North West Coast Connections Project – N Grid

The list below includes a record of advice we have provided for this project. For a list of all advice issued by the Planning Inspectorate, including non-project related advice, please go to the Register of advice page.

There is a statutory duty, under section 51 of the Planning Act 2008, to record the advice that is given in relation to an application or a potential application, including the name of the person who requested the advice, and to make this publicly available.

Preview
Enquiry received via post
response has attachments
See attached letter
I note you acknowledge that National Grid has paused its work on the North West Coast Connection project and as the project has not yet been submitted to the Planning Inspectorate (the Inspectorate), we have no formal powers to intervene on consultees behalf. However the Applicant has a statutory duty to take consultation responses into account and, if the application is submitted to us, part of our compliance checks are to ensure the consultation has been conducted properly.

With regard to your concern about the timeframe for the Applicant’s response to nopylons’ alternative proposal for an offshore route from Selker Bay to Walney, this is something the Applicant may respond to in their Consultation Report, which would be submitted to the Inspectorate as part of the application documentation. The Applicant has stated in their Scoping Report that a description of the alternatives considered, and an explanation of the decisions taken, will be provided within the Environmental Statement, which will also be submitted as part of the application documentation. The Examining Authority can also request the Applicant’s view on nopylons’ proposal during the Examination, if they consider it relevant to their examination of the application.

A copy of your correspondence has been placed on our records and will be presented to the Inspector at Acceptance, together with the application documents and local authorities’ comments on the Applicant’s consultation.

After the decision has been made regarding whether to accept the application for Examination all documents used to inform the decision will be published on our website.

If the application for development consent is formally accepted you will be able to submit your views in relation to the project which will be considered by the Examining Authority during the Examination.

The Inspectorate has published a series of advice notes which explain the Examination process, including information on how to get involved; of particular interest are advice notes 8.1 to 8.5. These are available at: [attachment 1]

We also recently published a Frequently Asked Questions document regarding Pre-application consultation and this can be viewed on our website here: [attachment 2].

20 September 2017
C A Rowntree
Enquiry received via email
response has attachments
Questions Raised by the Parish Council Coordination Group for consideration by the Planning Inspectorate
See attached response

04 April 2017
Parish Council Coordination Group - David Savage
Enquiry received via email
Query regarding alternatives
Many of the points in your email are addressed by [advice given in response of 6 February 2017], although I appreciate that you have identified certain specific pieces of information that you would like National Grid to provide. I have notified National Grid of the concerns you raised in your response.

As I explained, Applicants should provide enough information to allow members of the public to participate in their consultation activities, but are not required to provide or produce information purely because other parties have requested it to support their submissions. As previously noted, further policy on the consideration of alternatives can be found in National Policy Statement EN-1, Section 4.4.

I do not know if National Grid hold the information that you have requested, and since we have received no application as yet, I cannot say if that information will be submitted at the examination. However once an application has been made and if it is accepted for examination, it is open to you raise issues regarding this with the Examining Authority.

Before accepting an application, the Planning Act 2008 requires that the Secretary of State must be satisfied that the Applicant’s pre-application consultation has complied with the provisions in the Act and that the application is of a satisfactory standard to be examined. As part of this we will consult local authorities and consider any representations received by those authorities as to whether the applicant has complied with sections 42, 47 and 48 of the Planning Act 2008.

20 March 2017
Power Without Pylons - Graham Barron
Enquiry received via meeting
response has attachments
Update in relation to the North West Coast Connections Project
See attached meeting note

14 March 2017
National Grid
Enquiry received via email
Please find attached Friends of the Lake District's consultation response to the recent National Grid consultation on its PEIR for the North West Coast Connections Nationally Significant Infrastructure Project.

I would draw your attention to the significant failures in the consultation. These are due to
A: National Grid’s apparent misinterpretation of the EIA regulations and national planning policy on the setting of the Lake District National park; and

B: on restricting mitigation only to those areas of landscape and visual impact receptors which would suffer “Particularly significant effects” rather than “significant effect” as laid out in the EIA (Infrastructure) Regulations 2009.

C: Not enough ecological information provided to undertake a Habitats Regulations Assessment and the possibility that because there are alternative solutions (e.g. offshore), that the IROPI test would not be met under Article 6.4 of the Habitats Directive 1994.

We are also concerned that the costings for alternative route options which would avoid the issues raised above are not adequately described and evaluated in the consultation. Our concerns align with those of Ofgem whose current consultation on “North West Coast Connections – Consultation on the project’s Initial Needs Case and suitability for tendering” also raises these concerns when it states

However, we consider that the decision between NGET’s favoured use of a tunnel under Morecambe Bay and an alternative approach of using subsea cables around the bay is relatively finely balanced. We have concerns that significant changes in the cost of the tunnel, or additional work identified through the planning process [e.g. having to mitigate for impact on the National Park setting] could indicate in the future that the subsea cable option could be better value for consumers.

