parish Councils
Happisburgh Parish Council on behalf of Happisburgh Parish Council
"HAPPISBURGH PARISH COUNCIL Parish Clerk: Jo Beardshaw. Myrtle Cottage, Church Road, Potter Heigham, NR29 5LL Telephone: 01692 670787 email: [email protected] Vattenfall Declaration of Interest Address to be confirmed 11th September 2018 Dear Sir / Madam I would like to register an interest on behalf of Happisburgh Parish Council to be involved in the Norfolk Vanguard / Vattenfall consultation. There are two overriding reasons for Happisburgh Parish Council’s wish to register an interest: - The proposed landfall site is within Happisburgh - The proposed cable route runs through the village As a result of these facts, Happisburgh Parish Council is concerned about the following: - The impact of the work on beach and cliffs. - The timing of the work in the village, mainly its disruption to tourism within the village - Road closures and temporary traffic lights. - Work going on at night - The onward cable channels towards Necton - The possible impact on houses close to the cables (loss of value etc) - Road disruption including heavy works traffic (which should not be allowed through the village) - Excessive lighting (which should not be permitted) - Ensuring that the village receives some form of compensation Yours sincerely Jo Beardshaw Happisburgh Parish Clerk and Responsible Finance Officer "
Members of the Public/Businesses
Mr Paul King
"My reasons for objecting to the construction of the Vattenfall substation at Necton are listed below: 1. My father tile drained this land where the proposed substation is to be built. I have personally worked this land and know it will not hold water having been tile drained every 22 yards. Therefore the water will run down and flood Ivy Todd which I have seen happen many times over the years causing risk to people and wildlife. 2. I have lived down [redacted] since 1950. It is very peaceful with wonderful open skies. It will be devastating to look out from our back garden to see an 70 foot construction looking down on me with maybe a second substation to come. 3. On December 11th 1996 a Danish F16 fighter jet crashed on the land which is due to be dug up by Vattenfall to build the substation. It has now come to light there could be a radioactive substance risk at the crash site if the land is disturbed. From a health point of view this is very worrying. 4. I am concerned about noise coming from the construction of the site and also the noise generated from it on completion. 5. The health risk associated with a magnetic field emitted from such a large substation. 6. On my land I run a 5 van caravan and motorhome club site. I am concerned the substation will have a negative effect on business. People will prefer not to holiday near a substation but choose a site elsewhere. 7. Devaluation of my property."
Members of the Public/Businesses
Mrs Margaret Moore
"Disagree Rare bats have been found on the proposed site. The two species Barbastelle and Nathusius Pipistrelle bats categorised as rare by the BCT. A Danish Air Force Military jet crashed close to Necton in 1996 and there is a possible Radioactive substance risk on the site of the F16 plane crash. There are also dangerous contaminants which could get into the water source. There is also a possibility of a fire risk, the substations are surrounded by drying crops, should a fire start the residents of Necton would be at risk."
Members of the Public/Businesses
Tony Smedley
"PLANNING REGULATIONS: Vattenfall state in their PEIR that the proposed substation at Necton is out of character and too large for the location. They further state that no amount of visual mitigation will be sufficient within the life of the project and its operational phase. It will not fit within its rural surroundings. This goes against Breckland Council Planning Regulations. The substation is planned to be built on good, working agricultural land. It should be built on brown belt land such as a disused industrial area. The proposal does not comply with the National Policy Statement for Renewable Energy Infrastructure (EN-3). See Section 1.7.2 para 4 and additionally, section 2.4 ‘Criteria for Good Design’ para 2.4.2 which states that ‘…renewable energy infrastructure should demonstrate good design in respect of landscape and visual amenity’. Additionally, in EN-1 ‘NPS for Energy’ section 5.9, how will the requirements of para 5.9.8 be met? Has the impact noted in para 5.9.15 been considered? LAND CONTAMINATION: In December 1996 a Danish Air Force F16 jet crashed in Necton where Vattenfall’s Vanguard substation is planned, according to co-ordinates of the crash site provided by the RDAF. Documents recently revealed under The Freedom of Information Act state that the land was affected by a radioactive substance risk (fax IPC to MAFF). This risk may persist. There was also contamination with substances such as hydrazine and carbon fibre, which are both injurious to health. Debris was scattered over a wide area. Anecdotal evidence suggests there may be a local cancer cluster close to the crash site. Vattenfall’s Peir Chapter 19 ‘Ground Conditions and Contamination’ makes no mention of the plane crash or potential contamination. Vattenfall claimed ignorance of the crash. When they were told about it by residents they ignored them, not believing it. Even after being told about it by Norfolk County Council they did not include it in their submittal documents to PINS, despite having time to. Temporary farming restrictions were put in place because of the crash, and it is said that any large development planned for the site would require special permission (ad infinitum). This should be investigated by an independent body to avoid a conflict of interest. BUSINESSES: Vattenfall omitted mentioning holiday lets in the Necton, Ivy Todd and West End areas. In some cases these businesses will be destroyed, and this is not an accidental omission. Vattenfall admit they left them out deliberately as they are ‘insignificant’. This is abysmal to people who have spent years building a reputation-based business, only to be told by Vattenfall that they are insignificant. The area, designated as ‘dark rural landscape’ will be subject to noise, dust and light pollution, during the construction, and annual maintenance in the operational phase. FLOODING: The clay-topped fields of the substations’ sites are currently drained into one Wissey tributary by concrete ducts, which will be crushed during the build. Vattenfall have not provided a sufficiently detailed Flood Risk Assessment in accordance with EN-1 section 5.7, Flood Risk, para 5.7.4 "
Members of the Public/Businesses
Ann Seaman
"As a local home owner I am shocked at the sheer size of this project the impact on the local villages will be colossal. As I understand it Vanguard and National grid intend to use 92 acres of prime farm land, to build a further too power stations,mi also understand that 3 more suitable sites were offered, that would not effect local villages and not cause such upheaval to so many people. My second point is the land you intend to use was the crash site of a military jet, I find this very disrespectful as the farmer is not allowed to grow on the land because of the risk of nuclear pollution. It is also an unexplored site of arkilogical intrest. I am therefore lodging an objection to this development and would like more people friendly arrears explored I belive this is a more sensible and sensitive way to proceed Kind regards Ann Seaman "
Members of the Public/Businesses
response has attachments
Chris Alllhusen
"I am the last Landowner on the route to Necton, and the proposal includes taking some of our land for the sub-station. I would like to raise the following points – • This application is for Vanguard only, but must be seen as including Boreas, as the two will be sited next to each other. I believe, by splitting the application in this way, Vattenfall are cynically hoping to reduce people’s awareness of the scale of the project as a whole, as well as making permission for Boreas a formality. • I do not object to the project in principle, only to the siting of the Necton sub-station. The process of choosing which sites to put forward to the first round of public consultations in early 2017 was deeply flawed. By the time of our first meeting in November 2016, Vattenfall had already decided not to place the sub-station next to the existing one, an already low lying blighted site, but rather use one of their four chosen sites and move it even further onto higher ground. • Their preferred site for the sub-station, is now on one of the highest points of Norfolk, clearly visible for miles to the west, south & south east. There are far better sites that are lower and closer to the existing sub-station. Vattenfall’s decision not to investigate any of the sites adjacent to the existing sub-station has never been satisfactorily explained. • The proposed site is far too close to both a County Wildlife site and the listed building of Bradenham Hall. • The buildings will be some of the largest and highest in Eastern England, approx. 19 metres high, and no amount of landscaping with only shrubs and trees will ever hide them. On lower sites, the effect of the buildings could be mitigated by landscape and earth works. Vattenfall seem reluctant to include large scale earth works; they say owing to drainage issues, but presumably this is owing to cost. • I believe that noise and light pollution will be a huge problem in the high location. Tree screening will have little effect on such large buildings, as by the time the trees have any material impact, decades will have passed. Most of the alternative sites are far lower, by as much as 20 metres, and that, together with using the topography of the land and earth works, could make a huge difference to both visual and noise problems. • No surveys at all, for archaeology, wildlife or flora, have been done across our land for any purposes, other than one minor field. • In the last six months, Vattenfall have totally withdrawn from any local engagement, and have consistently refused to attend any of the local meetings held with George Freeman MP, local Parish Councillors and residents. Therefore, I can only assume that Vattenfall intend to rely heavily on gaining compulsory purchase powers, which should be used only as a last resort. I am sending four photographs by e-mail, reference Chris Allhusen, showing the proposed site and alternative sites. "
Members of the Public/Businesses
Donna Blackburn
"Against the new substations for Necton/ivy Todd "
Members of the Public/Businesses
Halena Higgs
"Their approach to the contaminated soil from the crashed Danish Jet in 1996, they just don't seem bothered about it. Also the actual size of the construction is huge and totally unsuitable for a village of our size. The fact that they are digging a trench from the Norfolk coast to the village beggers belief."
Members of the Public/Businesses
Karen Basten
"I have been a resident of Happisburgh for 25 years, and I have grave concerns regarding the Vattenfall Vanguard Project. I do not believe that there is robust evidence that the drilling and other ground works at landfall will not adversely impact the cliffs and coastline by Happisburgh, despite Vattenfall's assurances to the contrary. If defies logic that there will be no impact when there are cliff falls and erosion of the soft cliffs on a weekly basis. The long term impact on the local environment, all across the cable route, has been under played by Vattenfall. There is no regard for the destruction of wildlife habitats which will be devastated as trenches are dug for cable laying. Vattenfall' belief that such environments will recover quickly are flawed and unfounded. Some environments will be barren long after the project has finished. I believe that the impact on the residents of Happisburgh and the surrounding area has been poorly represented in the case put forward by Vattenfall. The proposed road closures are not clear and transparent. I am concerned about the closure of the coastal paths around the village which seem to be earmarked to be closed for a significant period of time during the project. This effectively cuts off a significant part of the village to those who live there for a prolonged period of time. I believe that the construction traffic will be unmanageable and create chaos and risk to those commuting to and from the village and surrounding areas. The roads in the vicinity of the landfall site and cabling route are not designed for heavy plant and articulated vehicles, and I have grave concerns about the safety of road users and pedestrians during this period, based on the outline plans from the project management. Additionally, I believe it very likely that vibrations from said heavy plant, on top of the actual drilling, will have a destructive effect on the aforementioned fragile cliffs. Finally, I have little confidence that the village of Happisburgh will not be left with a trail of devastation once Vattenfall have moved on, whether that be having sold the project on, or brought it to its conclusion years from now. Our beautiful British countryside will never be the same, and will be liable to further pillage under the guise of "maintenance", all for a project that has, in the greater scheme of thing, a very short life span. "
Members of the Public/Businesses
Leith Marar
"I and my wife own [redacted] Cottage on the southern outskirts of Happisburgh village. Landfall for the Vanguard and Boreas projects is going to be located in the narrow strip of land between ourselves and the coastal cliffs. Our property is let out to guests that come for the peace and tranquility of the location. Outlook from the rear of the property is farmers fields between us and the beach cliffs. We have been informed that a 10,000 square meter (100m X 100m) construction site will be located at the rear of our property possibly adjacent to it. Furthermore that the trench works will come to the surface with onward trenching in the fields at the southern boundary of our property. This will create a horrendous eyesore and with a noisy and light polluting installation that will profoundly change the nature of the home we have now owned for 4 years. Particularly disturbing is the length of time the installation will be periodically operational for, 3-4 years at currently estimates. At the end of the construction period estimated to be 2025 the site will be simply abandoned and simply permanently fenced to protect a very large hole in the ground never to be filled in. This will obviously make renting our home on the basis that we currently do untenable. Our property is also immediately adjacent to Whimpwell street being located at the roadside. Larger traffic vehicles passing now can cause vibrations in the property. Hence if earth moving trucks are to be passing the property on this very small road frequently we fear permanent damage to our house. These streets were simple not build to accommodate large and heavy loads. That is to say nothing of the implications for traffic that will not be able to pass trucks on these narrow carriageways. Finally it beggars belief that the best site deemed for landfall is an old quiet village with perhaps the most famously eroding coastline in the country. De-stabilising this at a time where recent landslips have left the village increasingly exposed seems obviously irresponsible. "
Members of the Public/Businesses
Brown & Co LLP. on behalf of Mr and Mrs G Kerry
"Mr and Mrs G Kerry own a smallholding predominantly comprising a large parcel of agricultural land extending to approximately 94 acres. This field has been identified as part of the Vattenfall cable route. This representation sets out Mr and Mrs G Kerry’s concerns for the project. The proposed cable route will have an effect on the holding and Mr and Mrs Kerry’s farming business certainly in the short term and potentially in the longer term if the concerns of the Kerrys are not dealt with appropriately. The current key concerns are as follows; • The proposed route intersects the principal field forming the smallholding and therefore the impact of severance to a high proportion of the farmland is significant; • The impact on the Kerry’s farming business and residential occupation of the farm during construction phase; • Crop loss and other associated losses including damage to underdrainage systems; • Concerns over soil stripping, storage and subsequent reinstatement particularly in light of previous issues surrounding damage caused by Anglian Water on the same site; • Destruction of soil structure and remedial cultivations; • Ecological disturbance; • Land sterilisation and potential for cross contamination; • Protection of features subject to statutory or non-statutory designations; • Effect on the local community; • Access during and after works by contractors and operators casing interference and disturbance; and • Potential interference with underground telephone line, Anglian Water infrastructure and any other service media. This representation is made to identify Mr and Mrs G Kerry as an interested party in the Project. "
Members of the Public/Businesses
Brown and Co on behalf of Necton Farms Ltd
"Necton Farms Ltd own 89 acres of agricultural land which has been identified as the site of the on-shore substations, to include the Vanguard and Boreas substations and the National Grid connection sites. A small proportion of the proposed substations is positioned outside of Necton Farms’ ownership. 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, circa 50 acres taken out of production for up to 5 years’ 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. "
Parish Councils
Oulton Parish Council on behalf of Oulton Parish Council c/o Mr L Mills, Clerk to the council
"Oulton Parish Council welcomes the use of HVDC and the installation of ducting for Norfolk Vanguard and Boreas if both projects progress; this will reduce the construction time for the projects and the impact on residents. However there are still issues of major concern: 1. Cumulative Impact OPC are still unaware of how Norfolk Vanguard’s cable route/mobilisation zone/cable logistic area and Orsted Hornsea Three Main Construction Compound at Oulton will interact with each other, given that they will be using the same access route B1149/The Street. The cumulative impact from traffic created by the two projects and its interaction with existing agricultural traffic, local businesses, tourists going to Blickling Hall and local residents has not been assessed. The rural road network in Oulton is already stretched almost to breaking point with the very large scale (both in vehicle size and volume) of existing agricultural traffic. Vattenfall has used Orsted Hornsea Three PEIR documents to assess cumulative impacts, but Oulton’s Main Compound did not appear in those PEIR documents. (Orsted have still not fully assessed this area nor put together a CTMP.) There is also a lack of information on the cumulative impact of Norfolk Vanguard and Orsted Hornsea Three projects on residents of Oulton regarding noise, traffic, air quality etc. Vattenfall PIC (Personal Injury Collison) data did not include B1149. Orsted Hornsea Three used PIA (Personal Injury Accident) data, which included sections of B1149, indicating that accidents were 25% higher than the national average. It would appear that the two projects, although accessing the same road routes, are neither assessing the same data, nor in the same way. NCC/BDC may not have been fully aware of all data relating to Oulton at time of consultations due to late addition of Vattenfall’s Cable Logistics Area and lack of traffic details relating to cumulative impact of Norfolk Vanguard & Orsted Hornsea Three on Oulton. There are concerns over the B1149 where the cable route crosses the road. Vattenfall have said they will not be using trenchless crossing (horizontal directional drilling) but will dig up the road to install their cabling. Orsted Hornsea Three will be using B1149 at potentially the same time. How will a CTMP work around this? One residential property in particular will be impacted directly by both projects, being next to the entrance to Saltcarr Farm and directly alongside the proposed shared access route for both projects - the southern end of Oulton Street. This impact has not been assessed. This property was highlighted in a planning appeal, alongside the unsuitability of ‘The Street’ to cope with large volumes of HGVs….. Appeal Ref: APP/K2610/A/14/2212257 . In summary, there is no specific traffic data in the DCO documents that looks at the cumulative impact at Oulton, from either project. 2. Cable Logistic Area The Cable Logistic Area is only mentioned on maps, no data in any documents specifically describing its location, function or reason for selection. This area was a late addition and only appeared on final maps. Link 68 only seems to refer to traffic to Mobilisation Area and cable route - traffic to and from Cable Logistic Area is not mentioned in DCO documents. 3. Other Issues Some areas of cable route seem to have been omitted in the ES, specifically Oulton area (Map 4). Blickling Conservation Area is missing from map ‘Policies and designations (map 4)’ Confusion in some documents where Breckland appears twice in tables and Broadland District Council is omitted. "
Other Statutory Consultees
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 and can confirm that:- 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. Please do not hesitate to contact us if you have any questions or concerns. "
Members of the Public/Businesses
Richard Barr
"Whilst I do not live directly along the line of the proposed route of the cables I consider that this poses a serious threat to the environment and amenity of a large area either side of the proposed development. Its impact will be huge, in an area that is already under strain from another intrusive development at the neighbouring village of Bacton. This is a largely unspoilt part of the countryside. It attracts thousands of visitors each year, many of whom come here because of the peace of the area. That peace will be shattered not only during the prolonged construction period, but also in perpetuity afterwards when the scheme is up and running. There will undoubtedly be increased noise and light pollution, along with excessive and prolonged noise pollution during the construction process. As has been pointed out, there is a perfectly feasible alternative - to bring the cables ashore and to connect up with the Walpole substations. It would involve a far shorter run of cables on land, and would be far less disruptive. I doubt that the cost would be significantly greater. I write from the point of view of an inhabitant of north Norfolk, but I am very much aware of the damage that will also be done along the whole length of the cables - and of course the impact when they reach their destination in mid Norfolk. I know it may seem xenophobic, but why on earth do we have to have a project created by a foreign company (who, like all other electricity suppliers) will profit from our country. If there has to be such a project why can it not be carried out by an English company?"
Members of the Public/Businesses
Roberta Spain
"Good afternoon, I am terribly concerned about the proposed 100 acre Vanguard/Boreas substations which is currently in planning in the town of Necton. I strongly believe the proposed development will have sustained and long term detrimental effects on the residents of the town, around 2000 in residence, and that there has not been adequate effort by Vattenfall to find alternative locations. There is significant research suggesting electric and magnetic fields produced by the substation cause diseases, principally childhood leukaemia. The village of Necton has a thriving youth population and a primary school which is putting the whole community at risk. Although there will be reassurance that the substation will comply with the exposure limits, why not put the substation at the site near Scarning and Wendling which is not close to residents and would use the same pylons requiring shorter cable distance and is supported as an alternative site by National Grid! This proposal should not go ahead for Necton which has already seen a substation been built, more than the communities fair share. I encourage the Secretary of State to reconsider and protect the residents. "
Members of the Public/Businesses
Stefan Flexen
"Hello, My correspondence is regarding the Vanguard/Boreas substation proposed development. The site which is being proposed is too close to a 2000 strong community who has already seen one substation built. As an acoustic professional I have grave concerns over the sound and light levels which the residents will be subjected to and the future where there is a high likelihood that more will be built. There are sites which would be more suitable in Scarning and Wendling. These sites are not located as close to residents but have the same infrastructure to pylons and is supported by the National Grid. Necton is a thriving community with new developments and businesses choosing it as a prime location. This substation does not need to be built on the doorstep of this community and I would urge a rethink to developing a site further away. Thank you, Stefan "
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of A W Ditch and Son
"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 VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor "
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Albanwise
"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 VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor "
Members of the Public/Businesses
Brown & Co LLP. on behalf of Angloflora Farms Ltd.
