Norfolk Vanguard

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Norfolk Vanguard

Received 16 September 2018
From 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 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.

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