“Please see below my response to the proposed Morgan & Morecambe Offshore Wind Farms : Transmission Assets, as invited in the consultation brochures. I have studied some of the handout documents namely; “Morgan and Morecambe Offshore Wind Farms: Transmission Assets: Statutory Consultation Brochure Oct 2023” : (SCB) “Morgan and Morecambe Offshore Wind Farms: Transmission Assets: Preliminary Environmental Information Report Oct 2023” : (PEIR) Plus Documents and Figures from the Project website. Firstly, can I say that the brochures show minimal information regarding the visual impact of the Transmission assets. There are many photographs of wind turbines but not a single photograph, artists impression or visualisation of the transmission assets / substations. On page 4 of the SCB, we are told EnBW and Flotation Energy are pioneers in offshore wind power and operate numerous offshore wind farms. Why then can you not give specific details and example photographs of the transmission assets? This total lack of transparency undermines the effectiveness of the consultation process and inhibits the understanding by the local community of the impact of the project. Without such basic information surely this “Statutory” consultation process must be null-and-void. There has been no obvious process outlined for the selection of the candidate sites for the substations. How many sites from the Blackpool Landfall to the Penwortham National Grid Substation Penwortham (NGSP) were considered (other than the 4 Zones subsequently documented)? For example, in your heat mapping exercise (shown in Figs 4.22a and 4.22b covering Topography, Utilities, Flood Risk, Overhead Lines, Protected Areas, Residential Properties and Roads) the summary Heat Map “Combined Heatmapping” shows the area just north of the river Ribble as a green “More Suitable” area. This land is not farmland but is waste / industrial brown field and has no impact on residential property. Why was this “More Suitable” area not considered at all? The SCB has many motherhood statements but no details to substantiate them and again falls below the requirement for a Statutory Consultation. For example, Pages 6 and 31 of the SCB talks about local employment. What employment opportunities will be afforded locally once the substations are operational? Can you give examples? Page 21 of the SCB states the size and positioning of the substations is still being developed. How can you undertake a Statutory Consultation when the basic details have yet to be defined – particularly the size of the substations? I understand the basic design has yet to be decided – Air Insulated Switchgear (AIS) versus Gas Insulated Switchgear (GIS). Given the differences in footprint, noise, safety and aesthetics, will GIS be the preferred option or will AIS be installed to save on cost? Surely the basic design should have been finalised before embarking on a Statutory Consultation. Can you confirm how the two designs would impact the size and visual appearance of the proposed substations by providing artists impressions or visualisations and give an indication of which design you are favouring? Does the consultation process give the local community a say in the design, given the significant differences in aesthetics they present? It is clear there are two companies involved in producing power from the offshore wind turbines, but why can the power not be routed through one combined substation thus reducing the size and disruption to the environment? After all, when it gets to Penwortham the power is combined when fed to the National Grid. The original proposals included sites in two Zones (3 & 4) adjacent to the NGSP. These options have been quickly dropped for reasons that are questionable. In Section 4.10.1 “Identification of Onshore Substations Search Area”, clause 4.10.1.2 mentions an 8 km buffer zone around the NGSP – what does this mean? Do the substations have to be within 8 km or are they excluded from the buffer zone? Why 8km – what is the relevance of this distance? Table 4.1 of PEIR states the maximum length of onshore cables is 25 km and the NGSP is 19km from the landfall at Blackpool so why not run the cables to Zone 4 next to the NGSP? Zone 4 already has electricity assets in the Zone and routing the cables to substations in this area would mean no cables or assets above ground within the Fylde. Clauses 4.10.1.3 and 4.10.1.4 specifically reference avoiding existing settlements and residential areas around Penwortham, Longton, Walmer Bridge, Hutton and New Longton but there is no reference to existing settlements north of the river Ribble, for example Kirkham, Freckleton and Newton-with-Scales. Why is it imperative to avoid South Ribble settlements and not Fylde settlements? Indeed, there are few significant, immediate population centres near Zone 4. Hutton is approximately 1000m away and Longton 1800m distant, unlike the proposed location in Zone 1 which is surrounded by villages and towns – namely Kirkham (400m to the North), Newton-with-Scales, (450m to the East), Freckleton (450m to the South) and Lower Lane (150m to the West). Table 4.13 – Summary of the Red, Amber, Green (RAG) Appraisal, appears to be working backwards to define Zone 1 as the preferred option, then Zones 3 and 4 colour coded to generate the desired result. It is also not clear how the scoring for R, A or G has been determined and whether some criteria have a higher weight than others. For example, weight seems to have been given to the fact that Zones 3 and 4 (adjacent to the NGSP) are near a Special Protection Area (SPA) – however these two zones are NOT in the SPA and therefore this is completely irrelevant. Zone 4 is also coloured red because there were a few “farmland” birds in the area and, whilst Zone 1 and Zone 4 both have hedgerow and mature trees, Zone 4 has been coloured Red while Zone 1 has been coloured Amber. Page 27 of the SCB states that Zones 3 and 4 are “rich” in sensitive habitats that support numerous protected species of birds – yet the RAG assessment identifies a few farmland birds and waders. If there is no specific designation for protection of wildlife, then there are not enough important species to prevent development and the land is no different to any other land. For the Criterion “Planning Policy and Future Development Potential” it has been recognised that Zone 1 is in a designated Green Belt but no cognisance that the area is designated as an “Area of Separation” in Strategic Policy GD3 of the Fylde Local Plan. The reason for the designation of this location as an Area of Separation is to protect the rural characteristic of the Fylde and to make sure that Newton with Scales and Kirkham do not merge together. The main reason for selecting Zone 1 is the supposed ease of transport access (a fact which was substantiated during discussions with Project personnel in the “Statutory” consultation meetings held in November) and specifically highlighted on Page 27 of the SCB where access to main highway networks is a reason for selecting Zone 1. The A583 however is a high-speed (50mph) highway and there have been many Road Traffic Accidents over the years including fatalities. While access seems easy, traffic movements during construction would be problematic and hazardous. By comparison, Zone 4 borders the main trunk road A59 and there is paved access to Zone 4 at What3words smiled.files.civil (off Walton Gardens road) which is only 430 m from the A59. Traffic speed is slower in this area (40mph limit) but in practice is much slower due to the calming nature of the Hutton Roundabout. Why therefore has Zone 4 been coloured Red when access is easy and traffic speeds are much lower than Zone 1? Again, there is a lack of transparency in how accessibility has been assessed. So, to summarise, whilst assessment of a zone’s suitability considers the potential impact on ecology and ornithology and its proximity to a main road, there appears to be little consideration for the impact on the humans living in the settlements in the Fylde and the main reason for choosing Zone 1 appears to be the spurious assertion that road links are better. Throughout the process there has been a repeated lack of transparency of the selection of sites for the substations. Such a lack of tangible information undermines the ability of the community to assess the impact of the project and therefore it is my opinion that the whole assessment procedure is flawed and should be subject to formal review. I note that Clause 5.1.5.5 states “Feedback and local knowledge provided to the projects will continue to be reviewed and considered as part of the route planning and site selection process”. I am sure you will agree that feedback from myself and the numerous other respondents reinforces the need to reconsider the location of these substations and locate them in Zone 4 where there is already considerable electricity infrastructure.”