"Angloflora Farms Ltd. have approximately 65 acres of agricultural land forming four parcels which are identified as being affected by the Vattenfall cable route. This representation sets out Angloflora Farms Ltd.’s concerns for the project. The proposed cable route will have an effect on the holding and the farming business certainly in the short term and potentially in the longer term if the concerns of Angloflora Farms Ltd. are not dealt with appropriately. The current key concerns are as follows; • The proposed route and associated access affects four land parcels, either directly as the working area of the cable route or by provision of access; • Severance to productive arable land during construction; • The impact on the farming business and residential occupation of the farm during construction phase; • Crop loss and other associated losses including damage to underdrainage systems; • Concerns over soil stripping, storage and subsequent reinstatement; and • Destruction of soil structure and remedial cultivations; • Ecological disturbance; • Land sterilisation and potential for cross contamination; • Protection of features subject to statutory or non-statutory designations; • Effect on the local community; • Access during and after works by contractors and operators causing interference and disturbance; and • Potential interference with existing drainage for which plans are not available and any other service media. This representation is made to identify Angloflora Farms Ltd. as an interested party in the Project. "
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 VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH 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
"Our client's other 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 VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor "
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Diocese of Norwich
"Our client's other 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 VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH 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 and 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 VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH 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 T 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 VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor "
Members of the Public/Businesses
George Freeman MP
"The local community and their legal representatives have repeatedly made the case that Norfolk Vanguard Ltd/Vattenfall UK’s pre-application community consultation was inadequate – and I very much agree with them. Indeed, little, if any, information has been provided as to why this site has been chosen ahead of other sites and when specific queries/concerns about a range of aspects concerning the proposals have been raised by individuals, a generic set of FAQ style answers have, for the most part, been used to answer them. My office and I have received similar such answers from Norfolk Vanguard Ltd/Vattenfall UK and, therefore, can very much sympathise with the view locally that they have disregarded the expressed views and concerns of local Councillors, residents and businesses (as well as my own as the local Member of Parliament) by tailoring these FAQs to provide vague ‘answers’ to very open ended questions – in a process that they clearly see as being a mere ‘box-checking’ exercise. Few people in Necton and the surrounding area believe that they have actually received an answer that adequately addresses the specific question that they have asked, and there remains considerable confusion about the true nature of these proposals and how they will likely impact the surrounding area. Specifically, the community has expressed concerns about the visual and environmental impact of the high vantage site chosen by Vattenfall, without any support from the local community. Furthermore, the visual representations being provided by Norfolk Vanguard Ltd/Vattenfall UK have been inadequate. Requests from both the community and myself for up to date visual files to be provided have continued to be refused (even after the decision to pursue the HVDC option), despite the grave concerns that Necton and its surrounding communities have about the likely visual impact that the proposed substation will have on the area. I firmly share the widespread local belief that the application is sited incorrectly – as the site is located on some of the highest land in Norfolk and consultation has been disingenuous. Having visited it several times, spent time in the heart of the village and viewed it from surrounding villages, it is clear that any construction there will be a significant visual blight. As alluded to above, the decision to pursue HVDC will massively compound the problem – with a structure of approximately 25m in height being required at this incredibly prominent location. I have no doubt whatsoever that this would result in the substation being visible, not only to all of Necton, but also to a number of villages within a several mile radius. I have very little faith that even the best mitigation techniques will quell this enormous visual impact on the surrounding area. As the local community and their legal representatives have also repeatedly made clear, insufficient environmental information has been provided by Norfolk Vanguard Ltd/Vattenfall UK as part of their plans. This has taken on even more importance in recent weeks as I have been made aware by the local community of grave local concerns relating to the crash of an F-16 fighter jet at the location back in 1996. A major military clean-up operation was required at the time, with the land having been contaminated with hazardous fuel and, it is feared, radioactive substances. Farming was not permitted at the location for some time due to the likelihood that traces of the contaminants would still be present, and many locals are concerned that, under the proposals, Norfolk Vanguard’s cable corridor will run through the site and disturb any remaining contaminants – posing a serious threat to the surrounding community. Despite Norfolk Vanguard Ltd/Vattenfall UK having been made aware of these circumstances, it appears that they have still not taken steps in response to this information. While I, as the MP, am not opposed to the proposals for a substation in this part of Mid Norfolk in principle, and have consistently made clear to my constituents and Norfolk Vanguard Ltd/Vattenfall UK my desire to broker an arrangement that all parties can largely support, the applicants refusal to properly consult leaves me with no choice but to forcefully support my constituents and local Councillors in opposing this application for the reasons I have discussed. I do not believe the plans put forward are at all acceptable in their current form. I urge you to insist that specific site consultations be redone, as I have no doubt that otherwise they will be subject to a successful Judicial Review. "
Members of the Public/Businesses
Geraldine Allen
"As a local resident I am writing to strongly oppose the plan for substations in Necton for the following reasons: 1. The site is set at the highest point in the area which increases its visibility in a beautiful landscape and will impact negatively on property prices 2. The noise level generated by the site in sound and vibrations is unacceptable in this rural area 3. The site is between the toxic area of a plane crash and also impinges on an archaeological area 4. There are two other suggested sites which would have less impact on the neighbouring community which have not been adequately explored. "
Other Statutory Consultees
Health and Safety Executive
"On the 6/8/18, I emailed Ruari Lean (Project Manager) to say that "I co-ordinate HSE’s NSIP responses and have been looking through the application documents on the PINs Website for Norfolk Vanguard but cannot find the specific location which addresses the points raised in the letter from HSE attached. Please could you point me in the right direction? I have looked through the Consultation Report and S42 response document, amongst others. I want to point out any specific responses to the points made by HSE to our Risk Assessors. We may need to raise a Relevant Representation otherwise but I wanted to check with you first". As we have received no response, the points made under Section 42 of the Planning Act remain relevant: "Will the proposed development fall within any of HSE’s consultation distances? The table below illustrates the major hazard sites and pipelines which may be affected by the onshore elements of the Norfolk Vanguard offshore wind farm. The actual sites and pipelines will depend on the final route of the export cables. HSE Ref. Site/Pipeline Operator Operator Ref. Site/Pipeline Name Pipelines 7446 National Grid Gas 1705 5 Feeder Bacton to Yelverton 7450 National Grid Gas 1709 Bacton to Roudham Heath 8371 National Grid Gas 2648 Bacton to Kings Lynn Comp. 12238 National Grid Gas 2739 27 Feeder Bacton to Kings Lynn 7409 National Grid Gas 1668 East Dereham to Wells 8377 National Grid Gas 2654 Brisley to Bushey Common 7413 National Grid Gas 1672 Bushey Common to Saham Grove 7414 National Grid Gas 1673 Saham Grove to Swaffham There are other, non-Major Hazard pipelines in the area (possibly operated by BPA and GPSS) that may also be affected by the proposed NSIP. Would Hazardous Substances Consent be needed? The presence of hazardous substances on, over or under land at or above set threshold quantities (Controlled Quantities) may require Hazardous Substances Consent (HSC) under the Planning (Hazardous Substances) Act 1990 as amended. The substances, alone or when aggregated with others, for which HSC is required, and the associated Controlled Quantities, are set out in The Planning (Hazardous Substances) Regulations 2015. Hazardous Substances Consent would be required if the site is intending to store or use any of the Named Hazardous Substances or Categories of Substances and Preparations at or above the controlled quantities set out in schedule 1 of these Regulations. Further information on HSC should be sought from the relevant Hazardous Substances Authority. Explosives sites There are no licensed explosive sites in the vicinity. However, there is a fixed rule licence for Maritime and Coastguard Agency North, Norfolk, Sector Base, Pollard Street, Bacton, Norfolk NR12 0LB. We are unable to make a decision until we know where the construction traffic will go and where the control station for the windfarm will be and if it will be manned. Please contact us via the email address above". "
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of J Grier
"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 VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor "
Members of the Public/Businesses
Savills (UK)Ltd (Savills (UK)Ltd) on behalf of Mes A Green
"Our client supports green energy. There are concerns in respect to the route of the cable which currently is proposed to be laid through our clients property; The construction corridor will be within 50m for our client’s residential property creating substantial disturbance Major disturbance to horse livery business during construction and will continue to impact on the business at least 2 years after the scheme has been completed. Negotiations are still on going to amend the route of the cable through arable fields. Vattenfall have advised the chosen route is to avoid archaeology although at the present time they have not been able to confirm the significance of the archaeology. The access to the construction corridor is through the front drive of the residential property and not practical. Negotiations are ongoing in this regard. The route sterilises the land for an future development. Our client's other 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 VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 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
Miss Phoenix
"Dear Sir, Further to Vattenfall’s erroneous decision to try to locate two huge substations in the village and hamlet of Necton and Ivy Todd respectively. This letter outlines some of the obligations to this plan, starting with their own PIER report in which Vattenfall contradict themselves on numerous occasions. It is quite clear that have NOT completed a proper, thorough and legal consultation and investigation. The residences closest to the proposed substation site at West End have NOT been consulted and completely ignored by Vattenfall. New people have moved into the area to suddenly find there is a possibility of two huge substations on their doorstep – the searches they carried out before purchasing NEVER highlighted this, which is staggering shocking because hiding something as important as the possibility of a proposed two huge substations is wrong on so many levels. Vattenfall, therefore, cannot go ahead with this proposal, they have to go to an alternative site. In the initial consultation, Vattenfall spouted about ONE substation for Vanguard; they NEVER said anything about the second substation Boreas. I have this in their leaflet, which only mentions ONE substation. So either Vattenfall has systematically lied from the outset or they are very bad at planning and realised ‘late in the day’ that they needed another substation. Either way, it calls in to question their transparency, competency and casts a shadow over the whole proposed project. Vattenfall, therefore, cannot go ahead with this proposal, they have to go to an alternative site. Independent noise experts have stated quite clearly that Vattenfall are UNABLE to get the noise from the two substations within the agreed legal limit. Vattenfall does not seem to be interested at all in the proper investigation into this important issue. If Vattenfall cannot obtain the legal limit for noise, for THEIR preferred site at Necton/Ivy Todd and they CANNOT, then they need to go to an alternative site. Vattenfall think they can bully and baffle their way to building these huge substations at Necton/Ivy Todd, throughout the whole process so far they have displayed arrogance to a staggering scale thinking they know better than the local community, some of whom were born here. Vattenfall think they know better than independent experts, they don’t. Vattenfall, therefore, cannot go ahead with this proposal, they have to go to an alternative site. We have heard from a Farmer who knows the soil and is actively encouraged by the Government to look after the soil; has stated that burying the cable underground will actually destroy the soil by killing the bacteria and rendering the ground useless for years if not irrevocably, catastrophic in a rural farming community that is Norfolk. Vattenfall have glossed over this FACT in their insatiable greed and desire to destroy Norfolk and Necton/Ivy Todd. Vattenfall has been told there is a cheaper and more viable alternative to go around the coast with a Marine Cable and join the Marine Cable Connector at Walpole near Sutton Bridge that DONG are putting in now. Vattenfall need to properly investigate and seriously consider this as a better, cheaper alternative option, then destroying huge swathes of Norfolk with burying cable that are ultimately destructive to the land and destroy a local community in and around Necton/Ivy Todd, which are a VILLAGE and HAMLET respectively NOT A TOWN and a VILLAGE as misrepresented in their PIER report. When I attended the last consultation meeting on the 10 November 2017, Vattenfall own employee [] admitted no-one wanted the substation anywhere and she wouldn’t want one where she lives! While [] was pleasant to talk to, her answers on the Marine Cable showed Vattenfall haven’t looked into this option at all. Vattenfall’s drive is “there is only one place for the substations and that’s Necton/Ivy Todd” Vattenfall are not interested in the slightest at looking at cheaper, viable and vastly better alternatives. Vattenfall are far too arrogant, ignorant and supercilious to even try and consider them, which is precisely why this project should NEVER be given the go-ahead because it will destroy Norfolk as a farming community by rendering the soil useless. Furthermore, they will destroy Necton/Ivy Todd a designated dark rural landscape with businesses built up around that designation and the surrounding communities irrevocably. Vattenfall, therefore, cannot go ahead with this proposal, they have to go to an alternative site. The National Grid would support a move to an alternative site, so Vattenfall are not bound to Necton/Ivy Todd in anyway other than by their blinded arrogance. Vattenfall cannot in any way justify their determination to destroy Necton/Ivy Todd and the surrounding communities in the slightest. Fransham Parish Council has already rejected Vattenfall planting their huge substations on Vattenfall’s proposed site. 66% of Necton/Ivy Todd residents have said NO in a resounding manner to Vattenfall’s proposal of two huge substations here, which will add 50% to the size of the village. Vattenfall does not seem to have looked at access to their preferred site, which only seriously viable option here is from the A47, as the rest of the roads around Necton/Ivy Todd community are single country LANES, completely UNSUITABLE for heavy construction traffic. Vattenfall, therefore, cannot go ahead with this proposal, they have to go to an alternative site. I look forward to your reply to this letter and this important matter, which I hope is given your utmost consideration. Thank you. Yours sincerely Miss H Phoenix "
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mr and Mrs J Leeder
"Our client is a long standing successful local business specialising in outdoor pig breeding and employing local people. The proposed scheme severely impacts on the business. It will be necessary to relocate the 900 sows plus accompanying piglets and replacement stock whilst the scheme is under construction Relocation will be a major operation and finding alternative suitable land within the area will not be easy. At this point in time Vattenfall are unable to give a clear indication of the construction timetable which makes it very difficult to plan for the future of the business "
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mr P Bunting
"Our client's other 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 VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor "
Members of the Public/Businesses
Brown & Co on behalf of Mr Peter Edwards
"1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) and the Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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. "
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mrs A Jones
"Vattenfall are still in negotiations with our client but at the present time there has been no confirmation on; 1. The current access route to the construction corridor being amended. The current proposed access is not physical possible due to the levels between the road and the field as well as the presence of an Oak Tree 2. The current route being amended to avoid the destruction of a belt of 40 year old deciduous hardwood trees and reduce the depth that needs to be drilled to directly drill under the River Wensum. The current area for the drill pit is near the top of a ridge, over 15 m higher than the river Wensum and approx 300 meters from the River Wensum. Our client's other concerns are outlined in the ‘Outline Representations’ detailed below prepared by NFU and LIG (working group). IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). _____________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONENLEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor "
Members of the Public/Businesses
Savills on behalf of Mrs C B Hart
"Our client is an affected landowner. They are concerned that the environmental impact of this project is fully explored and understood before development is undertaken. The impact should be minimised as much as possible, the local wildlife disturbed as little as possible, ensure the local residents are not blighted by noise or light pollution from the construction and mitigation from the disruption of large vehicles on small lanes. It is important that the integrity of the top soil and drainage systems that are within the cable corridor are treated appropriately to minimise damage. "
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mrs P Carrick
"Our client's other 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 VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH WARWICKSHIRE CV8 2TZ REF Louise Staples, MRICS, FAAV Rural Surveyor "
Members of the Public/Businesses
Mrs Valerie Morris
"The impact of Vattenfall's actions on the local population concerns me. Electricity and people do not go together. I had a shock from the National Grid as a child and lived next to a pylon for just over 40 years, With what is already in place, sea animal radars are being affected. Concreted land doesn't encourage healthy crops on the surface. The acreage to be lost is a lot. People living nearby will slowly deteriorate health wise. The brain to function properly relies on ample liquid. In the summer when the air is naturally drier we drink more otherwise the body dehydrates and we get angry quickly. Electricity automatically disrupts oxygen levels which even full size mature trees would have a tough time handling. Planting trees after installation is like the closing the door after the horse has bolted. Hawthorn hedging is best as a first. Trees need space to flourish and set down a good rooting system. Where I moved from a lot of the food had "Produced in Norfolk" on the label. With all the other projects in the pipeline for Norfolk much agricultural land will be lost as it succumbs to concrete and tarmac coverage. This island is overpopulated for the resources we have. Food is important. I have asked the question of location of plague pits. With nationwide overbuilding this may cause a problem. Solutions to known problems should be worked out before any installation takes place. The consequences of bad management in terms of health will show up very quickly. Storage of electricity is a problem. Vattenfall could add to that. Is that responsible? I have no answers for you. Air quality is one reason I moved here. The natural balance will be upset. Have you consulted a Geomancer. The Earth after all is a living organisation itself."
Other Statutory Consultees
National Grid Electricity Transmission PLC and National Grid Gas PLC
"Representation by National Grid Gas Plc and National Grid Electricity Transmission Plc (together ‘National Grid’) to the Norfolk Vanguard Offshore Wind Farm Order Development Consent Order. National Grid wishes to make a relevant representation to the Norfolk Vanguard Offshore Wind Farm Offshore Wind Farm DCO 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, above ground installations (AGI’s) and a gas terminal located within or in close proximity to the onshore scoping area. The transmission pipelines along with AGI’s and terminals 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 agnational reement. "
Non-Statutory Organisations
Norfolk Wildlife Trust
"The Norfolk Wildlife Trust (NWT), has more than 35,000 members and has been taking a lead role on action for wildlife in Norfolk, since its foundation in 1926. NWT is one of a network of 46 Wildlife Trusts (TWT), which 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. NWT and TWT work closely together with regard to the impacts of offshore wind farms. NWT input to the planning process, with regard to offshore wind farms focuses mainly on onshore biodiversity impacts. In this context, NWT was a member of the Onshore Ecology Working Group and submitted comments jointly with the Wildlife Trusts at the PEIR stage. The principal issue is mitigation of impacts on Local Wildlife Sites, which may occur through cabling or associated location of haul roads. In addition, with regard to mitigation of impacts on great-crested newt, we wish to see consideration made to the potential for using the new Natural England licencing procedure to enable restoration of great-crested newt habitat, in order to mitigate for impacts of cabling. With regard to offshore impacts, we support The Wildlife Trust’s submission regarding impacts of noise on marine mammal and inclusion of fishing in cumulative/in-combination assessment. "
Members of the Public/Businesses
Peter Soldan
"I live in Ridlington, less than 500Metres from the proposed site for the Mobility Area, on the Happisburgh Road. I support the development of renewable energy and the need for an increase in such energy to replace the use of fossil fuels. It is very clear that we are consuming fossil fuels, which were formed over many millions of years, far too rapidly. Such development should, where possible, use the approach which has least negative impact on the environment. Vattenfall have taken a major step in this direction by adopting the HVDC approach to the transmission of the electrical power from the wind farm to the National Grid. This will reduce the impact on North Norfolk and the Coastal/Countryside area very significantly. The Relay Station would have had a major impact on this area throughout its operational life and reducing the number of cables to be installed from 36 to 8 will reduce the construction phase impact dramatically. My primary areas of concern are: 1. The project should not be allowed to reverse the adoption of the HVDC transmission decision without a resubmission of the project to the Planning Process. For many Norfolk residents our representations would be very different if there was a possibility of an HVAC solution being adopted. 2. The level of both Heavy Goods Vehicle and construction traffic associated with the Duct Installation phase of the project and its impact on roads and 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. The MA should only be used during the duct installation phase 2021 to 2023, security should be via passive sensors and cctv not illumination to avoid the impact on local residents and wild life (bats, owls etc) and it should be positioned much closer to the B1159 to reduce the impact on the Happisburgh Road which is not suited to 2-directional HGV traffic. 4. The land fall should not be at Happisburgh without some protection from further coastal erosion. The rate of erosion is such that the cables will be exposed at some time in the lifetime of the wind farm and the jointing box will need to be protected. It would be better to plan and do it now, not when it will cost more. The land fall should have been planned to be where there are coastal defences in place. Other better options were rejected earlier in the planning process because it was claimed that the HVAC requirements could not be accommodated at those locations. With regard to the Mobility Area on the Happisburgh Road and the projected HGV traffic during the duct installation period, 2021 to 2023. Happisburgh Road is not capable of carrying two-way HGV traffic and there is a real possibility that contractors/drivers will approach/depart through Ridlington village when the road is 'proved' to be too narrow to carry the two-way traffic between the B1159 and the Mobility Area. Vattenfall, at a meeting in the Witton and Ridlington village hall, stated that traffic would not be allowed to go through Ridlington village, however, we need to know what measures will be applied to ensure construction traffic is kept out of the village. Contractors and/or drivers, on piece-rates or following their sat/nav systems, may well decide to ignore Vattenfall's directions if there is congestion. This Mobility Area should be closer to the B1159 and access should be either direct from the B1159 or the Happisburgh Road widened between the B1159 and the Mobility Area. "
Members of the Public/Businesses
Rupert Lovegrove
"I am opposed to the proposal for a further two substations to be built at Necton. I live very close to the existing substation and have a very clear idea of the intrusion into many peoples lives that this proposal will cause ,during and after construction. My main personal concerns are with the massive extension of the National Grid part of the project ,do the NG have to follow the same rules as private companies as regards noise levels ,light pollution and proper visual screening of the development? The proposed NG extension would reach very close to the A47 and indeed our property and this would not allow enough land for adequate screening of the site. This substation would be very visible and distracting to drivers on an already overstretched and risky area of the A47. I have been disappointed with the lack of information provided by consents solutions and vattenfall concerning screening and noise / light levels during and after construction .I have also not yet received an explanation as to why our property is part of the vattenfall 'corridor' . "
Members of the Public/Businesses
Sheila Rowe
"The Vanguard and the following on Boreas substations are being built far too close to the houses in Necton village. They will be very tall (up to 25 metres) and take up a lot of agricultural land (an additional 100 acres above the substation already in existence). Vattenfall have told us that the buildings are too big to be screened from view. This is a rural village and the character of the village will be ruined by the huge infrastructure planned. There is an alternative location for these substations that National Grid have said is suitable for the substations that is not close to a village and has very good access. It will have shorter cable runs so will be better for the environment. Please ask them to investigate this site before agreeing to this application going ahead. I am also concerned that the buried ground contamination from a plane crash in 1996 will be disturbed. There was a lot of remediation at the time and the ground could not be used. The National Rivers Authority warned MAFF that there was an ongoing radiation risk that I don't want to see unearthed and spread. Vattenfall have not included this in their planning application, although they were officially informed of it. This makes me suspect they are not an ethical Company who will spread the contaminate towards the village and into the ground water. This site is therefore not suitable for the proposed plans."
Non-Statutory Organisations
The Wildlife Trusts
"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 Vanguard Marine Mammals Expert Topic Group and as such, this representation focuses on marine mammal. However, we also support Norfolk Wildlife Trust’s submission regarding onshore biodiversity impacts. 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 (SNS) SCI. We are pleased that the applicant has committed to the production of a Site Integrity Plan (SIP). However, in its current form the SIP lacks detail and therefore TWT does not consider it adequate to ensure no adverse effect on the SNS SCI beyond reasonable scientific doubt. To achieve this, 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 SNS SCI. Noise modelling should also be undertaken to demonstrate the degree of noise reduction which could be achieved through mitigation. Finally, TWT recommends that all offshore wind farm developments should be conditioned as part of their Development Consent Order to pay into an underwater noise levy which would fund and deliver strategic mitigation and monitoring and establish an implementation group. Based on the scale and ambition of the offshore wind industry, there is potential for tens of thousands of harbour porpoise to be impacted by underwater noise disturbance (up to 75,789 porpoise indicated in appendix 12.6). Therefore, a mechanism to deliver strategic monitoring and mitigation to understand and manage in-combination underwater disturbance impacts is urgently required. TWT has produced a paper on the underwater noise levy which we are happy to share with the Planning Inspectorate. TWT value the relationship developed with applicants during the pre-application stage. Due to the uncertainties on marine mammal mitigation and monitoring at examination, we wish to be named on any associated documents for consultation post-consent including Marine Mammal Mitigation Protocols 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. More generally on underwater noise management in relation to harbour porpoise: • TWT does not agree with the current SNCB proposal on underwater noise management. The science underpinning the approach is weak, it is difficult to deliver and does not encourage noise reduction. • Underwater noise should be managed at a regional seas level using noise limits. Noise limits should apply across all construction activities associated with offshore wind farm development. This approach is used in Germany, the Netherlands and Belgium, and should be applied in English and Secretary of State waters, ensuring consistency across the Southern North Sea. • Detailed monitoring of noise levels and harbour porpoise population activity should be undertaken at a strategic level to verify predictions made in planning applications and to provide information for the growth of the offshore wind sector. Finally, we would also like to raise that fishing has not been included in any cumulative/in-combination assessments for Norfolk Vanguard. TWT does not consider fishing to be part of the baseline. Following the commencement of judicial review proceedings by TWT against Dogger Bank Wind farms, we were given assurances that fishing would be included in future offshore wind farm assessments. We make this case for all SACs assessed in the application. "
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Trustees of Stinton Hall Trust being Sir David Chapman, Grant Picher, Micheal Dewing and William Edwards
"IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 ?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. 4.2?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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5.?Construction and Funding 5.1 ?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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6.? Cumulative Impact 6.1 ?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. 7. ?Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8.? Field Drainage 8.1 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 but it is not satisfactory. 8.2?To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. ?Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10.?Flood Issues 10.1 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. 11.?Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. ?Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. ?Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14.?Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018.? IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH WARWICKSHIRE CV8 2TZ REF? Louise Staples, MRICS, FAAV ?Rural Surveyor "
Local Authorities
Breckland Council
"Breckland Council intends to submit a Local Impact Report in terms of the planning issues for the District."