I would like to know what role PINS has in raising these issues with National Grid and whether they would prevent an application to PINS from “meeting the required standards to proceed to examination, including whether the developers consultation has been adequate” (PINS Advice note 8.1)
Thank you for your enquiry regarding National Grid’s recent consultation on the proposed North West Coast Connections Project.

Prior to commencing consultation, the Applicant is required to under section 47 of the Planning Act 2008 (PA2008); prepare a consultation strategy known as the Statement of Community Consultation (SoCC) and to seek agreement on their strategy with the relevant local authorities (i.e. those authorities whose administrative areas the route alignment would pass through). The Applicant has a duty under Section 49 of the PA2008 to take account of responses to consultation. All applications must be accompanied by a Consultation Report. In this document the Applicant must show that they have complied with the statutory pre-application consultation requirements, and that they have had regard to the responses.

The duty to consult on preliminary environmental information (PEI) derives from Regulation 10 of the Infrastructure Planning Environmental Impact Assessment (EIA) Regulations 2009 (as amended)(the ‘EIA Regulations’). Regulation 2 of the ‘EIA Regulations’ defines PEI as “information referred to in Part 1 of Schedule 4 which—
(a) has been compiled by the applicant; and
(b) is reasonably required to assess the environmental effects of the development (and of any associated development)”

The Planning Inspectorate’s Advice Note 7 “Preliminary Environmental Information, Screening and Scoping” states that “PEI is not expected to replicate or be a draft of the ES. However, if the applicant considers this to be appropriate (and more cost-effective) it can be presented in this way. A good PEI document is one that enables consultees (both specialist and non-specialist) to understand the likely environmental effects of the proposed development and helps to inform their consultation responses on the proposed development.”

Upon submission of an application the Planning Inspectorate will write to relevant local authorities and ask for their views on whether or not the consultation has been adequate, if you have concerns regarding the adequacy of the consultation process in your area, you may therefore wish to contact the relevant local authorities, highlighting your concerns, so as to inform their adequacy of consultation response. At acceptance, the Planning Inspectorate will consider the Consultation Report, alongside any adequacy of consultation representation made by a local authority and the other application documents, before deciding whether or not to accept the application for examination in line with Section 55 of the PA2008. Appendix 3 of the Planning Inspectorate’s Advice Note 6: “Preparation and submission of application documents” sets out the information considered prior to accepting an application, which includes in section 3.3(a) “where applicable, the environmental statement required under the EIA Regulations and any scoping or screening opinions or directions” therefore the adequacy of any environmental impact assessment is a consideration for acceptance.

Until an Application is submitted to the Secretary of State for consideration, the Planning Inspectorate would not comment on whether an Applicant has met the required standards to proceed to examination, including whether the Applicant’s consultation has been adequate. We would strongly encourage you to continue to engage with the Applicant, feeding any concerns that you may have with either the assessment process or the consultation process to them and with the relevant local authority.

22 February 2017
Friends of the Lake District - Kate Willshaw
Enquiry received via email
response has attachments
Power Without Pylons is concerned with the southern element of the NWCC connection, from Moorside to Heysham. National Grid (NG) has announced some undergrounding in the Lake District National Park, but still proposes to construct giant 50m pylons just outside the Park, in particular around the Duddon Estuary.

We have some questions for PINS regarding alternatives:
1. At the forthcoming planning enquiry, will objectors be able to raise the question of alternative options?

2. What are your criteria for allowing the discussion of alternatives?

3. Will we be allowed to discuss all possible alternatives, or just those that have already been considered by NG, or just those that have been proposed in a consultation?

4. We have assumed that this discussion will be possible, and have therefore tried to obtain as much information as possible about the different options. However, we have not had sufficient co-operation from NG and other relevant organisations. It would seem to us that, as part of a democratic process, the applicant should be obliged to provide relevant information. We also need to have this information as soon as possible. Do you have the power to ensure that we are given all the relevant information that we have requested?
Please see attached response

06 February 2017
Power Without Pylons - Graham Barron
Enquiry received via meeting
response has attachments
Project update meeting with National Grid concerning the proposed North West Coast Connection project
See attached meeting note