Local Authorities
Broadland District Council
"The District Council notes that the proposed development will deliver a significant national benefit in the supply of substantial renewable energy in the UK. However the anticipated local impacts should be addressed. A separate cable corridor and associated development within the District is proposed as part of the Hornsea Three off-shore windfarm. The cumulative impacts of the two proposals need to be considered. In this respect it is noted that Hornsea Three are proposing their main construction compound on part of the former airfield to the east of Oulton, in addition to the two construction compounds that Vattenfall are proposing in Oulton using the same access road as the Hornsea Three proposals. There are concerns about whether the construction programmes will overlap and therefore cause significant disruption in the village and the surrounding area. In addition the two cable corridors cross at a point north of Reepham and this has the potential to increase the visual and environmental impacts of the proposal in the locality of this intersection. The installation of the cable route will also require the removal of sections of hedgerow; these will have to be assessed using the criteria set out in the Hedgerow Regulations 1997 to establish if they would be considered as important due to the flora, fauna or historical significance associated with them. If sections are removed and cannot be replaced following installation of the cables this will have greater long term significance to the landscape of the locations and some form of mitigation would be appropriate which could include replacement planting on adjacent land. The District Council would like to reiterate that the Norfolk authorities have signed up to County position statement in respect of offshore wind energy proposals that was sent to the Rt. Hon Dr Greg Clark MP on 26 February 2018 which requests that the offshore energy companies undertake to: a) Secure improvements to the local electricity distribution networks in the County; and b) Ensure real economic benefits in respect of the (i) provision of high quality jobs; (ii) creation of training/skills initiatives in the energy sector and (iii) the provision of wider community benefits. "
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of C Siely
"IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 ?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. 4.2?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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5.?Construction and Funding 5.1 ?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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6.? Cumulative Impact 6.1 ?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. 7. ?Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8.? Field Drainage 8.1 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 but it is not satisfactory. 8.2?To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. ?Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10.?Flood Issues 10.1 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. 11.?Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. ?Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. ?Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14.?Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018.? IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH WARWICKSHIRE CV8 2TZ REF? Louise Staples, MRICS, FAAV ?Rural Surveyor "
Members of the Public/Businesses
Bidwells on behalf of Christopher S Wright
"I have specifically raised the following points with Vattenfall which need further consideration:- - That the cable depth be increased to 1.75 metres on health and safety grounds. - That the route of the cable easement across my property be diverted/re-routed southwards to minimise the disturbance, noise and dust which would greatly affect the Elm Farm house and buildings where I live and the adjoining residents. - The proposed access routes to the easement strip are unacceptable as they infringe on the privacy and enjoyment of my property. Alternatives have been suggested. The outline representations which I support are detailed below as prepared by the National Farmers Union in conjunction with the Land Interest Group of which Bidwells representing me is a member. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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 as this takes more land out of agricultural production. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 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
Cllr. Graham Everett
"I am the elected Broadland District Councillor for Reepham Ward and as such have had numerous meetings with the Applicant. I fully support renewable energy and the Vattenfall Project, however, due consideration must be given to the impact on the local communities and unnecessary disruption must be avoided whenever possible. The Reepham area will already incur significant disruption as Orsted have submitted a DCO for a scheme (Hornsea Three) within a similar timeframe and the cable routes cross with Vattenfall in the Reepham area. I have urged the applicant to use trenchless crossing (HDD technology) at 3 key road crossing points on the B1145 to minimise the overall disruption in the area. The applicant is not prepared to consider this request which is extremely disappointing so I respectfully ask the Inspectorate to consider requesting this should Consent be granted. The B1145, although categorised as ‘B’ is a very important connecting road from Kings Lynn through to North Walsham and a key route between the A1067 and the A140 at Aylsham. Vattenfall are proposing to use trench crossings at these 3 road crossing points, closing one lane at a time under traffic light management which I find unacceptable especially on Dereham Road at Pettywell, Reepham. Vattenfall are proposing to use HDD technology to cross Marriott’s Way which is only a few metres south of the B1145 therefore I can find no valid reason why this area could not be extended to include the B1145. The B1145 is a heavily used road especially by large commercial, farm and other large agricultural vehicles, I believe it would be unsafe and unacceptable to consider reducing this road to a single lane especially as the cable route is on a bend and the workers in the trench would need an additional safe working zone not just half a road width otherwise an accident could be waiting to happen. I believe the 2 other cable crossings on the B1145, both on Cawston Road should have HDD trenchles crossings again on similar safety grounds. Orsted cable routes will cross inbetween the 2 Vattenfall crossings on the B1145, Cawston Road, and they are using HDD crossings, not only in this location but for every road crossing irrespective of the road classification. As Orsted are uncertain as to whether they will be using HVAC or HVDC technology their HDD trenches could be up to 80 metres in width yet will use HDD, I submit that Vattenfall should be able to accommodate this request at 3 key road crossing points especially as their trench width will only be a maximum of 45 metres."
Members of the Public/Businesses
Dennis Jackman
"The proposed Vanguard / National Grid substations will be sited near to my house in Necton. The previous Dudgeon / National Grid substations construction was very noisy and there was light often all through the night. The plans for the Vanguard substation show that they will be working antisocial hours for months and months. To make matters worse, they have stated that there will be ongoing maintenance, also during antisocial hours. These substations should not be constructed close to houses. "
Non-Statutory Organisations
Eastern Inshore Fisheries and Conservation Authority
"1.0 Role of Eastern IFCA 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 six nautical miles out to sea. The proposed offshore cable route for Norfolk Vanguard Offshore Wind Farm will pass through the Eastern IFCA district. Therefore, given the potential impacts upon inshore fisheries and habitats, it is considered appropriate for Eastern IFCA to provide comment on the Environmental Statement for this development. It should be noted that our interest focuses primarily on the inshore section of the cable route corridor. 2.0 East Marine Plan policy In all consultation responses the Authority assesses applications according to their adherence with policies detailed in the relevant marine plan, as directed under section 58(1) of the Marine and Coastal Access Act 2009. The plans relevant to the Authority’s district are the East Inshore and East Offshore Marine Plans (HM Government, 2014). We consider whether proposed developments will have a positive, negative or negligible effect on plan policies related to the Eastern IFCA vision. 2.1 Policies BIO1 and MPA1 Any activity that disturbs the seabed has the potential to have negative impacts on habitats and biodiversity. The extent of these impacts is highly dependent on seabed habitat type, and the nature and extent of the disturbance. The export cable corridor for Norfolk Vanguard Offshore Wind Farm, which is anticipated to have a maximum long-term footprint of 150,000 m2, will run through both the Haisborough, Hammond and Winterton Site of Community Importance (SCI) and the Southern North Sea candidate Special Area of Conservation (cSAC). The cable route will also make landfall at Happisburgh South, close to the south-east border of Cromer Shoal Marine Conservation Zone (MCZ). Eastern IFCA would like to take this opportunity to note our appreciation for the change in the route to avoid the MCZ. 2.1.1 Haisborough, Hammond and Winterton SCI The Haisborough, Hammond and Winterton SCI is designated for a series of sandbanks which meet the Annex I habitat description ‘Sandbanks slightly covered by sea water all the time’. It is also designated for Annex I Sabellaria spinulosa reefs. The export cable corridor will run through the SCI, with installation expected to take six months of work, and anticipated cable repairs required at up to 10 km per cable pair at five-year intervals in the SCI. Temporary habitat loss, the remobilisation of sediment and disturbance is likely to result from each set of cable works, reburials and repairs. We appreciate that Vattenfall have stated its commitment to minimising cable protection where possible within the Environmental Statement, on the back of comments about Policy CAB1 of the East Marine Plan (HM Government, 2014). The worst-case scenario examined still states that up to 4 km of cable protection could be required in the SCI per cable pair if hard substrate is encountered (total of 8 km in the SCI). Cable protection would result in direct habitat loss where protection is placed. We would like to re-emphasize that cable protection works in Haisborough, Hammond and Winterton SCI are extremely undesirable, and are not in keeping with the East Marine Plans. Every effort should be made to maximise the length of cables that are buried and maintain burial over time. Using cable armouring instead of cable burial increases the likelihood of adverse environmental and fishery impacts. For more details on this matter please review the Eastern IFCA response to the Preliminary Environmental Information Report (PEIR) for this development (Section 3.3, Policy CAB1). We defer to Natural England for formal conservation advice on the impacts of the offshore cable corridor on both sandbanks and Sabellaria spinulosa reefs and measures that could be put in place to mitigate these impacts. As stated in Eastern IFCA’s response to the PEIR, Vatenfall should note that Eastern IFCA are seeking fishing closures (via a byelaw) to protect sensitive features within the inshore section (within six nautical miles of the shore) of the SCI. These closures are yet to be finalised, but any works in this area will need to proactively take into consideration up-to-date closures and the latest available information on the location of sensitive species and habitats. Eastern IFCA will ensure that any changes to existing fishery closures are duly publicised. Eastern IFCA is keen to encourage parity by encouraging regulators of non-fishing activities that could damage or disturb sensitive features (e.g. cable laying, remedial works and cable protection) to prevent or at least minimise such activities in areas closed to fishing for the protection of these features. 2.1.2 Southern North Sea Harbour Porpoise candidate SAC The entire Norfolk Vanguard site, including its export cable corridor, lies within the Southern North Sea cSAC, a European Marine Site designated to protect harbour porpoise under the Habitats Directive as transposed by the Conservation of Habitats and Species Regulations 2010 and the Offshore Marine Conservation Regulations 2007. Within Eastern IFCA’s response to the PEIR we requested that the impact of the project on sandeels, which are among the most important prey species for harbour porpoise and which inhabit and spawn in the project area, was further assessed in combination with other plans and projects in the Southern North Sea. We acknowledge that the Environmental Statement concluded that the potential for the project to significantly contribute to the cumulative impact on sandeel populations (because “the project overlaps with low intensity spawning grounds for this species with high intensity spawning areas located to the north of the project area”). This conclusion was drawn despite medium behavioural sensitivity of sandeels to underwater noise from piling and medium sensitivity of sandeels to permanent loss of seabed habitat during operation. We defer to Natural England for formal conservation advice on this matter, however we would like to once again highlight Eastern IFCA’s concern about the scale of both licensed and planned offshore activities (particularly aggregate extraction and offshore wind farm construction) in the Southern North Sea, because of cumulative effects these could have on seabed habitats. Sandeels depend on the presence of adequate sandy substratum in which they burrow and are demersal spawners that lay eggs on the seabed. Whilst we appreciate the difficulty in studying potential wide-scale impacts of all offshore activity, this is an important issue worth considering. 2.1.3 Cromer Shoal Chalk Beds MCZ The Cromer Shoal Chalk Beds MCZ protects a range of seabed habitats, including subtidal chalk reefs, and peat and clay exposures, which provide important habitat and nursery areas for a variety of marine species, including commercially important fish and shellfish species. To meet the conservation objectives of this designation, the general management approach for protected features is to maintain at favourable condition (Defra, 2016). Eastern IFCA agree with the conclusion that the cable corridor, which is located approximately 60 m from the edge of the MCZ, will have an impact of negligible significance on the MCZ, as the MCZ is deemed to be of low sensitivity and the magnitude of impact is negligible. We do however defer to Natural England for formal conservation advice on Cromer Shoal Chalk Beds MCZ. 2.2 Policies EC3 and ECO1 In response to the PEIR, Eastern IFCA stated that we “would encourage further assessment on an ongoing basis of the cumulative impacts of all Southern North Sea wind farm activity, as well as other activities including aggregate extraction activities. The impacts of these projects on the marine environment and fisheries should be assessed in-combination, highlighting any potential cumulative effects associated with the licence application.” While we understand the response from Vatenfall that this is “not within the remit of a single project and would need to be undertaken at a strategic level and under the guidance of Regulators”, we still believe that it is the collective responsibility of all projects to comprehensively assess the cumulative impacts, under the guidance of the Regulators. Eastern IFCA have already stated that we do not agree that already installed infrastructure and practiced licenced activities should not be included in the cumulative impact assessment. All possible cumulative impacts need to be assessed, regardless of whether an activity is already licenced, installed or otherwise. This should include, but not necessarily be limited to, planned and licensed wind farm and aggregate dredging activity in the Southern North Sea. 2.3 Policies GOV2, GOV3 and FISH1 Thank you for taking into consideration our comments regarding Eastern IFCAs support of the use of a local Fisheries Liaison Officer, the Kingfisher Information Service and Notice to Mariners to minimise disruption to fishers. We appreciate that as described in Section 14.7.1 of the Environmental Statement, Notices to Mariners, Kingfisher notifications and other notices will be issued as required to the fishing community in an efficient and timely manner. We would like to re-emphasise that this communication is extremely important to fishers’ livelihoods and should be carried out on a continuous basis and well in advance of scheduled works and closures during every phase of development. As stated within our response to the PEIR, although the level of fishing effort occurring inshore is much smaller than that applied by larger (predominantly Dutch) offshore fishing vessels, displacement (for example during construction or maintenance works, or because of cable exposure) can have disproportionately large effects on inshore fisheries, which are characterised by small vessels operating within a short range from launch sites. 2.4 Policy FISH2 2.4.1 Electromagnetic fields Overall impacts of electromagnetic fields (EMF) are assessed as an issue of minor adverse significance to elasmobranch species within the Environmental Statement. In the context of the assessments of EMFs, Vatenfall have stated that “it is important to note that from the results of other post-consent monitoring conducted to date, there is no evidence to suggest that EMFs pose a significant threat to elasmobranchs at the site or population level”. However, we highlight that there are appreciable gaps in the scientific literature as to the potential effects of EMF emissions from subsea cables on marine fauna, and therefore there remain uncertainties in the ability of Vatenfall to determine that there will be no adverse effects on fish and shellfish ecology. Eastern IFCA is particularly concerned about the proliferation of marine electricity cables off the East Anglian coast and the potential – but very poorly understood – impacts on marine life. Outside of the assessment of EMF impacts on elasmobranchs, Eastern IFCA would like to refer you to the recently published Marine Pollution Bulletin paper by Scott et al. (2018) on the effects of EMF on edible crab, Cancer pagarus. The impact of EMF on crustaceans is another issue worth considering due to the commercial and ecological importance of the edible crab and European lobster, Homarus gammarus, and the recent advance in scientific research on this subject. 3.0 General comments and requests The provision of GI shapefiles for the proposed cable corridor would be extremely helpful in identifying the location of proposed works in relation to designated features of MPAs that would be affected and in relation to Eastern IFCA’s proposed restricted areas in Haisborough, Hammond and Winterton SCI. It would also be useful to have more detailed timings of the proposed activities as there is often seasonal variation in the sensitivity of some habitat features and the importance of fisheries can vary throughout the year."
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of G Hales and Mrs P Riches
" IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 ?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. 4.2?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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5.?Construction and Funding 5.1 ?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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6.? Cumulative Impact 6.1 ?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. 7. ?Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8.? Field Drainage 8.1 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 but it is not satisfactory. 8.2?To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. ?Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10.?Flood Issues 10.1 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. 11.?Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. ?Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. ?Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14.?Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018.? IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH 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
" IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 ?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. 4.2?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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5.?Construction and Funding 5.1 ?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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6.? Cumulative Impact 6.1 ?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. 7. ?Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8.? Field Drainage 8.1 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 but it is not satisfactory. 8.2?To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. ?Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10.?Flood Issues 10.1 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. 11.?Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. ?Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. ?Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14.?Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018.? IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH WARWICKSHIRE CV8 2TZ REF? Louise Staples, MRICS, FAAV ?Rural Surveyor "
Other Statutory Consultees
Historic England
"Historic England (retaining the formal title of the Historic Buildings and Monuments Commission for England) is now the government service championing England’s heritage and giving expert, constructive advice. We summarise our representation regarding this proposed project as follows: 1. We appreciate that the Applicant has adopted a design-envelope approach in terms of assessment of different engineering designs by which this proposed project might be delivered. We understand that decisions are still to be made about offshore installation of infrastructure, such as the wind turbine generator foundation options and the seabed preparation that may be required. All such matters therefore regarding different design options need to consider the impact that they may have on the historic environment in line with National Policy Statement: Renewable Energy Infrastructure (EN-3). 2. In the vicinity of the proposed electricity export cable landfall location (near Happisburgh, Norfolk) there are identifiable heritage assets of international significance. We welcome the attention given to these matters in the Environmental Statement (ES), it is therefore a directly relevant matter that all mitigation measures, as included in the outline archaeological Written Schemes of Investigations (WSIs), are secured through the draft Development Consent Order (DCO) to inform delivery of this project, should consent be obtained. 3. Likewise for the on-shore cable route from the landfall to the substation we note the outline WSI (onshore) and we wish to ensure that all necessary mitigation measures, are secured through the draft DCO and are agreed with the relevant local authority archaeological advisors to ensure delivery of this project, should consent be obtained. 4. The proposed archaeological mitigation strategy as set out in the outline archaeological WSI – offshore, should enable any subsequent programmes for survey data acquisition and analysis post-consent to be delivered in accordance with a revised archaeological WSI, as necessary to support delivery of the selected engineering design of the intended project. It is therefore a relevant matter that specific provisions within the draft deemed Marine Licence of the draft Development Consent Order must allow effective delivery of agreed archaeological mitigation programmes in line with published professional guidance for the archaeological sector. 5. 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. A key factor is how the accumulation of information derived from development-led archaeological assessments might increase knowledge and understanding. It is therefore a relevant matter that a core component of a viable mitigation strategy is the satisfactory completion of analysis programmes, within defined time periods, to accepted professional standards with publication and access through public archives. 6. We have previously raised concerns in relation to the impact of the substation on the significance of a number of designated heritage assets through development within their setting. We are pleased that a specific historic environment visualisations chapter has been produced (see ES Vol. 1 Chapter 29) to work alongside the Historic Environment Chapter of the ES. Using this additional material we confirm that there are limited views of these assets, however we will explore this issue further in our written representation. "
Members of the Public/Businesses
John Gills
"Why can someone involved in a company as big as this get their survey wrong, which now means an even bigger monstrosity being built on our doorstep. We've been told lies about this scrapyard and the size of it so how do we know we're not being lied to about other aspects of this plant. And does the new size of this plant mean more money to our parish."
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of L Padulli
" IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 ?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. 4.2?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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5.?Construction and Funding 5.1 ?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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6.? Cumulative Impact 6.1 ?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. 7. ?Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8.? Field Drainage 8.1 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 but it is not satisfactory. 8.2?To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. ?Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10.?Flood Issues 10.1 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. 11.?Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. ?Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. ?Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14.?Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018.? IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH WARWICKSHIRE CV8 2TZ REF? Louise Staples, MRICS, FAAV ?Rural Surveyor "
Other Statutory Consultees
response has attachments
Marine Management Organisation
"The Marine Management Organisation, as a key stakeholder, wishes to make a written representation. However due to the size of the document, it will be sent to the PINS case team separately via email. "
Other Statutory Consultees
Maritime and Coastguard Agency
"The MCA’s remit for Offshore Renewable Energy Installations (OREIs) is to ensure that the safety of navigation is preserved, and our search and Rescue capability is maintained, whilst progress is made towards government targets for renewable energy. Vattenfall has undertaken a detailed Navigation Risk Assessment (NRA) in accordance with MCA guidance (MGN 543 and its supporting annexes, and risk assessment methodology), and we are satisfied that all aspects of the NRA have been adequately addressed, including the traffic surveys. However, there are still aspects of the project that will need to be discussed beyond consent, and concerns which will need to be addressed and agreed with MCA, as follows: Layout Design The turbine layout design will require MCA approval prior to construction to minimise the risks to surface vessels, including rescue boats, and search and rescue aircraft operating within the site. As such, MCA will seek to ensure all structures are aligned in straight rows and columns with a minimum of two lines of orientation. We are concerned about the scale of the development in combination with multiple windfarms in the Southern North Sea (East Anglia Three, Norfolk Vanguard East and West and Norfolk Boreas), and the turbine layout and orientation must be discussed and agreed with MCA at the earliest opportunity. We are pleased to hear that continued dialogue is in place with the developers of East Anglia Three. We note that the NRA considers ‘worst case scenario’ with just one line of orientation, however MCA’s preference is for at least two for the purposes of safe navigation for surface vessels, and search and rescue capabilities. We will also require turbines to be in straight lines but understand that micro-siting is likely necessary. The next step is commitment to an agreed set of design principles, which should be included or referred to as part of the DCO. Deep Water Routes An assessment of the DWRs relative to Norfolk Vanguard is presented in section 17, most notably the DR1 LightBuoy Deep Water Route (DWR), and the West Friesland DWR. We are content that the corridor is compliant with the MCA requirements. Transboundary issues have been considered, and the Dutch authorities and relevant Dutch stakeholders have been consulted. Marking and Lighting MCA will seek to ensure the turbine numbering system follows a ‘spreadsheet’ principle and is consistent with other windfarms in the area. All lighting and marking arrangements will need to be agreed with MCA and Trinity House. Emergency Response & Co-operation Plans A SAR checklist will need to be completed in agreement with MCA before construction starts. This will include the requirement for an approved Emergency Response Co-operation Plans (ERCOP). This will be included as a formal condition of the DCO. Construction scenarios We would expect to see some form of linear progression of the construction programme avoiding disparate construction sites across the development area, and the DCO needs to include the requirement for an agreed construction plan to be in place ahead of any works commencing. Mooring Arrangements: It is noted that floating wind turbines are being considered. Further details are required on the anchor and line spread, monitoring during construction and operation, recovery of turbines and Third Party Verification. Reference should be made to recent guidance on regulatory expectations developed by MCA and HSE. Hydrographic Surveys Section 28.5 Hydrographic Surveys states that “As required by MGN 543, detailed and accurate hydrographic surveys will be undertaken periodically at agreed intervals. The applicants are reminded that the final data supplied as a digital full density data set, and the report of survey, should be submitted to the MCA Hydrography Manager and the UK Hydrographic Office. This information is yet to be submitted and failure to report the survey or conduct it to Order 1a might invalidate the NRA if it was deemed not fit for purpose Cable Routes Export cable routes, cable burial protection index and cable protection are issues that are yet to be fully developed. However due cognisance needs to address cable burial or protection and any consented cable protection works must ensure existing and future safe navigation is not compromised. The MCA would accept a maximum of 5% reduction in surrounding depth referenced to Chart Datum. Safety Zones The requirement and use of safety zones as detailed in the application is noted and supported. Conclusion A Statement of Common Ground is yet to be agreed and we would like to see this progressed as soon as possible to address the above issues. "
Members of the Public/Businesses
Miss Sherrie Nobbs
"Development Consent for Norfolk Vanguard Offshore Wind Farm. I wish to register my opposition to the above development due to the positioning of Necton Vanguard and Boreas substations. 1. Congestion during the construction phase has not been considered. The A47 is the main route across the country and is naturally busy. The addition of the construction traffic will mean longer delays for local vehicles attempting to use it. This will have a detrimental impact on daily life and local businesses. As the project appears to have a construction phase of five years what measures will be taken to address this. 2. Positioning of the substations. The two proposed substations are sizeable industrial sites which are to be sited close to a residential area. 3. Operational impact. What visual, audible and electrical impact will the development have during the construction and operation? Little information has been given on this, as the type of substation was not even decided upon when the consultation process was operation. 4. Lack of clear planning and consultation. Informed decisions and understanding cannot be achieved unless all relevant information is provided. Project details have been neither precise nor forthcoming, suggesting there could be further developments planned."
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mr and Mrs M Jones
" IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 ?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. 4.2?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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5.?Construction and Funding 5.1 ?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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6.? Cumulative Impact 6.1 ?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. 7. ?Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8.? Field Drainage 8.1 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 but it is not satisfactory. 8.2?To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. ?Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10.?Flood Issues 10.1 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. 11.?Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. ?Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. ?Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14.?Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018.? IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH 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
" IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 ?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. 4.2?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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5.?Construction and Funding 5.1 ?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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6.? Cumulative Impact 6.1 ?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. 7. ?Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8.? Field Drainage 8.1 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 but it is not satisfactory. 8.2?To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. ?Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10.?Flood Issues 10.1 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. 11.?Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. ?Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. ?Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14.?Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018.? IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH WARWICKSHIRE CV8 2TZ REF? Louise Staples, MRICS, FAAV ?Rural Surveyor "
Non-Statutory Organisations
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of National Trust
" IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 ?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. 4.2?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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5.?Construction and Funding 5.1 ?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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6.? Cumulative Impact 6.1 ?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. 7. ?Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8.? Field Drainage 8.1 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 but it is not satisfactory. 8.2?To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. ?Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10.?Flood Issues 10.1 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. 11.?Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. ?Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. ?Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14.?Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018.? IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH WARWICKSHIRE CV8 2TZ REF? Louise Staples, MRICS, FAAV ?Rural Surveyor "
Other Statutory Consultees
Addleshaw Goddard LLP on behalf of Network Rail Infrastructure Limited
"APPLICATION BY NORFOLK VANGUARD LIMITED FOR AN ORDER GRANTING DEVELOPMENT CONSENT FOR THE NORFOLK VANGUARD OFFSHORE WINDFARM PLANNING INSPECTORATE REFERENCE: EN010079 SECTION 56 PLANNING ACT 2008: RELEVANT REPRESENTATION OF NETWORK RAIL INFRASTRUCTURE LIMITED This is the section 56 representation of Network Rail Infrastructure Limited (Network Rail) provided in respect of Norfolk Vanguard Limited's (NVL) application for a Development Consent Order (Order) which seeks powers to enable the construction of the Norfolk Vanguard 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 new rights (including restrictive covenants), access only" (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. "
Non-Statutory Organisations
response has attachments
NFU
"IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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
Orsted Wind Power A/S
"Orsted Wind Power A/S (Orsted) has received notification that the Norfolk Vanguard Offshore Wind Farm (Norfolk Vanguard) has been accepted for examination. Please accept this as Orsted’s representation that it has an interest in the Norfolk Vanguard application, and wishes to be treated as an interested party for the purposes of the examination process. Orsted is the promoter of the Hornsea Project Three Offshore Wind Farm (Hornsea Three). Hornsea Three’s application was submitted in May 2018, accepted for examination in June 2018 and the examination process will commence on 2nd October 2018. General and Project Need: In principle, Orsted supports Norfolk Vanguard 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: Offshore, whilst the siting of the offshore array, export cable route and the onshore connection points of the two projects differ, the Norfolk Vanguard cumulative impacts for some topics / receptors interact with Hornsea Three. Onshore, the export cable corridor for the projects will cross at land north east of Reepham, Norfolk. In addition, Hornsea Three understand that Norfolk Vanguard's sister project, Norfolk Boreas (which is due to submit a separate application for Development Consent in June 2019 [Source: Planning Inspectorates project page]), will follow the same onshore cable corridor and therefore also cross the Hornsea Three onshore cable corridor near Reepham. The onshore construction works for the projects also make use of land near Oulton Street, with Hornsea Three utilising the established hard standing area at Oulton Airfield to accommodate its main construction compound and Norfolk Vanguard utilising a cable logistics area on land to the south east of Oulton Airfield. Where the onshore cable route for the projects cross, or where there is potential for direct interaction in and around Oulton Street, Hornsea Project Three will continue to work with Noroflk Vanguard:- • To manage construction traffic impacts, Hornsea Three 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, Hornsea Three 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. Offshore, in general, Hornsea Three welcomes the findings of the cumulative and in-combination assessments as far as they relate to the Hornsea Three. Cumulative impacts between Norfolk Vanguard and Hornsea Three include:- • Fish and shellfish; • Marine mammals; • Offshore ornithology; • Commercial fisheries; • Aviation; and • Marine archaeology. Now that both projects have completed their Environmental Statements and have published their applications, Orsted is confident that any potential concerns with regard to cumulative and in-combination impacts can be readily addressed. To support this, Hornsea Three is in regular contact with Norfolk Vanguard’s promoters, Vattenfall, at all levels of the project and have sought, and will continue to seek, to liaise on environmental matters. Orsted reserves the right to make further representations throughout the forthcoming examination period."
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of P Mutimer
" IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 ?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. 4.2?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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5.?Construction and Funding 5.1 ?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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6.? Cumulative Impact 6.1 ?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. 7. ?Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8.? Field Drainage 8.1 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 but it is not satisfactory. 8.2?To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. ?Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10.?Flood Issues 10.1 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. 11.?Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. ?Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. ?Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14.?Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018.? IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH WARWICKSHIRE CV8 2TZ REF? Louise Staples, MRICS, FAAV ?Rural Surveyor "
Members of the Public/Businesses
Pat Bailey
"I object to this project for several reasons. 1) the cliffs at Happisburgh are extremely unstable. There appears to be no precedent for drilling under and through these sandy fragile cliffs. It is my concern that this may cause the cliffs to erode at a faster rate than they already are. 2) Happisburgh relies on it's tourists for income for local businesses i.e. shops, pub, cafes, lighthouse and holiday lets. If the project goes ahead, tourists will be driven away and the village may never recover. 3) Traffic flow will be disrupted by the running track crossing the village and the roads. This will not only be inconvenient for residents, and the parents of children attending the school at the centre of the village, but will be off putting to visiting tourists. Added pollution from HGV traffic is a health concern for residents. 4) The field between White Cottage and the cliffs, where the cables will be coming above ground, will be a permanent blot on the idyllic landscape, spoiling both the views of the village and the iconic lighthouse."
Non-Statutory Organisations
response has attachments
Royal Society for the Protection of Birds (RSPB) (Royal Society for the Protection of Birds (RSPB))
"RSPB Relevant Representation Regarding Norfolk Vanguard Offshore Windfarm 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. Although some progress was made during this process, the RSPB remains concerned that some methodological procedures used in the assessment are inadequate to ensure a robust assessment and therefore a proper understanding of the likely impacts of the scheme. 2. Offshore ornithology impacts We have significant concerns regarding the findings of some of the impact assessments. As a result of the methodological concerns (set out below) and our own recalculation of collision risk using the Marine Scotland stochastic model, the RSPB considers that the impacts have not been adequately assessed and, as such consider that an adverse effect on the integrity (AEOI) of the following SPAs/pSPAs and their species cannot be ruled out for the following ornithological interests: • The impact of collision mortality on the kittiwake population of the Flamborough Head and Bempton Cliffs SPA and the Flamborough and Filey Coast pSPA (FHBC SPA/FFC pSPA) alone and in-combination with other plans and projects; • The impact of collision mortality on the gannet population of the FHBC SPA/FFC pSPA alone and 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 alone and in-combination with other projects. We also consider that potential for likely significant effects on the following site exists, and that this site cannot be screened out from further assessment at this stage: • Bruine Bank pSPA (Netherlands) – displacement of razorbills and guillemots, particularly during migratory periods. In addition, we consider that insufficient evidence has been provided to rule out potential significant impacts on the following 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 auks (guillemot, razorbill and puffin) and red-throated diver. 3. Concerns regarding the assessment of collision risk Our major concerns regarding the assessment process and evidence base are outlined below. (a) Potential Biological Removal Potential Biological Removal (PBR) is used in justification of conclusions of no AEOI for both gannet and kittiwake. The RSPB disagree with the use of PBR in this context following the publication of the review by O’Brien et al. (2017) and the RSPB Practitioner’s Perspective (Green et al., 2016), and therefore support NE’s position that PBR does not provide an appropriate threshold for this purpose (as outlined in the Secretary of State’s HRA for the Hornsea Project 2 offshore windfarm). PBR was designed to manage whaling quotas by detecting unsustainable mortality in a population leading to risk of its extinction, whereas SPAs are set up to maintain or restore a population of conservation importance. Levels of acceptable mortality derived from PBR are therefore likely to be higher than those acceptable for a population to continue to meet the conservation objectives of a SPA. Where population modelling is required to inform an assessment, this should be based on Population Viability Analysis (PVA). PVA enables comparison of the change in population size with and without the project after several years, thereby presenting an indication of the magnitude of change attributable to the proposal and is therefore more suitable for assessing the effects of a project on a SPA. (b) Stochastic Collision Risk Model (CRM) In order to predict the collision risk mortality of an offshore wind farm in the UK, the Band (2012) model has previously been used in assessment. This model uses a number of input parameters, such as bird size, flight speed and turbine blade dimensions, to calculate the probability of a bird that passes through the swept area of a turbine blade colliding with that blade. For this deterministic model the input parameters were defined as single values with no indication of variability around them. In reality, most of the parameters will exhibit a considerable degree of variability and stochastic collision risk modelling has been developed to allow this to be incorporated into the model and thus generate a potential range of output predicted collision mortalities. MacGregor et al., (2018), under commission of Marine Scotland Science and overseen by an expert steering panel, produced a revised and fully tested stochastic model to widespread stakeholder acceptance. By contrast, the Applicant has presented an entirely untested new version that does not follow a recognised methodology, with insufficient detail provided as to how it incorporates variability or how it overcomes the statistical difficulties of non-independence (the degree of interrelation) of some of the variables. The RSPB therefore does not agree that the model presented by the Applicant is fit for purpose and recommend that the Marine Scotland (MacGregor et al., 2018) model version is used in preference. (c) Use of median bird densities within the CRM The Applicant has presented deterministic and stochastic versions of the CRM (see above). For the deterministic version (Band 2012) of the CRM the correct value to use for bird density is the mean monthly value. As detailed in Environmental Statement Appendix 13.1 Ornithology Technical Appendix Annex 3 [APP-217], the values used by the applicant appear to be median values, which will result in the model predicting considerably lower collision mortalities. (d) Nocturnal Activity Factor We do not agree with the changes in Nocturnal Activity Factor (a parameter used in collision risk modelling) proposed. The value presented for kittiwake is based on unpublished evidence which does not appear to form part of the examination documentation and therefore we are unable to assess the robustness of the study. The current factor is derived from the expert opinion collected by Garthe and Huppop (2004) and this use is endorsed by Band (2012). A review of seabird vulnerability to offshore wind farms (Furness et al., 2013) recommended that no changes be made to the nocturnal activity scores for these species, and an update, including the same authors (Wade et al., 2016) maintained this recommendation. It is also not clear how these revised rates account for the distinction between the definition of daylight as used in the Band model and with the official concept of ‘twilight’ and ‘night’. This is an issue as the Band (2012) model considers the nocturnal period as between sunset to sunrise and so treats flight activity that occurs at twilight as being within the nocturnal flight period. Evidence from tagging shows that an important number of seabirds actively forage at twilight. While we welcome the latest published evidence review for gannet (Furness et al., 2018), we are concerned that the mortalities predicted using revised nocturnal activity rates for gannet (and this is also applicable to kittiwake) are potentially underestimated because they do not account for the potential interaction between survey timing and diurnal behavioural patterns. Peaks in foraging activity at first and last light (see for example Fig. 3 in Furness et al. 2018) will not be accounted for in the assessment if these did not coincide with surveys (the timings of which are currently unknown, but likely to be midday if aerial), and the survey may have been carried out at a time of much lower activity. Thereby the application of the revised nocturnal activity factor recommended by Furness et al., (2018) could result in inaccurate underestimates of collision risk. The Nocturnal Activity Score presented for gannet in the application documents is also not in accordance with this latest review (Furness et al., 2018) which recommends 8% in the breeding season and 3% in the non-breeding season. The values used in the assessment, 4.3% and 2.3% respectively, will result in a prediction of fewer collisions. (e) Underestimation of collision mortality Based on a comparison with our own calculations using the MacGregor et al., (2018) model version with a range of nocturnal activity rates, the Applicant’s model underestimates collision mortality for key species, and it produces significantly reduced predictions compared to the deterministic model, particularly when the deterministic model is also re-run using mean (rather than median) monthly bird densities. (f) Breeding season definitions We have concerns about the manner in which biological seasons for gannet and kittiwake have been defined by Vattenfall’s consultants. The use of the ‘migration-free breeding season’ means that months where breeding and migration can overlap are excluded from the analysis of breeding season impacts, artificially reducing the duration of the breeding season and hence risks underestimating collision mortality of breeding birds. The definition of ‘breeding season’ as presented in Furness (2015), should therefore be used, except where colony specific evidence clearly suggests otherwise. (g) Apportioning of mortality to SPAs We have concerns about some of the figures used for apportioning of collision mortality to SPAs and the evidence used to support this. The estimated proportion of kittiwake from FHBC SPA/FFC pSPA used in the HRA is 16.5% and is based on no site-specific historical estimates. Notwithstanding the applicants unfounded criticisms of the FAME and STAR tracking of kittiwakes, which is dealt with below, the assessment does not take into account more recent tracking of kittiwakes from FHBC SPA/FFC pSPA carried out in 2017, using lighter tags (<3% bodyweight) and following the birds for a longer period due to a novel attachment method, that showed a high degree of overlap of colony breeding birds with the development site. We therefore do not agree with the value used for apportioning kittiwake collision mortalities to the FHBC SPA/FFC pSPA as it will considerably underestimate the actual impact. We are concerned that the methods used for apportioning collision mortality of lesser black-backed gulls to the Alde-Ore Estuary SPA are inadequately explained, with insufficient reference to current knowledge and with a cavalier attitude toward precaution. Such calculation is difficult because of two competing factors. Throughout the UK, the urban population of lesser black-backed gulls is increasing, while those in “natural” colonies is decreasing (JNCC, 2018). In simplistic terms this could be argued as reducing the impact apportioned to the SPA. In the Applicant’s calculations of the number breeding birds within foraging range of the developments a number of inland, urban colonies are included, such as Ipswich and Norwich as likely sources of birds foraging in the development areas. While we acknowledge that there is a need for more research on the foraging behaviour of urban gulls, it is unlikely that such gulls, especially those from non-coastal urban colonies will forage in the offshore marine environment to the same extent as those breeding at coastal “natural” colonies, such as the Alde-Ore Estuary SPA. The inclusion of birds from such sites dilutes the potential significance of impact on the Alde-Ore Estuary SPA. Furthermore in calculating the number of non-SPA birds the Applicant gives a rounded up figure of 5400 birds, then simply doubles it (and rounds up further) to 11000, with scant justification other than saying 5400 was a likely underestimate, but presenting no supporting evidence. By overstating the non-SPA population in this way, the potential impact on the Alde-Ore Estuary SPA is again significantly understated. We therefore do not agree that these calculations provide confidence to support a conclusion of no adverse effects on integrity of the population of lesser black-backed gull from the Alde-Ore Estuary SPA and consider that a full assessment, including PVA should be carried out. (h) Gannet avoidance rate Whilst the RSPB accepts the SNCB’s 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. In light of evidence from Cleasby et al., (2015), which demonstrated that foraging birds flew higher, and were therefore at greater risk of collision, than commuting birds, and given that the BTO avoidance rate review was heavily biased to non-breeding gannets, we prefer a more precautionary AR of 98% for the breeding season. (i) 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 and STAR 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 2.5 % of the birds’ body weight and observed longer foraging ranges with multiple actively breeding birds visiting the Norfolk Vanguard site. • The applicant repeatedly asserts that the RSPB data are not available. This is simply not true, they are available upon formal request, and the consultants who authored this section have had data made available to them under such a request. (j) Potential for mitigation of impacts on the Alde-Ore Estuary SPA The RSPB are concerned at the Applicant’s interest in mitigating impacts on lesser black-backed gull through predator management at the Alde-Ore Estuary SPA. Mitigation measures need to counter or at least lessen effects arising from the development proposals and must be over and above required management measures for the SPA. Due to the uncertainty around the relative importance of the various factors affecting this population, and therefore the likely effectiveness of the proposed management measures on productivity as well as no evidence that they will be over and above required management for the site, we do not agree that measures of this sort should be considered as mitigation for SPA impacts. (k) Screening out of Bruine Bank pSPA The Bruine Bank pSPA in Dutch waters is approximately 20km from Norfolk Vanguard at the closest point and is of importance for wintering razorbill and guillemot. Although the site was screened, we do not consider that sufficient evidence has been provided to screen this pSPA out from further assessment, particularly in relation to displacement of birds during the migration period. 4. Note 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. The RSPB August 2018 References Band, W. (2012) Using a collision risk model to assess bird collision risks for offshore windfarms. SOSS02 Project Report to The Crown Estate. Cleasby, IR, Wakefield, ED, Bearhop, S, Bodey, T W, Votier, SC and Hamer, KC (2015), Three-dimensional tracking of a wide-ranging marine predator: flight heights and vulnerability to offshore wind farms. J Appl Ecol, 52: 1474–1482. [redacted] Furness, RW (2015) Non-breeding season populations of seabirds in UK waters: Population sizes for Biologically Defined Minimum Population Scales (BDMPS). Natural England Commissioned Reports, Number 164 [redacted] Furness, R, Wade, H & Masden, E (2013). Assessing vulnerability of seabird populations to offshore wind farms. Journal of environmental management. 119C. 56-66. 10.1016/j.jenvman.2013.01.025. Furness, R, Garthe, S, Trinder, M, Matthiopoulos, J, Wanless, S, Jeglinski, J (2018) Nocturnal flight activity of northern gannets Morus bassanus and implications for modelling collision risk at offshore wind farms, Environmental Impact Assessment Review, 73,1-6, [redacted] Garthe, S. & Hüppop, O. (2004) Scaling possible adverse effects of marine wind farms on seabirds: developing and applying a vulnerability index. Journal of Applied Ecology 41: 724-734. Green, R. E., Langston, R. H. W., McCluskie, A., Sutherland, R. and Wilson, J. D. (2016), Lack of sound science in assessing wind farm impacts on seabirds. J Appl Ecol. doi:10.1111/1365-2664.12731 Marine Scotland. (2018) A Stochastic Collision Risk Model for Seabirds in Flight. Marine Scotland Topic Sheet, 2pp. DOI: 10.7489/12101-1 JNCC (2018) Latest population trends: lesser black-backed gull. [redacted] O'Brien, S. H., Cook, A. S., & Robinson, R. A. (2017). Implicit assumptions underlying simple harvest models of marine bird populations can mislead environmental management decisions. Journal of environmental management, 201, 163-171. Wade, H, Masden, E, Jackson, A.C. & Furness, R. (2016). Incorporating data uncertainty when estimating potential vulnerability of Scottish seabirds to marine renewable energy developments. Marine Policy. 70. 108-113. 10.1016/j.marpol.2016.04.045. "
Members of the Public/Businesses
Sarah Rodgers
"I am a resident of the village of Holme Hale which lies close to the proposed site for the Norfolk Vanguard offshore windfarm development. I have attended public meetings and am totally dissatisfied by the outcome of consultations. The proposed siting of the substation is not the best choice which was available to Vattenfall. It is at a relative highpoint in the landscape which will make it far more visible from a far greater distance. The proposal to make the technology DC will mean it has to be built to a greater height which will again intrude into the landscape. Statutory limits on noise pollution will mean that it is likely to have to be encased creating a further unsightly eyesore on a traditional rural landscape. There is already light pollution from the Dudgeon sub-station and representations by Vattenfall on bunding to counter this are totally inadequate. The site has a high level of toxicity as a result of being a plane-crash site. There are important archaeological features on the site. Concentrating substations together in one location creates a highly targettable site in the event of hostilities. In summary, it will intrude unacceptably on the landscape, destroy important archaeological features, be a health hazard and a security risk. I would urge planners to take a longer term view and recommend that other sites be given proper consideration so that the negative impact of such a concentration of infrastructure is sensibly neutralised."
Members of the Public/Businesses
response has attachments
Bidwells on behalf of Sir Edward Evans-Lombe
"As presently planned, the Orsted cable line will run about 55kms to the Swardeston National Grid receiving station and The Vattenfall Line will run about 60km to the Necton receiving station. These lines will actually cross each other at Salle. Vattenfall have ‘booked’ their Necton destination with the National Grid. These arrangements appear to run contrary to common sense because Orsted’s landing point is much closer to Necton than Vattenfall’s and Vattenfall’s landing point is much closer to Swardeston than Orsted’s. It is calculated that, if Orsted and Vattenfall swapped destinations, 22kms of cable would be saved. If both lines came ashore close to each other east of Cromer and then ran together to the closest National Grid receiving station, possibly Swardeston, or a new receiving station at or near North Walsham, up to 80km of cable line would be saved. These savings of line would lead to substantial savings of installation cost and public amenity. If the “East of Cromer Solution” was adopted, these savings would be massive. Further, it appears it might be possible for Orsted to connect with The National Grid at Walpole to the west of Kings Lynn where loss of amenity would be minimal. The making of a Development Consent Order as proposed should be made conditional on Vatenfall agreeing to give up it’s “booking” of Necton, thus making it available to Orsted. The Applicants should be required to investigate the East of Cromer Solution and the Walpole Solution and report to the Planning Authority. "
Members of the Public/Businesses
Brown and Co on behalf of Stephen Peter Evan Garrett and Penelope Anne Yvonne Garrett
"One of the proposed routes of the cable immediately adjacent to Wood Farm presents severe implications, and is in contradiction of publicised policy for defining the route, the key policy principles being; 1. ‘INSTALL CABLES WITHIN OPEN AGRICULTURAL LAND WHERE POSSIBLE’. There are many options for routing the cable through open agricultural land, away from residential property. Prior to 27th April 2018, Vattenfall were undertaking public consultation on a route across open agricultural land to the south. 2. ‘AVOID RENDERING PARCELS OF AGRICULTURAL LAND INACCESSIBLE DURING CONSTRUCTION’ During laying of the cable, along the entire project length, there are many instances where fields are crossed by the cable. As a result, Vattenfall are employing mitigation works so that farmers can access all of their land and continue to farm after the scheme. Such mitigation works and compensatory provisions can be made to farmers, in a simple manner, and there is no reason why this can’t be applied to the southern option, rather than passing Wood Farm. 3. AVOID AREAS OF IMPORTANT HABITAT, TREES, PONDS AND AGRICULTURAL DITCHES Upon the boundary of Wood Farm, and within very close proximity either side, there are conifer trees, mature trees, mature hedging, a ditch, ancient oak trees, ancient orchard, all with established habitats. During the construction works and following the scheme, these ecological features will be destroyed. NB Vattenfall environmental surveyors have not visited the site to assess these valuable habitats, or prepared reports at the time of DCO submission. 4. MINIMISE IMPACTS ON AGRICULTURAL PRACTICES AND ACCESS By simply applying mitigation works and compensation, there will be no impacts on agricultural practices or shooting if the route crosses open land to the south. 5. REDUCE PROXIMITY TO RESIDENTIAL DWELLINGS The ‘key principle’ of avoiding residential property would not be met if the cable is positioned next to Wood Farm. The implications; • The property is served by a water borehole and septic tank; operation, contamination changes to the water table are concerns. • The property is clay lump construction, without foundations. Vibrations, soil swell, and other ground disturbance caused by the engineering works, could result in weakness in the construction of the house, in years to come, affecting property value. • The only access to the property is via Googles Lane running to a private track along which Mr and Mrs Garrett have a legal right to and from Wood Farm, and underwhich the proposed cable will run. During construction (not only the width of the cable, but also by consequence of the cable route along this longer section being used as a ‘runway’), access will be prevented. It is critical that access is not interrupted, in any way, for business, domestic and emergency purposes; business purposes, for the training and breeding of dogs. The works will severely unsettle the dogs, particularly during pregnancy. 6. MINIMISE IMPACTS TO LOCAL RESIDENTS IN RELATION TO ACCESS TO SERVICES AND ROAD USAGE, INCLUDING FOOTPATH CLOSURES Access issues pertaining to Wood Farm House as above, apply under this ‘key principle’. "
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of T Love
" IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 ?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. 4.2?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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5.?Construction and Funding 5.1 ?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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6.? Cumulative Impact 6.1 ?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. 7. ?Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8.? Field Drainage 8.1 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 but it is not satisfactory. 8.2?To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. ?Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10.?Flood Issues 10.1 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. 11.?Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. ?Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. ?Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14.?Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018.? IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH WARWICKSHIRE CV8 2TZ REF? Louise Staples, MRICS, FAAV ?Rural Surveyor "
Members of the Public/Businesses
The National Trust
"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 preservation 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 Vanguard 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 two key outstanding concerns, and therefore objects 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 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. No formal agreement has been reached with Vattenfall as to how the Trust, County Planning Archaeologist and developer might work together to achieve a suitable and appropriate methodology for the archaeological work to be undertaken on the Estate prior to any development. 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 schedule of mitigation (Impact to Archaeology) refers to the “Implementation of a temporary suspension of intrusive groundworks in any area where previously unknown remains are encountered until remains have undergone appropriate archaeological investigation. In the event of a discovery, archaeological requirements and necessary ‘next steps’ will be agreed in consultation with NCC HES and HE”. The Trust should be added to the consultees on any ‘necessary next steps’, any proposed mitigation and on the Written Scheme of Investigation referred to in requirement 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. Acquisition of Land Whilst Vattenfall have said that the Trust’s interests are excluded from compulsory acquisition under the draft DCO, the documentation does not make that clear. The book of reference should be amended or an appropriate undertaking given. "
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Trustees of Salle Park Trust being Sir David Chapman, Grant Pilcher, Michael Dewing and William Edwards
" IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 ?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. 4.2?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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5.?Construction and Funding 5.1 ?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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6.? Cumulative Impact 6.1 ?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. 7. ?Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8.? Field Drainage 8.1 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 but it is not satisfactory. 8.2?To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. ?Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10.?Flood Issues 10.1 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. 11.?Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. ?Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. ?Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14.?Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018.? IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH 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
"IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 ?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. 4.2?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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5.?Construction and Funding 5.1 ?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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6.? Cumulative Impact 6.1 ?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. 7. ?Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8.? Field Drainage 8.1 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 but it is not satisfactory. 8.2?To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. ?Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10.?Flood Issues 10.1 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. 11.?Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. ?Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. ?Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14.?Request to Attend Hearings and make Representations 14.1 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. 14.2 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 14th September 2018.? IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH WARWICKSHIRE CV8 2TZ REF? Louise Staples, MRICS, FAAV ?Rural Surveyor "
Members of the Public/Businesses
Alan Gibson
"The adverse effect if granted this planning application will have on the local amenity."
Members of the Public/Businesses
Corbett Farming Company
"I am raising these points below on behalf of Corbett Farming Company. The reasons I object are: 1. The need for two new substations so far inland from Vattenfall's Wind Farm is unnecessary 2. Vattenfall’s Public Consultation was flawed 3. The proposal will cause unrecoverable damage to the environment  4. Impact the livelihoods and wellbeing of Farmers 1. Why two new substations so far inland from Vattenfall's Wind Farm is unnecessary? Alternative Solutions - A marine cable connection around the coast into Walpole would prevent the cable route coming 47km across the Norfolk countryside, and eliminating the need for new substations or any expansions. This would result in other wind farms having the ability to connect to it if required. - A connection could be made on any suitable pylon on the 400KV overhead existing cable lines, which would reduce the distance the cable would have to come inland and provide a larger search area for a suitable site away from houses or villages. 2. Flawed public consultation - Vattenfall have not consulted with me over their requirement to access the overhead pylon on my land, yet they have printed in all their documentation the need to do so - No alternative sites were consulted on - Insufficient information on the National Grid extensions - Incorrectly stating no other suitable connection sites were possible - Allowing comments on 4 footprint options which were in different locations but all within the same field to an invitation only audience. - Inaccurate exaggerations of distance to nearest properties 3. Unrecoverable damage to the environment - Soil damage in the wide cable route areas - Destruction of fully established trees and hedges - It would force wildlife out of their habitats Alternative solutions would reduce the environmental impacts 4.Why would the proposal impact the livelihoods and wellbeing of Farmers? Farmers rely on the land they rent or own to make their business profitable and make their living, it is not equitable that Vattenfall should benefit at the expense of hundreds of others Businesses and theirs hundreds of stakeholders. Listed below are the specific impacts that this project will cause to a large amount of farmers: -Loss of food production - Land drains will have to be cut to lay the cables, leading to flooding in areas in and around the cable corridor - Cables heating up the soil impacting on any future crop production - Junction bays have to be installed resulting in further loss of croppable land  - The cable corridor will prevent access to fields and segregate certain areas of fields leading to crop loss - All in all, it will cause years of unnecessary mental and financial suffering to farmers and landowners "
Members of the Public/Businesses
David Vear
"This development is not in keeping with the local area and will ruin the landscape and views. The existing substation can be seen from our hall window. The new substation will have HDVC meaning parts will be over 80 foot tall because the power will have to be converted back to HVAC for connection to the grid, and so giant converter halls will be constructed. Vattenfall have admitted that trees will never hide these buildings. The new development will have an effect on the local environment and concerns have been raised about bat species in the Necton area. We have major concerns about the detrimental effect any new development will have on house prices. The existing substation can be seen from our hall window. We had problems with noise and light pollution during construction of the existing Dudgeon and continue to have issues with light pollution especially during the autumn/winter months. We are concerned that we will have similar problems should the new development go ahead. Our MP has expressed the view that the consultation process was flawed. Finally - why lay hundreds of miles of cables across the Norfolk countryside? Surely it makes sense to position the substation closer to the coast where the cables make landfall from the wind farms."
Members of the Public/Businesses
Helen Standley
"I believe that Happisburgh will be affected long term by the Vanguard & Boreas projects, and that the damage done to the village will never recover. The erosion of our cliffs has been enormous over the last 50 years and is not slowing down. Drilling underneath these cliffs is not going to be wise, there have been several cliff falls in the last year and metres of cliff are regularly disappearing. Other issues include noise, potential flooding, archaeology, wildlife on and offshore, pollution for residents, loss of income. Air quality in North Norfolk is generally good, but if this project is passed this will no longer be the case with the amount of HGV and traffic passing through all of our narrow lanes. So many of our cottages and houses are built right on the roadside, we just cannot cope with this level of traffic. Happisburgh has been chosen as landfall because we have no protection on this tiny part of coastline, we are a small vulnerable Norfolk village versus a Swedish Govt company. Traffic in the area will be unbearable, including HGV vehicles 24 / 7. Residents of the village will not be able to get from one end to the other, and all footpaths will be closed. Tourists will stop coming, because our tranquil peaceful village will no longer be the attraction it is now. Happisburgh Lighthouse is the only privately owned working lighthouse in the UK and brings many tourists to the village. It is open to the public and monies raised goes to the upkeep of the lighthouse. Archaeological finds, including 'The Happisburgh Handaxe' and the Happisburgh footprints, both evidence of early Paleolithic activity here. A Parish owned car-park which is self funding and raises money for the village, RNLI lifeboat station and souvenir shop, historic pub with separate coffee House and carvery, village shop, fish shop and cafe are all part of a thriving community who welcome tourists, year round, whilst staying a quiet, beautiful place for its residents to live. If Vattenfall are allowed to go ahead with this project, it will be the end of village life for Happisburgh."
Members of the Public/Businesses
James Sheringham
"I am writing as a Parish Councillor for Fransham, and as a local resident and Farmer. Necton has recently seen two substations built adjacent to Necton village and visible from 3 further villages. The cable corridor ran through my farm so I have first hand experience of the affects and damage caused. I strongly object to this planning application for the reasons outlined below. 1. The proposed sites for the two new substations are completely unsuitable 2. The need for two new substations so far inland from Vattenfall's Wind Farm is unnecessary 3. Vattenfall’s Public Consultation was flawed 4. The proposal will cause unrecoverable damage to the environment  1. Proposed Sites are Unsuitable - They are very near villages such as Necton, Ivy Todd, Fransham, Holme Hale and Bradenham causing distress and sadness with their inhabitants - They will extend an already very visible large structure on top of a hill adding to the visual pollution and light pollution at night - The sites have a high potential in exceeding the governed noise enforcements imposed in the area  Adds further infrastructure to the same area - The sites have very poor access on the brow of a hill with blind summits either direction on the A47, the location of which has already caused a number of road incidents. Other possible access points would bring unnecessary traffic through Fransham increasing pollution and risk to the inhabitants. - Not complying with Breckland Planning: Vattenfall state the development is too massive to be screened from view, and does not fit into the rural landscape. (PEIR ref: Chapter 29 - Table 29.18) Vattenfall admit it will not comply with the Breckland Local Plan which states: “Development…should be of a scale and design that respects the character and rural setting of the settlement.” And “All design proposals must conserve or enhance the existing character of an area.” 2. Why two new substations so far inland from Vattenfall's Wind Farm is unnecessary? Alternative Solutions - A marine cable connection around the coast into Walpole would prevent the cable route coming 47km across the Norfolk countryside, and eliminating the need for new substations or any expansions. This would result in other wind farms having the ability to connect to it if required. - A connection could be made on any suitable pylon on the 400KV overhead existing cable lines, which would reduce the distance the cable would have to come inland and provide a larger search area for a suitable site away from houses or villages. 3. Flawed public consultation - No alternative sites were consulted on - Insufficient information on the National Grid extensions - Incorrectly stating no other suitable connection sites were possible - Allowing comments on 4 footprint options which were in different locations but all within the same field to an invitation only audience. - Inaccurate exaggerations of distance to nearest properties 4. Unrecoverable damage to the environment - Soil damage in the wide cable route areas - Destruction of fully established trees and hedges - It would force wildlife out of their habitats - Alternative solutions would reduce the environmental impacts "
Members of the Public/Businesses
Julianne
"I am a local resident and object to this planning application for the reasons outlined below. 1. The proposed sites for the two new substations are completely unsuitable 2. The need for two new substations so far inland from Vattenfall's Wind Farm is unnecessary 3. Vattenfall’s Public Consultation was flawed 4. The proposal will cause unrecoverable damage to the environment  1.Proposed Sites are Unsuitable - They are very near villages such as Necton, Ivy Todd, Fransham, Holme Hale and Bradenham causing distress and sadness with their inhabitants - They will extend an already very visible large structure on top of a hill adding to the visual pollution and light pollution at night - The sites have a high potential in exceeding the governed noise enforcements imposed in the area  Adds further infrastructure to the same area - The sites have very poor access on the brow of a hill with blind summits either direction on the A47, the location of which has already caused a number of road incidents. Other possible access points would bring unnecessary traffic through Fransham increasing pollution and risk to the inhabitants. - Not complying with Breckland Planning: Vattenfall state the development is too massive to be screened from view, and does not fit into the rural landscape. (PEIR ref: Chapter 29 - Table 29.18) Vattenfall admit it will not comply with the Breckland Local Plan which states: “Development…should be of a scale and design that respects the character and rural setting of the settlement.” And “All design proposals must conserve or enhance the existing character of an area.” 2.Why two new substations so far inland from Vattenfall's Wind Farm is unnecessary? Alternative Solutions - A marine cable connection around the coast into Walpole would prevent the cable route coming 47km across the Norfolk countryside, and eliminating the need for new substations or any expansions. This would result in other wind farms having the ability to connect to it if required. - A connection could be made on any suitable pylon on the 400KV overhead existing cable lines, which would reduce the distance the cable would have to come inland and provide a larger search area for a suitable site away from houses or villages. 3.Flawed public consultation - No alternative sites were consulted on - Insufficient information on the National Grid extensions - Incorrectly stating no other suitable connection sites were possible - Allowing comments on 4 footprint options which were in different locations but all within the same field to an invitation only audience. - Inaccurate exaggerations of distance to nearest properties 4.Unrecoverable damage to the environment - Soil damage in the wide cable route areas - Destruction of fully established trees and hedges - It would force wildlife out of their habitats - Alternative solutions would reduce the environmental impacts "
Members of the Public/Businesses
Kate Sheringham
"I strongly object to this planning application for the reasons outlined below. 1. The proposed sites for the two new substations are completely unsuitable 2. The need for two new substations so far inland from Vattenfall's Wind Farm is unnecessary 3. Vattenfall’s Public Consultation was flawed 4. The proposal will cause unrecoverable damage to the environment  Proposed Sites are Unsuitable - They are very near villages such as Necton, Ivy Todd, Fransham, Holme Hale and Bradenham causing distress and sadness with their inhabitants - They will extend an already very visible large structure on top of a hill adding to the visual pollution and light pollution at night - The sites have a high potential in exceeding the governed noise enforcements imposed in the area  Adds further infrastructure to the same area - The sites have very poor access on the brow of a hill with blind summits either direction on the A47, the location of which has already caused a number of road incidents. Other possible access points would bring unnecessary traffic through Fransham increasing pollution and risk to the inhabitants. - Not complying with Breckland Planning: Vattenfall state the development is too massive to be screened from view, and does not fit into the rural landscape. (PEIR ref: Chapter 29 - Table 29.18) Vattenfall admit it will not comply with the Breckland Local Plan which states: “Development…should be of a scale and design that respects the character and rural setting of the settlement.” And “All design proposals must conserve or enhance the existing character of an area.” Why two new substations so far inland from Vattenfall's Wind Farm is unnecessary? Alternative Solutions - A marine cable connection around the coast into Walpole would prevent the cable route coming 47km across the Norfolk countryside, and eliminating the need for new substations or any expansions. This would result in other wind farms having the ability to connect to it if required. - A connection could be made on any suitable pylon on the 400KV overhead existing cable lines, which would reduce the distance the cable would have to come inland and provide a larger search area for a suitable site away from houses or villages. Flawed public consultation - No alternative sites were consulted on - Insufficient information on the National Grid extensions - Incorrectly stating no other suitable connection sites were possible - Allowing comments on 4 footprint options which were in different locations but all within the same field to an invitation only audience. - Inaccurate exaggerations of distance to nearest properties Unrecoverable damage to the environment - Soil damage in the wide cable route areas - Destruction of fully established trees and hedges - It would force wildlife out of their habitats - Alternative solutions would reduce the environmental impacts "
Members of the Public/Businesses
Lucy Sheringham
"I am raising these points below as a local resident. I object to this planning application for the reasons outlined below. Flawed public consultation - No alternative sites were consulted on - Insufficient information on the National Grid extensions - Incorrectly stating no other suitable connection sites were possible -Allowing comments on 4 footprint options which were in different locations but all within the same field to an invitation only audience. Proposed Sites are Unsuitable - They are very near villages such as Necton, Ivy Todd, Fransham, Holme Hale and Bradenham causing distress and sadness with their inhabitants - They will extend an already very visible large structure on top of a hill adding to the visual pollution and light pollution at night - The sites have a high potential in exceeding the governed noise enforcements imposed in the area  Adds further infrastructure to the same area - The sites have very poor access on the brow of a hill with blind summits either direction on the A47, the location of which has already caused a number of road incidents. Other possible access points would bring unnecessary traffic through Fransham increasing pollution and risk to the inhabitants. - Not complying with Breckland Planning: Vattenfall state the development is too massive to be screened from view, and does not fit into the rural landscape. (PEIR ref: Chapter 29 - Table 29.18) Vattenfall admit it will not comply with the Breckland Local Plan which states: “Development…should be of a scale and design that respects the character and rural setting of the settlement.” And “All design proposals must conserve or enhance the existing character of an area.” Alternative Solutions - A marine cable connection around the coast into Walpole would prevent the cable route coming 47km across the Norfolk countryside, and eliminating the need for new substations or any expansions. This would result in other wind farms having the ability to connect to it if required. - A connection could be made on any suitable pylon on the 400KV overhead existing cable lines, which would reduce the distance the cable would have to come inland and provide a larger search area for a suitable site away from houses or villages. Unrecoverable damage to the environment - Soil damage in the wide cable route areas - Destruction of fully established trees and hedges - It would force wildlife out of their habitats - Alternative solutions would reduce the environmental impacts "
Members of the Public/Businesses
Lynn Sheringham
"I am raising these points below as a local resident. I strongly object to this planning application for the reasons outlined below. 1. The proposed sites for the two new substations are completely unsuitable 2. The need for two new substations so far inland from Vattenfall's Wind Farm is unnecessary 3. Vattenfall’s Public Consultation was flawed 4. The proposal will cause unrecoverable damage to the environment  1. Proposed Sites are Unsuitable - They are very near villages such as Necton, Ivy Todd, Fransham, Holme Hale and Bradenham causing distress and sadness with their inhabitants - They will extend an already very visible large structure on top of a hill adding to the visual pollution and light pollution at night - The sites have a high potential in exceeding the governed noise enforcements imposed in the area  Adds further infrastructure to the same area - The sites have very poor access on the brow of a hill with blind summits either direction on the A47, the location of which has already caused a number of road incidents. Other possible access points would bring unnecessary traffic through Fransham increasing pollution and risk to the inhabitants. - Not complying with Breckland Planning: Vattenfall state the development is too massive to be screened from view, and does not fit into the rural landscape. (PEIR ref: Chapter 29 - Table 29.18) Vattenfall admit it will not comply with the Breckland Local Plan which states: “Development…should be of a scale and design that respects the character and rural setting of the settlement.” And “All design proposals must conserve or enhance the existing character of an area.” 2. Why two new substations so far inland from Vattenfall's Wind Farm is unnecessary? Alternative Solutions - A marine cable connection around the coast into Walpole would prevent the cable route coming 47km across the Norfolk countryside, and eliminating the need for new substations or any expansions. This would result in other wind farms having the ability to connect to it if required. - A connection could be made on any suitable pylon on the 400KV overhead existing cable lines, which would reduce the distance the cable would have to come inland and provide a larger search area for a suitable site away from houses or villages. 3. Flawed public consultation - No alternative sites were consulted on - Insufficient information on the National Grid extensions - Incorrectly stating no other suitable connection sites were possible - Allowing comments on 4 footprint options which were in different locations but all within the same field to an invitation only audience. - Inaccurate exaggerations of distance to nearest properties 4. Unrecoverable damage to the environment - Soil damage in the wide cable route areas - Destruction of fully established trees and hedges - It would force wildlife out of their habitats - Alternative solutions would reduce the environmental impacts "
Members of the Public/Businesses
Margaret Meen
"I am a local landowner and object to this planning application for the reasons outlined below. 1. The proposed sites for the two new substations are completely unsuitable 2. The need for two new substations so far inland from Vattenfall's Wind Farm is unnecessary 3. Vattenfall’s Public Consultation was flawed 4. The proposal will cause unrecoverable damage to the environment  1.Proposed Sites are Unsuitable - They are very near villages such as Necton, Ivy Todd, Fransham, Holme Hale and Bradenham causing distress and sadness with their inhabitants - They will extend an already very visible large structure on top of a hill adding to the visual pollution and light pollution at night - The sites have a high potential in exceeding the governed noise enforcements imposed in the area  Adds further infrastructure to the same area - The sites have very poor access on the brow of a hill with blind summits either direction on the A47, the location of which has already caused a number of road incidents. Other possible access points would bring unnecessary traffic through Fransham increasing pollution and risk to the inhabitants. - Not complying with Breckland Planning: Vattenfall state the development is too massive to be screened from view, and does not fit into the rural landscape. (PEIR ref: Chapter 29 - Table 29.18) Vattenfall admit it will not comply with the Breckland Local Plan which states: “Development…should be of a scale and design that respects the character and rural setting of the settlement.” And “All design proposals must conserve or enhance the existing character of an area.” 2.Why two new substations so far inland from Vattenfall's Wind Farm is unnecessary? Alternative Solutions - A marine cable connection around the coast into Walpole would prevent the cable route coming 47km across the Norfolk countryside, and eliminating the need for new substations or any expansions. This would result in other wind farms having the ability to connect to it if required. - A connection could be made on any suitable pylon on the 400KV overhead existing cable lines, which would reduce the distance the cable would have to come inland and provide a larger search area for a suitable site away from houses or villages. 3.Flawed public consultation - No alternative sites were consulted on - Insufficient information on the National Grid extensions - Incorrectly stating no other suitable connection sites were possible - Allowing comments on 4 footprint options which were in different locations but all within the same field to an invitation only audience. - Inaccurate exaggerations of distance to nearest properties 4.Unrecoverable damage to the environment - Soil damage in the wide cable route areas - Destruction of fully established trees and hedges - It would force wildlife out of their habitats - Alternative solutions would reduce the environmental impacts "
Members of the Public/Businesses
Mrs Vanessa Long
"The proposed site at Necton is wholey unsuitable for the major development planned by Vattenfall for the following reason. The small rural village of Necton has already been subject to the construction of the Dudgeon National Grid Substation, and all the disruption it caused to the surrounding area, to add another would be an over development of the site, "
Members of the Public/Businesses
Paul Haddow
"I am a local resident and strongly object to this planning application for the reasons outlined below. Flawed public consultation - No alternative sites were consulted on - Insufficient information on the National Grid extensions - Incorrectly stating no other suitable connection sites were possible - Allowing comments on 4 footprint options which were in different locations but all within the same field to an invitation only audience. -Inaccurate exaggerations of distance to nearest properties Alternative Solutions - A marine cable connection around the coast into Walpole would prevent the cable route coming 47km across the Norfolk countryside, and eliminating the need for new substations or any expansions. This would result in other wind farms having the ability to connect to it if required. - A connection could be made on any suitable pylon on the 400KV overhead existing cable lines, which would reduce the distance the cable would have to come inland and provide a larger search area for a suitable site away from houses or villages. Proposed Sites are Unsuitable - They are very near villages such as Necton, Ivy Todd, Fransham, Holme Hale and Bradenham causing distress and sadness with their inhabitants - They will extend an already very visible large structure on top of a hill adding to the visual pollution and light pollution at night - The sites have a high potential in exceeding the governed noise enforcements imposed in the area  Adds further infrastructure to the same area - The sites have very poor access on the brow of a hill with blind summits either direction on the A47, the location of which has already caused a number of road incidents. Other possible access points would bring unnecessary traffic through Fransham increasing pollution and risk to the inhabitants. - Increased flood risk on the proposed site due to a thick layer of impervious clay. Run-off taken by a small tributary (Wissey) that historically and regularly floods the road and nearby properties and blocks the 4” culvert. This has been inadequately addressed."
Members of the Public/Businesses
R Jackson
"I object to the planning application for two new substations and an extension to the current substation near Necton. It appears to be a substantial amount of industrial development for a rural area which will have a negative impact on the local villages and countryside. The hamlet of Ivy Todd and village of Necton are adjacent to the proposed development which could have a significant effect upon the residents there both emotionally and financially. Due to the proposed size and scale of the multiple substations, neighbouring villages such as Little Fransham, Bradenham and Holme Hale are also going to be negatively impacted. The proposed DC buildings are extremely tall so will be visible from miles around; the substation itself will produce a constant electrical ‘hum’ which is unacceptable near human habitation. Has any thought or investigation been made into the safety and long-term health effects of such EM / electrical noise and vibrations and how far will such effects be felt? Furthermore, the greater the size of the development the further the distance will be of this negative effect. Another concern is the local environment and habitat for scarce wildlife such as rare bats, hares and birds which will also be disturbed and negatively impacted by environmental damage and noise when we should be trying to protect it. Light pollution, in an area that is noted for its dark skies, is also a concern. The land around villages is poorly drained so the run off from an increased concrete development will also give the potential for flooding in the surrounding areas; flooding should be prevented rather than building something which may well make the situation worse. Although I support green energy it appears ridiculous to pipe it in so far from its source, across huge swathes of countryside, to then pick on one rural community to house multiple electrical substations rather than siting it in a more remote and hidden location. Necton has one substation already so any new substations should be sited in alternative locations in the region to reduce the impact on one area and one environment. It also appears that Vattenhall have been very vague with what they are planning and any mitigation measures they would put in place; this opaque approach has caused alarm amongst the local residents. It appears that all the possible alternative sites have not been fully investigated in order to find a solution that would provide minimal impact on local communities. At the moment, it does feel like this area has been picked as an easy target without any thorough investigation into all the possible negative impacts that it will have on both the local community and the environment. "
Members of the Public/Businesses
Robert Craigan
"I strongly object to this development which will obliterate a beautiful tract of countryside . The proposed site is home to a huge variety of wild life including deer , hare and numerous species of butterfly's but is rare in it self , in that it occupies an elevated position uncommon in Norfolk . Furthermore when similar positions are to be found in the county they are as often as not prohibited to the public . The proposed development bears no resemblance to the initial one presented at the very first parish council meeting of which I attended in particular the noise levels of which were stated would be inaudible . I note that a condition of making this representation is that it must not contain anything frivolous . However in an ever increasing commercial environment where everything has to be quantified to equate to a commercial cash value is it frivolous to talk of the beyond money benefit this location has on our health and well being ? Walking the meandering path up to the summit watching Deer herds graze and Hares sprint across the fields along the way before turning to view the sunset after a stressful workday provides us all with a sense of relaxation and calm tranquility beyond the measure of banknotes . This monstrous development will permanently remove a valuable natural amenity from the residents of Necton , and Ivy Todd"
Members of the Public/Businesses
Suzanne Meen
"I object to this planning application for the reasons outlined below. 1. The proposed sites for the two new substations are completely unsuitable 2. The need for two new substations so far inland from Vattenfall's Wind Farm is unnecessary 3. Vattenfall’s Public Consultation was flawed 4. The proposal will cause unrecoverable damage to the environment  1.Proposed Sites are Unsuitable - They are very near villages such as Necton, Ivy Todd, Fransham, Holme Hale and Bradenham causing distress and sadness with their inhabitants - They will extend an already very visible large structure on top of a hill adding to the visual pollution and light pollution at night - The sites have a high potential in exceeding the governed noise enforcements imposed in the area  Adds further infrastructure to the same area - The sites have very poor access on the brow of a hill with blind summits either direction on the A47, the location of which has already caused a number of road incidents. Other possible access points would bring unnecessary traffic through Fransham increasing pollution and risk to the inhabitants. - Not complying with Breckland Planning: Vattenfall state the development is too massive to be screened from view, and does not fit into the rural landscape. (PEIR ref: Chapter 29 - Table 29.18) Vattenfall admit it will not comply with the Breckland Local Plan which states: “Development…should be of a scale and design that respects the character and rural setting of the settlement.” And “All design proposals must conserve or enhance the existing character of an area.” 2.Why two new substations so far inland from Vattenfall's Wind Farm is unnecessary? Alternative Solutions - A marine cable connection around the coast into Walpole would prevent the cable route coming 47km across the Norfolk countryside, and eliminating the need for new substations or any expansions. This would result in other wind farms having the ability to connect to it if required. - A connection could be made on any suitable pylon on the 400KV overhead existing cable lines, which would reduce the distance the cable would have to come inland and provide a larger search area for a suitable site away from houses or villages. 3.Flawed public consultation - No alternative sites were consulted on - Insufficient information on the National Grid extensions - Incorrectly stating no other suitable connection sites were possible - Allowing comments on 4 footprint options which were in different locations but all within the same field to an invitation only audience. - Inaccurate exaggerations of distance to nearest properties 4.Unrecoverable damage to the environment - Soil damage in the wide cable route areas - Destruction of fully established trees and hedges - It would force wildlife out of their habitats - Alternative solutions would reduce the environmental impacts "
Members of the Public/Businesses
William Meen
"I strongly object to this planning application for the reasons outlined below. 1. The proposed sites for the two new substations are completely unsuitable 2. The need for two new substations so far inland from Vattenfall's Wind Farm is unnecessary 3. Vattenfall’s Public Consultation was flawed 4. The proposal will cause unrecoverable damage to the environment  1.Proposed Sites are Unsuitable - They are very near villages such as Necton, Ivy Todd, Fransham, Holme Hale and Bradenham causing distress and sadness with their inhabitants - They will extend an already very visible large structure on top of a hill adding to the visual pollution and light pollution at night - The sites have a high potential in exceeding the governed noise enforcements imposed in the area  Adds further infrastructure to the same area - The sites have very poor access on the brow of a hill with blind summits either direction on the A47, the location of which has already caused a number of road incidents. Other possible access points would bring unnecessary traffic through Fransham increasing pollution and risk to the inhabitants. - Not complying with Breckland Planning: Vattenfall state the development is too massive to be screened from view, and does not fit into the rural landscape. (PEIR ref: Chapter 29 - Table 29.18) Vattenfall admit it will not comply with the Breckland Local Plan which states: “Development…should be of a scale and design that respects the character and rural setting of the settlement.” And “All design proposals must conserve or enhance the existing character of an area.” 2.Why two new substations so far inland from Vattenfall's Wind Farm is unnecessary? Alternative Solutions - A marine cable connection around the coast into Walpole would prevent the cable route coming 47km across the Norfolk countryside, and eliminating the need for new substations or any expansions. This would result in other wind farms having the ability to connect to it if required. - A connection could be made on any suitable pylon on the 400KV overhead existing cable lines, which would reduce the distance the cable would have to come inland and provide a larger search area for a suitable site away from houses or villages. 3.Flawed public consultation - No alternative sites were consulted on - Insufficient information on the National Grid extensions - Incorrectly stating no other suitable connection sites were possible - Allowing comments on 4 footprint options which were in different locations but all within the same field to an invitation only audience. - Inaccurate exaggerations of distance to nearest properties 4.Unrecoverable damage to the environment - Soil damage in the wide cable route areas - Destruction of fully established trees and hedges - It would force wildlife out of their habitats - Alternative solutions would reduce the environmental impacts "
Members of the Public/Businesses
Lucy Sheringham on behalf of Andrew Rogers
"Objections towards this planning application Public Consultation issues No Alternatives sites were consulted on Very limited information on the National Grid Extensions Stating no other connection sites were possible which was an incorrect statement Allowing comments on 4 footprint options which were in different locations but all within the same field to an invitation only audience. Proposed Site Large negative impact on Necton, Ivy Todd, Fransham, Holme Hale and Brandenham; noise, light pollution and a huge eye sore which Vattenfall state the development is too massive to be screened from view, and does not fit into the rural landscape. (PEIR ref: Chapter 29 - Table 29.18) Suitable alternatives are available, in particular I refer to a Marine Cable connection around the Coast into Walpole which would prevent a cable route coming 47km across the countryside, eliminating the need for more substations and expansions. This would allow other wind farms to connect to if it was to use the Walpole route. Traffic Terrible access points on the A47 the highlighted access points proposed by Vattenfall have pin are unsuitable and very dangerous, one of which has had many accidents happen in that location already. "
Members of the Public/Businesses
Anglian Water Services Ltd
"Thank for you the opportunity to comment on the Norfolk Vanguard 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 water undertaker. To date discussions with the applicant have focused on the impact on groundwater sources only. 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. 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 2017. It is noted that specific protective provisions have been included in the current version of the DCO (Schedule 6, Part 16 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
Lucy Sheringham on behalf of Anna Spratt
"I object to this planning application for the reasons outlined below. Flawed public consultation - No alternative sites were consulted on - Insufficient information on the National Grid extensions - Incorrectly stating no other suitable connection sites were possible Allowing comments on 4 footprint options which were in different locations but all within the same field to an invitation only audience. Proposed Sites are Unsuitable - They are very near villages such as Necton, Ivy Todd, Fransham, Holme Hale and Bradenham causing distress and sadness with their inhabitants - They will extend an already very visible large structure on top of a hill adding to the visual pollution and light pollution at night - The sites have a high potential in exceeding the governed noise enforcements imposed in the area  Adds further infrastructure to the same area - The sites have very poor access on the brow of a hill with blind summits either direction on the A47, the location of which has already caused a number of road incidents. Other possible access points would bring unnecessary traffic through Fransham increasing pollution and risk to the inhabitants. - Not complying with Breckland Planning: Vattenfall state the development is too massive to be screened from view, and does not fit into the rural landscape. (PEIR ref: Chapter 29 - Table 29.18) Vattenfall admit it will not comply with the Breckland Local Plan which states: “Development…should be of a scale and design that respects the character and rural setting of the settlement.” And “All design proposals must conserve or enhance the existing character of an area.” Alternative Solutions - A marine cable connection around the coast into Walpole would prevent the cable route coming 47km across the Norfolk countryside, and eliminating the need for new substations or any expansions. This would result in other wind farms having the ability to connect to it if required. - A connection could be made on any suitable pylon on the 400KV overhead existing cable lines, which would reduce the distance the cable would have to come inland and provide a larger search area for a suitable site away from houses or villages. Unrecoverable damage to the environment - Soil damage in the wide cable route areas - Destruction of fully established trees and hedges - It would force wildlife out of their habitats - Alternative solutions would reduce the environmental impacts "
Members of the Public/Businesses
LucY Sheringham on behalf of Annabelle Rogers
"I object to this planning application for the reasons outlined below. Flawed public consultation - No alternative sites were consulted on - Insufficient information on the National Grid extensions - Incorrectly stating no other suitable connection sites were possible -Allowing comments on 4 footprint options which were in different locations but all within the same field to an invitation only audience. Proposed Sites are Unsuitable - They are very near villages such as Necton, Ivy Todd, Fransham, Holme Hale and Bradenham causing distress and sadness with their inhabitants - They will extend an already very visible large structure on top of a hill adding to the visual pollution and light pollution at night - The sites have a high potential in exceeding the governed noise enforcements imposed in the area  Adds further infrastructure to the same area - The sites have very poor access on the brow of a hill with blind summits either direction on the A47, the location of which has already caused a number of road incidents. Other possible access points would bring unnecessary traffic through Fransham increasing pollution and risk to the inhabitants. - Not complying with Breckland Planning: Vattenfall state the development is too massive to be screened from view, and does not fit into the rural landscape. (PEIR ref: Chapter 29 - Table 29.18) Vattenfall admit it will not comply with the Breckland Local Plan which states: “Development…should be of a scale and design that respects the character and rural setting of the settlement.” And “All design proposals must conserve or enhance the existing character of an area.” Alternative Solutions - A marine cable connection around the coast into Walpole would prevent the cable route coming 47km across the Norfolk countryside, and eliminating the need for new substations or any expansions. This would result in other wind farms having the ability to connect to it if required. - A connection could be made on any suitable pylon on the 400KV overhead existing cable lines, which would reduce the distance the cable would have to come inland and provide a larger search area for a suitable site away from houses or villages. Unrecoverable damage to the environment - Soil damage in the wide cable route areas - Destruction of fully established trees and hedges - It would force wildlife out of their habitats - Alternative solutions would reduce the environmental impacts "
Members of the Public/Businesses
Brown & Co on behalf of Bawdeswell Farms Ltd
"Our client has been in proactive discussions with Vattenfall, however these matters are not concluded and therefore the outline representations are detailed below having been prepared by the NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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. "
Members of the Public/Businesses
Brian Bales
"The site is set at the highest point in the area which increases its visibility in a beautiful landscape & will negatively impact on property prices. The noise level that will be generated is unacceptable for a rural area. The two other sites suggested have not been explored properly & no rational explanation has been provided as to why these sites which would have less impact on the neighbouring community have essentially been discarded The site is between the toxic area of a plane crash and also infringes on an archaeological site. "
Members of the Public/Businesses
Brown & Co on behalf of Charity of Thomas Barrett - The Trustees thereof care of Nicholas Saffell
"Our client has been in proactive discussions with Vattenfall, however these matters are not concluded and therefore the outline representations are detailed below having been prepared by the NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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. "
Members of the Public/Businesses
Christine Dye
"Happisburgh is a small rural coastal village with an eroding cliff outside the marine conservation area. It seems that for this reason a multinational company owned by the Swedish Government thinks that we don’t matter! Happisburgh may not matter to them but it’s residents deserve to be heard and have their concerns taken into consideration. Our cliff is very fragile and drilling into it at its lowest point could cause catastrophic collapse. It could also lead to the flooding of communities lower than Happisburgh, that have been in receipt of large amounts of government money since the disastrous flooding in 1953. Two miles away on the coast is Bacton Gas Terminal, although within the marine conservation area, the seabed there is already littered with all manner of pipes, cables etc. Is there a possible linkup to the National Grid there? If that is not a possibility and knowing that the government intends investing in more offshore wind would it be feasible to put a cable around the coastline so that these companies could plug in instead of raping our countryside with their cable laying equipment and building huge structures in the rural landscape. It has taken 40 years to put the heart back into the soil after the gas pipeline was built and this is on some of the best agricultural (grade 1) land in the country. Vattenfall is proposing digging up 40 KM of this land to lay their cables for a contract of 25 years. We are fortunate in that, because we have no Street lighting we have (almost)dark skies which is now thought of as being a benefit rather than a disadvantage. We did not benefit from mains gas when Bacton was built and we will not derive any additional benefit from this disruption either. We have Sand Lizards; Bats; Sand Martins; Skylarks; Tawny, Little and Barn Owls all of which could be affected by the noise and light pollution and vibration. There are also Harbour and Grey Seals offshore. I have concerns about the amount and size of HGV’s going through our narrow village street, closure of roads which could cut the village in half. The noise and light pollution which will come from an industrial site in the village, the loss of amenities, beach access; footpaths; quiet lanes; peace and tranquility for an unspecified period of time. I have concerns on a wider scale as to what we are doing to our oceans by pumping tons of concrete to hold up Wind Turbines which apparently have a lifespan of 25 years. Isn’t it about time we found a better solution to our insatiable demand for electricity. Green peace estimates that if we covered every roof that is viable with solar we could power the country. If you add into that mix micro generation in rural communities, we would be self sufficient in energy. "
Members of the Public/Businesses
Christopher Dye
"My concerns are:- 1/ The fragility of the cliff Vattenfall intends drills into. 2/ The damage to wildlife both marine and land. 3/ lose of amenities around the village ie footpaths; Beach; roads etc closed for an unspecified length of time. 4/ The environmental damage both marine and land. The dumping of tons of concrete into the sea and the desecration of grade 1 agricultural land all for a 25 year contract. 5/ The noise and light pollution that will arise from having an industrial site with heavy machinery working 24/7 etc in the village 6/ As a coastal village we need tourism, but will they want to come to an industrial site with no amenities. 7/ The health and welbeing of the residents of this village who live constantly with the knowledge of their homes being lost to coastal erosion. Government Ministers;Politicians; Universities; Colleges and Schools; numerous survey teams including the BGS and Archaeologists from the British Museum all come to Happisburgh for very short lengths of time. They do not see or understand the effects of the catastrophic erosion which is occurring every second of every day as seen and experienced by the residents of this village which is down to many factors including vibration and heavy machinery. This is my overwhelming concern. "
Members of the Public/Businesses
Brown & Co on behalf of David Hampson
"Our client has been in proactive discussions with Vattenfall, however these matters are not concluded and therefore the outline representations are detailed below having been prepared by the NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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. "
Members of the Public/Businesses
David Spain
"The Vattenfall DCO is superficial with insufficient investigation of the following at the Necton substation: • Flood risk • Significant environmental contamination (plane crash in 1996) • There are a number of rare bat species sighted around land that will be disturbed by the construction at Necton • Compliance with local council noise limits when both planned substations (Vanguard and Boreas) are at full capacity • The buildings cannot be screened from view as they will be built on a high piece of land and the buildings will be 25 metres high • Suitability of the site chosen. It will be 100 acres of land for Vanguard and the closely following Boreas substations from the perspective of a rural village less than a Km away. • A suggested suitable alternative site (Scarning/Wendling) that is not close to a village has not been investigated • Unsuitability of site from the perspective of protection from terrorist threat to UK infrastructure. It will the biggest substation feeding the grid in the UK and sited close to an ancient wood • Five local holiday let/caravan site businesses will be negatively impacted by construction work. Noise / lighting nuisance not adequately managed in the application • Safe access to the site from the busy A47 "
Members of the Public/Businesses
Diane Flynn
"That this project must use the HVDC export system as confirmed by Vattenfall and no Cable Relay Stations will be constructed Vattenfall have not replied to all emails or comments that were submitted during the open sessions and subsequently so I am not convinced about the quality of their consultation work. Greater detail is required regarding any maintenance and de-commissioning activity post construction. The trench work should be within working hours and not when lighting is required Traffic will divert to avoid the routes used by the project and so this should be monitored and remedial action taken to prevent and address any disruption spreading to the wider road network. Vattenfall should demonstrate how they will protect areas which have remained relatively undisturbed by noise. Take the opportunity to support the improvement of local services and amenities such as sharing of trenchwork with local plans to introduce better broadband in rural areas"
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Dillington Hall Estate
"IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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. [Redacted] NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 14th September 2018. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 [Redacted], MRICS, FAAV Rural Surveyor "
Members of the Public/Businesses
Dr Andy Scarlett
"Whilst I accept that such projects involving major infrastructure are of national importance, I feel very strongly that the application in question should not be permitted to proceed in its current form, for the following reasons:- 1. Impact upon the Character & Amenity of the Locality due to the Proposed Location/Siting of Substation(s) at Necton: The proposed location is a green field site of considerable natural beauty. Importantly it is proposed to locate the necessary structures upon the highest (elevated) area of land in the local area, thereby making the extremely high buildings which are proposed (>20 metres high?) visible from a very considerable distance. This potentially risks maximising the environmental impact of the development and blighting the visual amenity of residents of numerous local villages and visitors to and travelling through this rural area. Limited information available to-date from the applicant regarding this aspect suggests that very little consideration has been given to taking significant steps to minimise the visual magnitude of the proposed development and its likely impact both on the local environment and the upon the current enjoyment of that environment by residents. Accepting that developments of this kind have to be located somewhere, it would be reassuring to see the applicant take more realistic steps in site selection & site configuration to minimise environmental (visual) impact. 2. Ambient Noise Levels in Necton & Surrounding Villages: The Applicant has provided little information to local residents regarding this matter, but the selection of a Direct Current-based system (over an AC system) is believed likely to cause the proposed substation to generate significant ambient noise levels, which in turn are likely to require mitigation measures in order to limit environmental impact. The high-elevation of the proposed substation site risks maximising propagation of any generated noise over a radius of a number of miles, thereby impacting upon the aural amenity of residents in local villages (noise levels in these rural villages typically being low). 3. Inadequate / Flawed Public Consultation: Whilst the applicant has undoubtedly taken steps to engage with the General Public, the level of detail provided in this process has unfortunately been at best limited. Despite repeated requests from Necton and Holme Hale Parishioners, the applicant has declined to provide artist’s impressions of the proposed substation structures to a level of detail where their magnitude & orientation, relative to surrounding local features & landscape, could be objectively assessed. Representatives of the applicant have also declined to attend numerous meetings held between concerned residents and our local MP George Freeman. There is a desire in the locality for meaningful engagement with the applicant, but this appears unlikely to be forthcoming until after the expiry of the representation period. Given this experience and the associated timelines, it is difficult if not impossible to regard the Public Consultation undertaken by the applicant to-date, regarding a proposed development of such a major nature within a rural area, as anything other than inadequate. Dr Andy Scarlett Sun 16/09/18 "
Members of the Public/Businesses
Ed Salmon
"I am raising these points below as a local resident. I object to the planning application for the reasons outlined below; Public Consultation Issues; 1. No alternative Sites were consulted on 2. Poor information on the National Grid Extensions 3. Stating no other suitable connection sites were possible; incorrect statement The proposed sites themselves are completely unsuitable; 1. They will have a huge negative impact on the surrounding villages including Holme Hale, Ivy Todd, Little and Great Fransham, Necton and Bradenham; the negative impacts include noise, light pollution, and creating an eye sore 2. The road infrastructure will encourage accidents with the poor visual splay junctions onto the A47 which would be used Environmental Impacts include soil damage, removal of established trees and hedges, disturbance of wildlife, all of which could be dramatically reduced if a marine cable to Walpole was the chosen route. The proposal is in breach on Breckland Councils planning policy. It will certainly not be of a 'scale and design that respects the character and setting of a rural settlement'. Suitable alternatives are available, in particular i refer to a Marine Cable connection around the coast into Walpole which would prevent the cable route coming 47km across the Norfolk countryside, and eliminating the need for new substations/expansions. It would also allow other wind farms to connect to it if it was to be moved to the Walpole route. "
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Farnham Farms Limited
"IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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. [Redacted] NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 14th September 2018. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 [Redacted], MRICS, FAAV Rural Surveyor "
Members of the Public/Businesses
Lucy Sheringham on behalf of Fiona Unick-Wagg
"I object to this planning application for the reasons outlined below. Flawed public consultation - No alternative sites were consulted on - Insufficient information on the National Grid extensions - Incorrectly stating no other suitable connection sites were possible Allowing comments on 4 footprint options which were in different locations but all within the same field to an invitation only audience. Proposed Sites are Unsuitable - They are very near villages such as Necton, Ivy Todd, Fransham, Holme Hale and Bradenham causing distress and sadness with their inhabitants - They will extend an already very visible large structure on top of a hill adding to the visual pollution and light pollution at night - The sites have a high potential in exceeding the governed noise enforcements imposed in the area  Adds further infrastructure to the same area - The sites have very poor access on the brow of a hill with blind summits either direction on the A47, the location of which has already caused a number of road incidents. Other possible access points would bring unnecessary traffic through Fransham increasing pollution and risk to the inhabitants. - Not complying with Breckland Planning: Vattenfall state the development is too massive to be screened from view, and does not fit into the rural landscape. (PEIR ref: Chapter 29 - Table 29.18) Vattenfall admit it will not comply with the Breckland Local Plan which states: “Development…should be of a scale and design that respects the character and rural setting of the settlement.” And “All design proposals must conserve or enhance the existing character of an area.” Alternative Solutions - A marine cable connection around the coast into Walpole would prevent the cable route coming 47km across the Norfolk countryside, and eliminating the need for new substations or any expansions. This would result in other wind farms having the ability to connect to it if required. - A connection could be made on any suitable pylon on the 400KV overhead existing cable lines, which would reduce the distance the cable would have to come inland and provide a larger search area for a suitable site away from houses or villages. Unrecoverable damage to the environment - Soil damage in the wide cable route areas - Destruction of fully established trees and hedges - It would force wildlife out of their habitats - Alternative solutions would reduce the environmental impacts "
Members of the Public/Businesses
Frank Cherry
"My concern would primarily be regarding the constant noise coming from a tall building housing the DC/A.C. conversion building. More information regarding noise would be welcome."
Members of the Public/Businesses
Gary Holley
"Dear Sir/Madam, I live in [Redacted], directly opposite the new proposed massive development. As well as living here I have a 4 star Holiday let with swimming pool which has been successfully run over 18 years, and earlier this year we received planning permission for four more Lodges, making it a small Holiday Park. Vatenfalls development is 4 minutes walk across the opposite field in full view.On the present smaller development we suffered continous light poloution throughout the construction process with flood lights on all night.This new proposal dwarfs the existing one. Effectively this development will destroy this business, as you only need one review in this day and age to say" location spoilt by massive sub station opposite". Game over! My opinion is that no serious study into the location of this project has ever been done,it is situated on high ground, visible on the A47 as you enter and leave Norfolk, which is the third most popular Holiday destination in the UK. Do holiday makers and residents of Norfolk really want to see this? Many of us are very upset, throughout Norfolk.Originally the existing Sub Station was going to Dunham,but the villagers were very opposed and it was moved to the existing position, and everyone thought that was the end of the matter, no mention of masses of further development. I have attended numerous Vatenfall meetings, they have ignored everyone, and we have been given a choice of positions all in the same footprint. It beggers belief! It appears to me that they are just jumping through the hoops with no interest in the local community, indeed I offered a much better location at Top Farm Fransham, with the Farmer interested in selling, and they showed no interest, other than "we may decide to put a road through the farm for access wether you like it of not". Wind Turbines were situated out at sea as it was easier to get planning, as many people objected to them, now its the infrastructure for them that is destroying the Norfolk Coutryside,not just here but all over Norfolk.If we need to have them,(although a recent news feature in the press stated that National Grid has a surplus of energy in summer and may have to pay generators to switch off),can a sensible location be used, one away from villagers,and out of sight of the main roads.Please can you prove the people of Norfolk wrong, and show that there still is a democratic process, as many feel the desicion has already been made. I have lived in Norfolk all my life, and respect the fact that we have to embrace developments, as I have coverted Old Norfolk Barns to Homes, but with respect to the local countryside. Norfolk is not industralised Coventry, but this is how it will appear when you drive in to Norfolk in the future. And what would future generations think? Whats happenning here is unforgivable in its present proposal. I would like to state that George Freeman has assisted with local meetings and invited Vatenfall to attend and discuss with the local villagers, but the last few meetings they decided not to bother attending. In fact they have never visited our home or holiday development to discuss or meet, instead tending to turn a blind eye to any obsticales . I sincerely hope that you look into this proposed ,development with a open mind. "your mind is like a parachute, works better when its open" A very concerned resident. Kind Regards, Gary M Holley "
Members of the Public/Businesses
Georgie Armstrong
"I am raising these points below as a local resident. I object to the planning application for the reasons outlined below; Public Consultation Issues; 1. No alternative Sites were consulted on 2. Poor information on the National Grid Extensions 3. Stating no other suitable connection sites were possible; incorrect statement The proposed sites themselves are completely unsuitable; 1. They will have a huge negative impact on the surrounding villages including Holme Hale, Ivy Todd, Little and Great Fransham, Necton and Bradenham; the negative impacts include noise, light pollution, and creating an eye sore 2. The road infrastructure will encourage accidents with the poor visual splay junctions onto the A47 which would be used Environmental Impacts include soil damage, removal of established trees and hedges, disturbance of wildlife, all of which could be dramatically reduced if a marine cable to Walpole was the chosen route. The proposal is in breach on Breckland Councils planning policy. It will certainly not be of a 'scale and design that respects the character and setting of a rural settlement'. Suitable alternatives are available, in particular i refer to a Marine Cable connection around the coast into Walpole which would prevent the cable route coming 47km across the Norfolk countryside, and eliminating the need for new substations/expansions. It would also allow other wind farms to connect to it if it was to be moved to the Walpole route. "
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Gorgate Ltd
"IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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. [Redacted] NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 14th September 2018. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 [Redacted], MRICS, FAAV Rural Surveyor "
Members of the Public/Businesses
Jackie Sidey
"My main concerns about the proposal are; 1) The permanent eyesore of such a vast industrial site, amplified by the elevated position and height requirement of the HVAC connection to what I understand will need to be up to 80 feet tall. This isn’t in-keeping with a rural village. The current substation is fairly discrete. 2) EMR issues from the large site, within close proximity to housing and an expanding Primary School. 3) The potential of increased flooding within the village of Necton due to development of an agricultural site. 4) The additional traffic the site will create both during construction and afterwards, impacting on the already busy, single carriageway section of the A47. This also is likely to make the Necton junction of the A47 even more treacherous than it currently is. 5) The noise and dust implications from the lengthy construction time needed to build the site. This will have a huge impact on the health and stress of residents nearby. "
Members of the Public/Businesses
John Darcy
"Please note our major concerns with regard to this application. We live in Ivy Todd and have been here for six years. A quiet and unassuming hamlet close to Necton. We were devastated to learn of the proposed development which will change lives forever. There are serious concerns about flooding here and our garage has suffered from this in our time here. The brook cannot cope now with the amount of water that comes down from the surrounding land and amore land goes under concrete this will decrease the drainage efficiency. I understand there was a plane crash on the proposed site a number of years ago and this raises concerns about potential toxins being released if there is substantial ground disturbance. Please remember changing land use from agricultural to commercial/industrial is worrying - THEY DON'T MAKE IT ANYMORE."
Members of the Public/Businesses
Kirsty Willis
"The site is set at the highest point in the area which increases its visibility in a beautiful landscape & will negatively impact on property prices. The noise level that will be generated is unacceptable for a rural area. The two other sites suggested have not been explored properly & no rational explanation has been provided as to why these sites which would have less impact on the neighbouring community have essentially been discarded The site is between the toxic area of a plane crash and also infringes on an archaeological site. "
Members of the Public/Businesses
Louise Brooks
"Happisburgh is a small vulnerable Norfolk village. Traffic in the area will be unbearable, including HGV vehicles 24 / 7. Residents of the village will not be able to get from one end to the other, and all footpaths will be closed. Tourists will stop coming, because our tranquil peaceful village will no longer be the attraction it is now. Happisburgh Lighthouse is the only privately owned working lighthouse in the UK and brings many tourists to the village. A Parish owned car-park which is self funding and raises money for the village, RNLI lifeboat station and souvenir shop, historic pub with separate coffee House and carvery, village shop, fish shop and cafe are all part of a thriving community who welcome tourists, year round, whilst staying a quiet, beautiful place for its residents to live. If Vattenfall are allowed to go ahead with this project, it will be the end of village life for Happisburgh. We seem to powerless to stop this. "
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Lucy Keane and Matthew Keane
"IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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. [Redacted] NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 14th September 2018. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 [Redacted], MRICS, FAAV Rural Surveyor "
Members of the Public/Businesses
Mark Kiddle-Morris
"I am concerned only with the proposed on shore sub station complex in the Parish of Necton. The extension of the existing National Grid sub station to accommodate the Vanguard (and later the Boreas) and the new substations required for both projects impose an unacceptable industrialisation of the countryside. The proposed use of a HVDC transmission system will impact on the visual amenity of the area due to the increased height of the structures required. The proposed siting of the new sub stations within the specified 3 km radius of the National Grid site has been poorly chosen being placed on the highest parcel of land in the area."
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mark, Dorothy, Marilyn and David Howell
"IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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. [Redacted] NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 14th September 2018. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 [Redacted], MRICS, FAAV Rural Surveyor "
Members of the Public/Businesses
Michael Birmingham
"I am concerned over the Vanguard proposal due to the follow: Environmental concerns. Impact on undefended and fragile cliffs, which have already suffered recent collapse. Works impact on light and noise pollution to local residents and tourists. Impact of heavy machinery and large trucks on the narrow roads and possible effects on buildings due to vibration. Road closures making it difficult for local residents and much needed local tourism. Archaeological issues: Everyone is aware of important archaeological finds on the beach. These works may destroy further and new important finds. Alternative works It is my understanding that connection to the national grid could be done using an offshore ring main. Lack of any compensation to the local community ( should works go ahead) e.g. enhancing sea defences."
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mills & Reeve Trust Corporation and Alexander Gavin Angell Lane
" IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 ?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. 4.2?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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5.?Construction and Funding 5.1 ?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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6.? Cumulative Impact 6.1 ?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. 7. ?Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8.? Field Drainage 8.1 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 but it is not satisfactory. 8.2?To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. ?Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10.?Flood Issues 10.1 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. 11.?Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. ?Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. ?Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14.?Request to Attend Hearings and make Representations 14.1 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. 14.2 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. [Redacted]? NFU?? Agriculture House? Stoneleigh Park? Stoneleigh? Warwickshire CV8 2TZ? DATED 14th September 2018.? IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD PROJECT DEVELOPMENT CONSENT ORDER 2018 AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND LAND AGENTS (LIG). ______________________________ OUTLINE REPRESENTATIONS ______________________________ NFU AGRICULTURE HOUSE STONELEIGH PARK STONELEIGH WARWICKSHIRE CV8 2TZ REF? [Redacted], MRICS, FAAV ?Rural Surveyor "
Members of the Public/Businesses
Savills (UK) Ltd (Savills (UK) Ltd) on behalf of Mr Rex Baldwin
"IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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. [Redacted] NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 14th September 2018. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 [Redacted], MRICS, FAAV Rural Surveyor "
Members of the Public/Businesses
Brown & Co on behalf of Mr Robert Claboon
"Our client has concerns relating to the potential sterilization of land with potential to be developed for housing and or employment/commercial use. The planning situation in North Norfolk remains highly fluid and under review. The timing of this infrastructure project may result in competing development interests being sterilized due to being at an earlier stage of the development consent process. There has been proactive and constructive discussions between Vattenfall and our client and this representation is submitted to reserve the right to have these matters considered in a more formal theater in the event that discussions fail to progress as expected. Further outline representations are detailed below on behalf of our client as prepared by the NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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. "
Members of the Public/Businesses
Mrs C L Cherry
"That this project is being built on a site that is unsuitable as it is at the highest point in the area between a crash site & significant archaeology. There are two more suitable sites in the area. The need for green energy is understood but it has to be on the right site and cause the minimum impact. There is the matter of converting DC - AC which will cause either considerable background noise &/or vibrations permanently to a large area. There will be massive tall buildings, the height of the existing pylons, incapable of being hidden by trees. It is more important that it is out of the sight line of the surrounding villages, rather than it not being seen from the A47. There is the fire risk to consider in an agricultural area and there are number of fires at substations each year. If we continue to have very hot dry summers, the fire risk increases and so do the serious consequences to villages & crops. There will be very few jobs at the site once completed & so far no people from Necton have been employed by any of the companies involved in this project. There is the wildlife to consider and the proposed site is home to two types of rare bats as listed by the BCT. Provision must be made to lessen the impact on all wildlife & habitat. "
Members of the Public/Businesses
Mrs H Birmingham
"I would like to register my interest over the following points. The vulnerability of the already eroding cliffs and that Vattenfall don't seem to have alleviated these concerns. Road and footpath closures along with extra traffic lights. This will cause huge disruption to those that use the school, shop, post office, pub, cafe and holiday cottages leading to uncertaincy for the livelihoods of these businesses.This will also affect the villagers that rely on these facilities. The increased noise pollution will also affect the living conditions of many villagers that live in houses right on the roads. These old houses, many in the conservation area, could possibly have their foundations compromised by the increased use by heavy vehicles. The holiday homes could suffer as visitors won't want to holiday in our village with all the disruption. Under the "Protection and Enhancement of Landscape and Settlement Character" Policy EN2 I am concerned that the proposed plans will not demonstrate that they will "enhance, protect, conserve and where possible enhance the special qualities and local distinctivenessof an area". We are all aware that renewable energy is necessary for the future but feel that these plans as they stand will ruin our village, it's community, countryside, beach and destination that holiday makers will want to visit."
Members of the Public/Businesses
Mrs Susan Allen
"As part of the group, N2RS, my representation covers the main concerns of the group but also my concerns in my role as a long standing local resident and holiday rental agent for properties in the area and regular leisure user of the beaches and countryside that will be affected. When N2RS was established in April 2017 the main focus was on the choice of technology: HVAC technology would have required cable relay stations, replacing productive agricultural land and leaving a permanent, invasive industrial sites near the coast in rural North-East Norfolk. HVDC technology would negate the need for cable relay stations, significantly reduce the cable width and reduce the impact for the majority of people along the whole cable route, including the access point at Happisburgh. N2RS worked tirelessly throughout the formal and informal consultations to raise awareness amongst the local community and encourage constructive engagement to ensure the project was fully debated by elected representatives the media and other interested parties. In doing this the members of N2RS recognised the need for renewable energy but felt it must be achieved with due regard and respect for the environment, homes, businesses and wildlife. N2RS therefore called upon Vattenfall to adopt best practice at a corporate level, by committing to an HVDC transmission system – as the least environmentally damaging choice of technology for this and future UK projects. Vattenfall’s unequivocal commitment to HVDC has therefore been welcomed by N2RS. As the Planning Inspectorate scrutinises the results of Vattenfall’s formal consultation, the strength of support for HVDC should become apparent and any deviation from this preferred system (pre or post consent) would undermine the planning process and would be totally unacceptable to the communities and stakeholders who have supported the HVDC route. The advantages of an HVDC are reiterated below: • No cable relay stations will be required in unspoilt countryside near the coast • The cable corridor width will be reduced substantially from 100 m to 45 m • The local landscape and countryside, which is key to the area’s character and its popularity with tourists, will be protected from permanent industrialisation. • Local wildlife (which includes many protected species) will no longer be threatened by loss of habitat due to cable relay stations. • Construction traffic, which would have impacted on nearby quiet lanes posing a real threat to tourism and to the quality of life of locals, will be reduced from eight years to two. • High-grade farmland will no longer be lost to cable relay station sites and disruption to farm operations will be reduced. • Ancient bridleways such as Munn’s Loke – the home of diverse wildlife and a much-valued local amenity – will not be lost or compromised. • Tourism businesses – holiday cottages, seaside parks, cafes and restaurants – will not be at major risk due to long term uncertainty, loss of reputation and loss of business or closure. Landfall at Happisburgh N2RS welcomes the commitment by Vattenfall to Horizontal Directional Drilling (HDD) at Happisburgh and its guarantee that the beach will not be needed for access. However, Happisburgh is facing major challenges due to rapid cliff erosion. Homes have been lost and others will be under threat if erosion accelerates at this current pace. The village coastline is a very important archaeological area with significant finds including 'The Happisburgh Handaxe' and the Happisburgh footprints, both evidence of early Paleolithic activity here. Over time this threat will be extended to inland villages and even the Norfolk Broads; an immensely valuable (economically and environmentally) and unique area. An opportunity to make landfall at an existing site at Bacton (which we believe may now be deliverable with the HVDC option) has been lost. This was partly due to restraints set by the Marine Conservation Zone – but given that the MCZ has already been breached by gas pipes and that the seabed will presumably recover (as we are led to believe is the case with the land) N2RS is disappointed that the Bacton option was so quickly dismissed and this should be a line of enquiry during the inspection process. Additional points Although welcoming the HVDC decision and acknowledging the significant extent to which it reduces impact, the project will still affect some individuals and communities, especially where the cable corridor runs close to homes and businesses, where traffic is disruptive and where it connects to the Grid. Therefore, a) Due regard should be given to homes and businesses which are still directly affected by the wider plans - and loss in property value and quality of life should be taken into account. It should not fall upon individuals to bear the brunt of schemes like this and those affected must be properly compensated. This would include owners of holiday businesses who will lose trade during construction and suffer longer-term loss of reputation for the area. b) The intrusion into the countryside should be kept to an absolute minimum and the developers should continue to liaise with local people to utilise their knowledge and experience so that homes, the quality of life of individuals, businesses and wildlife do not suffer unnecessarily. c) Vattenfall should continue to communicate with those who have expressed an interest in this project directly to inform them of major milestones and any aspect that will affect nearby communities – such as road closures and improvements. d) Once construction starts, local people should have an effective means of contacting the developer or project team especially in emergencies where for example there is evidence of harm to wildlife, flooding, other unexpected events or incorrect procedures being followed by sub contract workers. e) Vattenfall’s project team should recognise the importance of tourism and ensure wherever possible that works will not impact on the area during peak tourism periods. The impact on tourism businesses during construction and loss of reputation should be compensated. Tourism brings a very substantial income to this otherwise rural and relatively poor area. Finally, the rights of local people to enjoy their surroundings out of peak hours should also be respected. "
Members of the Public/Businesses
Neville McBrien
"1. Very Poor Public Consultation: Vattenfall incorrectly stated there were no other suitable sites when in fact their are, with one very close which would have greatly reduced visual impact of electrical substation construction. Also inaccurate distance quoted to nearest property 2.Flood Risk: The proposed site has a top layer of impervious clay and as the run-off is a small tributary of the Wissey there is markedly increased risk of flooding, in surrounding roads which regularly have flooded. 3. Site Location: Proposed site very close to 1996 Danish F16 crash site, with known radiation risk. Insufficient space between crash site and protected archaeology area. 4.Noise Limit Issues: Highly likely Breckland Council noise limit restrictions will be breached by DC substation when Vanguard an Boreas at full generation capacity. 5. Visual Impact in Rural Area: The proposed substation construction is very large and will not be adequately screened from view, particularly for Holme Hale residents. Almost certainly not compliant with Breckland local Plan. 6. Two Species of Rare Bats ignored in placement of site. 7. Fire Risk: There are inadequate measures against risk of field fire to substations. Adequate protection would further increase land required and already massive size. "
Members of the Public/Businesses
Lucy Sheringham on behalf of Nick Rice
"Objections towards this planning application: Necton is not a suitable location for this huge industrial development, which if completed will be the biggest of its kind in the world. There are far better alternatives available to avoid this mass construction in the Norfolk Countryside. Public Consultation issues: 1.No alternatives sites were consulted on 2.Very limited information on the National Grid Extensions 3.Stating no other connection sites were possible which was an incorrect statement 4. Allowing comments on footprint options which were in different locations but all within the same field to an invitation only audience. Proposed Site: Large negative impact on Necton, Ivy Todd, Fransham, Holme Hale and Brandenham; noise, light pollution and a huge eye sore which Vattenfall state the development is too massive to be screened from view, and does not fit into the rural landscape. (PEIR ref: Chapter 29 - Table 29.18) Suitable alternatives are available, in particular I refer to a Marine Cable connection around the Coast into Walpole which would prevent a cable route coming 47km across the countryside, eliminating the need for more substations and expansions. This would allow other wind farms to connect to if it was to use the Walpole route. Unrecoverable damage to the environment: 1.Soil damage in the wide cable route areas 2.Destruction of fully established trees and hedges 3. It would force wildlife out of their habitats 4.Alternative solutions would reduce the environmental impacts Traffic: Terrible access points on the A47. The highlighted access points proposed by Vattenfall are very unsuitable and dangerous, one of which has had many accidents happen in the location already. Radiation Risk: Vattenfall claim ignorance of the 1996 Danish air force F16 crash site which lies central to their 400kV cabling, and the associated radiation substance risk warning (given to MAFF in 1996, NGR TF 894100). NCC informed Vattenfall of crash and radiation risk on 5 June 2018. Insufficient space exists for this development between protected archaeology and radioactive risk. "
Members of the Public/Businesses
North Norfolk District Council
"Norfolk Vanguard Wind Farm Application Ref: EN010079 Submission of Relevant Representation North Norfolk District Council (NNDC) has been notified by Norfolk Vanguard Limited that, as of 24 July 2018, their application for Development Consent Order (DCO) in respect of Norfolk Vanguard 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 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 Vanguard Offshore Wind Farm (and sister Norfolk Boreas 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. Keys Aspects of the Project Affecting North Norfolk North Norfolk District Council’s jurisdiction extends inland from the Mean Low-Water mark along the coastline. The proposal in the form of landfall works, 45m wide onshore cable route, trenchless crossing zones and mobilisation areas would affect land within NNDC stretching from the intertidal area south of Happisburgh from where the onshore cable route travels inland in a north-westerly direction passing Ridlington and Witton, towards the northern edge of North Walsham before it exits North Norfolk District Council’s jurisdiction north of Aylsham near to the A140 at Banningham. The key design/construction decisions affecting North Norfolk include: • Choice of transmission system; • Phasing of the Project and Associated Construction Timetable(s); • Method of bringing offshore cables onshore at Happisburgh; • Working Corridor of onshore cable route; • Use of Horizontal Directional Drilling onshore; • Impact of construction traffic; • Landscape & Biodiversity Mitigation; • Community Benefits Choice of Transmission System - High Voltage Direct Current (HVDC) North Norfolk District Council welcomes the decision of Vattenfall to commit to the use of high voltage direct current (HVDC) transmission for both the Norfolk Vanguard and Norfolk Boreas projects. This decision was made following the Preliminary Environmental Information Report (PEIR) stage at which the District Council and many local residents/business and other consultees raised concerns about the potential adverse impacts from the onshore cable relay stations needed for the high voltage alternating current (HVAC) transmission system in the East Ruston / Ridlington area of North Norfolk. In the opinion of North Norfolk District Council, the decision by Vattenfall to adopt the HVDC transmission system meaning that cable relay stations are no longer required and allowing the working corridor of the project to be reduced to 45m, is a hugely positive step in terms of minimising project impacts within the North Norfolk area. Phasing of the Project and Associated Construction Timetable(s) Section 5.5.8 of Chapter 5 – Project Description sets out the Indicative Onshore Construction Programme for Norfolk Vanguard covering a six-year period (2020-2025). The Construction Programme has been set out at Table 5.36 and has been broken down into high level tasks based on a two-phase programme including (within North Norfolk): • Landfall works (2022 to 2025) o Duct Installation (2022 to 2023) o Cable Pull, Joint and Commission (2024 to 2025) • Onshore Cable Route (2020 to 2025) o Pre-Construction Works (2020 to 2021); o Main Duct Installation Works (2022 to 2023); o Cable Pull, Joint and Commission (2024 to 2025); Section 5.4.15 of Chapter 5 – Project Description sets out the Indicative Offshore Construction Programme for Norfolk Vanguard and tables 5.24 and 5.25 set out the construction programmes for single and two phase programmes respectively, with a single phase spanning 23 months (Q2 – 2024 to Q1 - 2026) and two phase programme spanning Q2 - 2024 to Q1 - 2025 in the first phase and Q2 – 2027 to Q1 – 2028 in the second phase. Clarity over Construction timetabling is a matter that NNDC would seek to be considered further, as part of the examination process, in order that any adverse impacts of construction in a single or two phase programme can be properly understood and appropriately managed for the benefit of residents and businesses within the District. The decision by Vattenfall to commit to installing ducting for Phase 1 and 2 of Norfolk Vanguard and also ducting for Norfolk Boreas at a similar time is welcomed and will help reduce unnecessary periods of ground disturbance and help lessen construction impacts over a prolonged period of time. In North Norfolk, many local communities are dependent on the agricultural and tourism economy and the Council believes that the examination should explore how the project, and any grant of DCO, could reduce the maximum construction envelope down to an acceptable level. This may include specifying a maximum gap between the end of the first phase and commencement of the second phase so there is greater certainty regarding the actual construction programme. The Council believes the examination panel will also need to satisfy itself that the benefits of any landscape mitigation works are delivered as early as possible so as to make the impact of the works acceptable in planning terms. Method of bringing offshore cables onshore at Happisburgh NNDC welcomes the commitment from Vattenfall to bring the offshore cables onshore via the use of the horizontal directional drill (HDD) method. The commitment in particular to use the ‘long drill’ option for Norfolk Vanguard and Norfolk Boreas schemes is something the Council were seeking following the PEIR stage, primarily to reduce the potential significant adverse impacts from open trench construction on the stability of cliffs in the Happisburgh area. This area of North Norfolk in particular has seen significant loss of cliff in recent years due to the effect of coastal processes with an increased risk to life and property including numerous buildings of heritage interest. It will therefore be important for the examination panel to give appropriate consideration to the potential for the project to be affected by and/or contribute to coastal change and to consider any public benefits that can be derived either as part of formal mitigation or as part of any wider community benefits to manage those adverse impacts in accordance with the adopted Shoreline Management Plan (SMP 6). Based on the evidence seen to date, NNDC remains firmly of the view that HDD techniques (long HDD drill) are the most appropriate techniques to be used to bring the offshore cables onshore as this will have the least damaging impact on the nearshore, will result in fewer adverse impacts on coastal processes and will reduce the potential to destabilise the cliffs at Happisburgh compared to open trenching techniques. There still remains a need for more detailed discussion at examination stage including: • Decommissioning Phase – Whilst ES Chapter 5 – paragraph 5.5.2.9 identifies that the cabling can simply be pulled from the ducting for recycling, there should however, be recognition that as the coast erodes, there is a risk that the seaward, and, over the long term, landward duct and infrastructure will be exposed and will require removal. Currently there are no funded mechanisms for the removal of historical/redundant infrastructure as it is exposed via erosion and as such these burdens often fall to the Local Authority. Long term arrangements would be beneficial to ensure that such implications do not, through default, fall to future generations of local government. • Removal of existing redundant sea defences - The foreshore between Happisburgh ramp and Cart Gap is largely either open coast or protected by a sea wall and groyne field. At the point of interchange between open and defended coast are sections of remnant and largely redundant coastal defences which provide little or no protection. Such remnants significantly detract from the visual appearance of the beach area whilst also posing a potential hazard to beach/marine users. Further extents of such defences run to the North of Happisburgh village although this section is currently in a less deteriorated state and currently provides a level of erosion protection. Should opportunities arise during construction and it is agreed at a local level, the removal of these redundant structures could generate environmental gains, particularly if coupled with community based coastal adaptation initiatives (where applicable). • Use of spoil from cable construction - A further opportunity for community benefit exists at the western end return of the Cart Gap sea wall. This end section of seawall has suffered from cliff scour and a significant void between the cliff and defence is now present. Should appropriate locally generated clean spoil requiring disposal be generated during construction, it could be considered beneficial to reuse these materials to infill behind this sea wall. This would be subject to necessary licences but could prevent otherwise locally useful materials being transported longer distances for disposal and provide additional erosion protection in this location. Working Corridor of onshore cable route Following the announcement by Vattenfall of the decision to use HVDC transmission, the typical working corridor (temporary strip - total land requirement to install the cables) of the onshore cable route has been able to be reduced to 45m within which a 20m permanent strip (total ongoing land requirement of the installed cables) would be created The District Council welcomes the proposal by Vattenfall to include the laying of ducting for the Norfolk Boreas project at the same time as laying ducting for the Norfolk Vanguard project. This will, amongst other things, significantly reduce the disturbance time for land/soils along the temporary strip and will allow for earlier delivery of landscape mitigation. Whilst providing both sets of ducting at the same time may increase associated project traffic, the impact timeframe of works will likely be significantly reduced through economies of scale in delivery of the project rather than having to come back at a future point in time to deliver and install the Norfolk Boreas ducting. Use of Horizontal Directional Drilling (HDD) onshore NNDC welcomes the use of Horizontal Directional Drilling (HDD) techniques so as to avoid sensitive or designated sites so as to minimise any potential impacts upon them. Figure 5.04 within Environmental Statement Volume 2, Chapter 5 – Project Description sets out in some detail the intended locations for Hydraulic Directional Drilling including six locations within the North Norfolk area. The Council believes it will be important at examination stage to ensure the correct HDD methods have been chosen along the onshore cable route and to ensure no other opportunities for use of HDD methods in sensitive locations have been missed. Impact of construction traffic Within North Norfolk it is assumed that the main traffic generators connected with Norfolk Vanguard (and part installation of Norfolk Boreas) will come from construction traffic associated with: • Bringing the offshore cables onshore at Happisburgh; and • Construction of the cable corridor. North Norfolk has many small and narrow country roads with restricted widths and limited opportunities for larger vehicles to pass each other. Traffic levels vary but tourism during March to October (heighted during the summer months especially near coastal locations) means that the timing of any construction works will be critical to minimising adverse highway impacts. Volume 1, Chapter 24 of the Environmental Statement considers Traffic and Transport. Associated Figures 24.07 and 24.07a within Volume 2 set out the various sections of the cable route and the location of mobilisation areas affecting North Norfolk and Figure 24.09 sets out proposed HGV routes serving the proposed stages of construction. Within North Norfolk’s area are the following sections (and associated reference numbers): • Section 13: MA8-E • Section 14: MA9-W • Section 15: MA10-W • Section 16 & 16a: MA10-E • Section 17a: MA10a-W • Section 17: MA11-W • Section 19: MA11-E Tables 24.13 and 24.14 set out the total HGV demand associated with ‘Duct installation and primary works’ and ‘Cable pull, joint and commission’ The environmental statement suggests that these tasks would generate approximately 67,433 HGV movements within North Norfolk. Whilst the Environmental Statement sets out that this is not a significant number of traffic movements, this may well not be viewed so by affected local residents and businesses. An Outline Traffic Management Plan has been prepared, the main purpose of which is to capture and secure the mitigation principles that, for the construction phase of the onshore elements of the project, are to be included in the final Traffic Management Plan (TMP) to be submitted pursuant to the discharge of relevant requirements of the Draft DCO. It will be important during the examination to ensure any likely adverse traffic impacts during the construction phase are properly captured and appropriately managed and mitigated through the TMP. Consideration will also need to be given to construction phasing and what will happen in the event of significant delay between first and second phases including construction compounds, temporary access routes and mobilisation works within North Norfolk. Landscape & Biodiversity Mitigation NNDC recognises that Vattenfall have undertaken desktop studies and Extended Phase 1 Habitat Surveys together with site specific surveys in accordance with best practice recommendations in order to inform the baseline data which underpin Environmental Statement Volume 1 Chapter 22 – Onshore Ecology and Volume 1 Chapter 23 Onshore Ornithology. Statutory and Non-Statutory designated sites are recognised within Figures 22.02 and 22.03. However, the ES recognises that not all areas have been surveyed in setting out potential impacts and cumulative impacts. Environmental Statement Volume 1 Chapter 29 considers Landscape and Visual Impact Assessment. The LVIA assesses the potential impacts of the project on landscape elements, landscape character and visual receptors within the study areas, including the likely impacts of the onshore components of the landfall and onshore cable route (most relevant to North Norfolk). A Schedule of Mitigation has been provided included those related to Onshore Ecology, Ornithology and LVIA matters which specify the measures proposed, the effect of mitigation and means by which it will be implemented. It will be important during the examination to ensure any likely adverse impacts relating to landscape and biodiversity interests are properly captured and appropriately managed and mitigated through the DCO requirements. Consideration will also need to be given to the timing of enhancement/mitigation works, particularly in view of the potential for the project to be split in to two phases. Community Benefits In respect of potential community benefits, NNDC recognises that the DCO process has to work within the sphere of planning law and under the notion that planning obligations should only be sought where they are necessary to make the development acceptable in planning terms; directly related to the development; and fairly and reasonable related in scale and kind to the development. NNDC recognises that, once built, the scheme is likely to be relatively benign. However, the authority believes that it is important that the proposals sufficiently address any harmful impacts associated with construction including potential damage to coastal areas, loss of trees and hedgerows along and associated with the cable corridor, damage to roads and verges from traffic together with consideration of harm to the economic prosperity of businesses affected by any extended or multi-phased construction activities. The Council believes it will therefore be important for the examination panel to carefully consider and understand the package of CIL compliant benefits being put forward by Vattenfall as part of the consent process and how those benefits would be secured. Outside of the DCO process, North Norfolk District Council will seek to negotiate with Vattenfall to secure a range of benefits for the wider community of North Norfolk. Summary Whilst NNDC is supportive of the principle of the Norfolk Vanguard (and Norfolk Boreas) offshore wind developments being proposed by Vattenfall, the Council believes it will be important to ensure the project(s) are managed and delivered in a way that does not result in significant adverse impacts on local communities and businesses close to the landfall and along the onshore cable route. The commitments already made by Vattenfall to use DC transmission, the use of long drill options to bring cables onshore and the commitment to installing ducting for the Norfolk Boreas scheme as part of the Norfolk Vanguard scheme help significantly reduce the size of the project envelope. This means that the scope of the examination process will be far simpler and easier to manage for all parties concerned and there is therefore greater clarity about the proposals and increased confidence that an acceptable DCO outcome can be achieved for the residents, businesses and communities of North Norfolk. Detailed conditions are required to ensure construction and operational noise are controlled so as to meet noise control targets within the Environmental Statement. Construction noise impacts and any complaint resolution will require comprehensive and well resourced complaints procedures to resolve complaints and ensure the provision of suitable mitigation. In particular, the Swafield Road area has been highlighted as being affected by the construction phase and assurances are sought on mitigation measures here. Operational noise impacts have been highlighted. Details of the effectiveness of mitigation measures should be submitted to enable assessment and coment in terms of both their term effectiveness and long term maintenance. North Norfolk District Council look forward to being engaged in the examination / DCO process moving forward and, in addition to the high level topic areas set out in this response, will also look to establish and agree how matters requiring discharge through subsequent planning conditions would be undertaken and by whom. Yours sincerely Geoff Lyon Major Projects Manager "
Members of the Public/Businesses
Phil Hayton
"1) From the outset Vattenfall’s flawed public consultation has been a mixture of obfuscation and half-truths including misleading illustrations of the development sites that were not in Necton at all! 2) The decision to make Necton the chosen spot for the largest development of this type in Europe was made many years ago without local consultation. Had we been asked we would have pointed out how little room is actually available between the archaeology and the radioactively contaminated plane crash site for a development of this size leaving no possibility for future expansion if needed. 3) The area chosen is capped by a thick layer of impervious clay that soon defies any attempts at drainage other than the natural topography via a small stream that becomes a raging torrent within minutes of any storm and consequently floods the road downstream, blocking the 4’ culvert and inundating the properties. 4) The area chosen is also the highest area of the parish making it almost impossible to screen the industrial development from view and making it impossible to avoid the light pollution from the many very high buildings planned. The existing Dudgeon sub-station ignored the Horlock recommendations and our request to avoid shiny silver reflective component’s and bright unfocussed lighting outside so we suspect Vattenfall/Boreas will do the same? 5) Vattenfall’s submission fails to account for the negative impact it will have on the two campsites and the five holiday let businesses within eyesight and earshot that appears to have been missed completely. 6) I have serious doubts that the noise constraints required by statute can be met when the three sub-station’s Dudgeon, Vattenfall & Boreas are all working at full capacity and because of the height of the chosen site mitigation measures will be difficult and expensive to design and build so we ,the parish, suspect they will be ignored. 7) The area chosen is close to an area of natural woodland with several species of bat and reptile not to mention the hedgehogs that appear to have been missed? 8) Following the flawed consultation I am not convinced that adequate measures to avoid fire from the arable crops have been considered, hedges and fences are inadequate on their own without firebreaks, substantially increasing the amount of land required. 9) A major infrastructure project such as this is a vulnerable target for the disaffected terrorist and the chosen site close to the edge of a wood makes it difficult to defend. In consideration of the points above I as a resident of Necton would like you to ask Vattenfall and The National Grid to consider alternative sites that they have so far neglected to do in any meaningful way so we may return to being a small rural community with little noise or light pollution. "
Members of the Public/Businesses
Lucy Sheringham on behalf of Ros Wright
"Objections Unsuitable site affecting 5 villages and very close to peoples homes Extending an already very large and visible substation on a hill visible for miles on a very bad site. Unnecessarily bringing a cable 47km inland destroying trees, hedges, wildlife habitats and soil damage Unsuitable access from the A47. None of the access points highlighted by Vattenfall are suitable Marine cable seems the obvious solution which other wind farms can ‘plug into’ in the future. Vattenfall’s consultation process was flawed - Providing misinformation to the public - No alternative sites or a marine cable were even looked at "
Members of the Public/Businesses
Susannah Spain
"In 1996 there was an F16 plane crash that contaminated the cable run route selected by Vattenfall to the National Grid substation at Necton. Vattenfall were informed about this event, and the presence of environmental contamination as a result, in the public consultation sessions but it was ignored. Vattenfall were then informed officially by Norfolk County Council, in the person of [Redacted], on 5th June 2018. This was in plenty of time for it to be included in the DCO application but it was not. The consultation undertaken by Vattenfall was flawed because they ignored information given to them and in particular they did not tell the truth when they said they did not know about the plane crash and therefore could not include it in their environmental report. According to MOD documentation, the contamination includes radioactive substances. Theis can be extremely expensive to remediate and high risk both to the persons carrying out the work and the local population if not done correctly to UK standards. It should not have been left out of any suitable and sufficient application for planning permission. There should be no possibility of Vattenfall starting any groundwork before the position of all radioactive substances have been pinpointed. In a plane crash, this can be spread over a large area that should not be disturbed until permission has been given by the Environment Agency. Suitable remediation plans covering the actual risk, together with agreement in principal by the Environment Agency for the construction work to go ahead, should be required before this particular DCO is accepted as carried out with due diligence for the Necton infrastructure. "
Members of the Public/Businesses
Sydney McNeil
"I object to the installation of the substation by Vanguard on the grounds that no thought has been made for the wildlife that exists or the farm land that needs protecting from an eyesore that will be the product of this proposal. Because of the rural nature of the area it would be more prudent to place such a substation where there already exists an industrial area which would blend in with an already similar area. This area has already seen the installation of a substation for the National Grid on ground that is all too evidently rural and the concreting over of well over 48 acres of land will constitute a disaster for wild life in the area as well as curtail much needed farming as our population grows and will add to flooding which naturally occurs in this area with a threat to nearby inhabitants. Despite being designed to provide electricity to a growing population this installation will destroy vast swathes of land disrupting local wildlife and farming areas as the necessary pipes laid across a considerable acreage of Norfolk. I therefore object to the substation being built at the proposed site because as an environmentally aware person, I cannot equate the support of an environmental argument that the Wind Turbines placed in the sea will be better for the environment that a nuclear station as the substation proposed ruins the environment. "
Members of the Public/Businesses
Lucy Sheringham on behalf of Thomas Bart
"Objections Unsuitable site affecting 5 villages and very close to peoples homes Extending an already very large and visible substation on a hill visible for miles on a very bad site. Unnecessarily bringing a cable 47km inland destroying trees, hedges, wildlife habitats and soil damage Unsuitable access from the A47. None of the access points highlighted by Vattenfall are suitable Marine cable seems the obvious solution which other wind farms can ‘plug into’ in the future. Vattenfall’s consultation process was flawed - Providing misinformation to the public No alternative sites or a marine cable were even looked at "
Members of the Public/Businesses
Lucy Sheringham on behalf of Tony Wright
"Objections Unsuitable site affecting 5 villages and very close to peoples homes Extending an already very large and visible substation on a hill visible for miles on a very bad site. Unnecessarily bringing a cable 47km inland destroying trees, hedges, wildlife habitats and soil damage Unsuitable access from the A47. None of the access points highlighted by Vattenfall are suitable Marine cable seems the obvious solution which other wind farms can ‘plug into’ in the future. Vattenfall’s consultation process was flawed - Providing misinformation to the public -No alternative sites or a marine cable were even looked at "
Members of the Public/Businesses
Brown & Co on behalf of Trustees of the Bawdeswell Settlement being David Gurney, David Brown, Kate Paul, William Barr
"Our client has been in proactive discussions with Vattenfall, however these matters are not concluded and therefore the outline representations are detailed below having been prepared by the NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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. "
Members of the Public/Businesses
Brown & Co on behalf of Trustees of the Gurloque Settlement
"Our client has been in proactive discussions with Vattenfall, however these matters are not concluded and therefore the outline representations are detailed below having been prepared by the NFU and LIG. IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE NORFOLK VANGUARD 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 Vattenfall 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 Housing, Communities and Local Government identified as the Norfolk Vanguard 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 month further specific details have been requested in regard to the build and these have not been forthcoming yet. For example details on timings of construction to be able to understand the impact on the cropping rotation of the farm or the commercial shoot over the winter months. Therefore it has not been possible to discuss all aspects of the scheme in detail. 2.2 Due to the lack of specific information there has been no progression in negotiations in the last month during September 2018. 2.3 Further specific detail has been requested from Vattenfall on soil management during construction, access routes shown on the plans submitted with the heads of terms, and in particular on how the location for the substation was chosen. 2.4 Vattenfall has still not sent out a draft option and easement to the agents or landowners following requests for these documents. It is imperative that the NFU and agents acting (LIG) see these documents to make sure that the terms are reasonable and follow what has been agreed in the heads of terms. 3.0 Compulsory Acquisition and Compelling Case Requirement 3.1 The DCO will contain powers to acquire compulsorily so much of the Order Land as is required for the authorised development, or to facilitate or is incidental to it. 3.2 Further, the guidance as to negotiations either before or parallel with formal processes may well give rise to a "legitimate expectation" that such will occur, and a failure to conduct such negotiations deprives landowners of the benefit that negotiations may have brought, especially in relation to the where different locations and lesser rights might have been achieved. 3.3 The NFU and the land agents LIG believe that no meaningful negotiations have taken place in regard to the site for the converter substation and the access routes. Therefore a compelling case as yet cannot be made. 4.0 HVDC Cables and Converter Substation 4.1 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. 4.2 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 19m high. 4.3. 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. 4.4 Questions have been raised as to why the substation 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. 4.5 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. 5. Construction and Funding 5.1 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 construction will take place 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. 5.2 We understand from Vattenfall that they do have the funding required for both schemes but confirmation on this is sort. 6. Cumulative Impact 6.1 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. 7. Jointing bays and Link Boxes 7.1 It is understood from other projects that ‘Jointing Bays’ should be all underground and will not interfere with agricultural operations. 7.2 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. 8. Field Drainage 8.1 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 but it is not satisfactory. 8.2 To date insufficient detail has been received by LIG on behalf of their clients and members in regard to how reinstatement of field drainage will take place. 8.3 No information has been provided as to where the detail on how field drainage will be reinstated is covered in the documents which form part of the DCO application. As no draft option and easement has been made available it has not been possible to see whether drainage reinstatement is covered satisfactorily in the proposed option and deed. 9. Soils 9.1 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 does not know how soil reinstatement and aftercare will be dealt with in the Option or Deed. Further no information has been provided as to how soil will be reinstated or the measures that 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. 10. Flood Issues 10.1 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. 11. Dust/Irrigation 11.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 12. Access routes to the Order Limits 12.1 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. Further a lot of access routes have been highlighted and agents are not actually sure that all of these access routes are needed. 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. 13. Access to land and the Haul Road 13.1 Insufficient detail has been provided as to how landowners and occupiers are to access land severed by the construction works and as to whether landowners will be able to access the haul road during construction. Further no detail has been provided on how the haul road may be constructed and if it is possible to use tracking for the haul road which can be laid on the surface of the land and taken up. No specific detail has been given on the time the haul road will be down severing land. Is it to be down for the construction period of 2 years and then will it be taken up and then re-laid for a further 2 years when the Boreas scheme construction starts? 14. Request to Attend Hearings and make Representations 14.1 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. 14.2 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. "
Members of the Public/Businesses
Wendy McNeil
"The objection that I have to this proposed installation, is that having lived in the village of Holme Hale for the past 13 years it is the very rural nature of the area in which our village is situated and that of surrounding villages which appears not to have been taken into consideration when submitting the application to the inspectorate by Vanguard. The consultation period which also included some meetings with local groups, individuals and Parish Councils did not once consider the way in which the installation would impact upon local communities and offered no alternative sites for consideration. Having spoken to the person who purported to be an environmentalist at a meeting representing Vanguard, there was no understanding from the company of how visible the site would be to the rest of the communities as apart from the talk of planting to hide the site (which in my opinion looking at the present National Grid substation with similarly suggested planting would not hide the proposed Vanguard substation for at least 20 years, perhaps more, there was no intention of moving the substation to a more suitable location where it would not be viewed by local villagers. Therefore my main objections are that no other sites were proposed and therefore we must assume that this site was chosen a long time ago, well before the community was advised of the proposed substation for Vanguard/Vattenfall and therefore the consultation period was flawed. Also that the rural nature in which the installation is to be sited is not suitable for purpose."