26 January 2017
National Grid
Enquiry received via post
I am writing to complain over the soon to be planning application that National Grid will be submitting to you.
We do not accept pylons between Drigg and Seascale. We do not accept the line being moved west closer to Stubblegreen. We do not accept that part of our village is to be underground cables and that our area, Stubblegreen, is to have pylons moved closer to our homes.
We will not accept this.
Our area has one of the best views in the western area of Cumbria a full 180° view of the Western Lake District fells, pylons in this would destroy the amenity value of our area. Detrimental to tourism both in and out the park.
Nugen the private company behind Moorside is paying nothing towards the National Grid upgrade. It should be paying for undergrounding all the way. In particular the southern route as this effects the National Park.
The Lake District National Park is currently in a bid for World Heritage Status. Pylons will destroy the beauty of the park both looking out and looking into the park in our area in particular.
We urge you to visit our area and do not allow pylons to destroy our area.
Moorside could and should be put in a location where road and grid infrastructure already exists such as Heysham. It will not provide local jobs. Nugen has already stated 4000-6000 workers will need to be brought into Cumbria.
Please protect our area.
We are not able to comment on your views about the project itself as the Planning Inspectorate must remain impartial in order to protect the interests of all parties that may participate in any future examination of an application.

It is for National Grid to design their project and justify it in their application for development consent. Part of this may include providing adequate information about why alternative design solutions were discounted at earlier stages of the project evolution. Like any other private or public organisation or individual they have a right to make an application for development consent. It is at their own risk if they submit an application that is not fully-formed, justified or mitigated properly using the views and information gathered at the pre application stage, and as a result falls short of gaining development consent.

I can assure you that if the application is accepted for examination, the appointed Examining Authority will carefully scrutinise the proposals and test it against the relevant National Policy Statement on electricity transmission infrastructure. In broad terms, the role of the Examining Authority will be to weigh the impact of the proposals against the Government’s policy on new transmission lines. The recommendation made by the Examining Authority to the Secretary of State about the project will be evidence based, taking account of all matters they decide are relevant and important. The Secretary of State (an elected Minister) will make the final decision about whether or not to grant development consent. The examination is held in public and all documents and any oral evidence provided and submitted to the Examining Authority is published during the course of the examination.

Anyone can participate in the examination by registering a relevant representation at the appropriate time. If you would like to be notified about the formal events that take place after the application is submitted then please enter your email address in the Email Updates section of the North West Coast Connections project page of the National Infrastructure Planning website.

09 January 2017
Sadie Clarke
I have grave concerns about the way in which these consultations have been structured. A national PRIVATE company (National Grid) wishes to put a major infrastructure in place. They hold ‘consultations in areas that might be affected’ but actually tell the surrounding communities what their preferred option is. They then take initial consultations which result in overwhelming support for an offshore option. This private company (NG) then reveals it is to go onshore throughout the Lake District National Park, across the Duddon Estuary in the setting of the National Park and connect via a tunnel across Morecambe bay (protecting the communities of south Lakeland). They then revise their preferred option to ‘mitigate‘, undergrounding in the LDNP, while incredibly still saying they will connect a power line section onshore across the setting of the National Park. This private company then tells us the bottom line is they have already shown great consideration with undergrounding and a tunnel, and the pylons across areas of outstanding natural beauty and SSSI land do not have ‘particularly significant’ effects on the landscape. To summarise, a private company tells citizens of the UK and the people of the Lake District what it will and will not do regarding OUR landscape? Since when have the population in a democracy been told what they must put up with by a private company! We are the communities who live here. In a democracy the people who live in an area should be stipulating what can and cannot be done in areas of outstanding natural beauty.

Most importantly, the private company National Grid is allowed to collate, count and sort the responses that they receive from the public who have responded! There is no public scrutiny from those who have put time and effort into campaigning against these monstrous proposals. How is this democratic? These communities do not trust National Grid with their responses, since their overwhelming desire for an offshore connection when asked for their views was completely ignored in the first consultation and then justified later by saying it was not a viable option anyway!! In the case of a national infrastructure development proposed by a private company, why do we not have safeguards such an INDEPENDENT company or group collecting, collating and reviewing the responses, while at the same time being open to scrutiny. This is absolutely intolerable- it is looking like corrupt behaviour from an overseas dictatorship rather than a democratic open society such as we supposedly call ourselves. At the very least we should have our MP John Woodcock, scrutinizing the responses alongside other interested parties.
I can address your concerns about the pre application consultation process directly, however, the Inspectorate must remain impartial in order to protect the interests of all parties that may participate in a future examination of an application, if and when one is submitted. As such, I am not able to comment on your views about the project itself.

Past and present Governments’ policy on the provision of infrastructure has led to the current situation where energy infrastructure, including power stations and electricity transmission lines, are developed and owned by private companies, and regulated by government through Ofgem and other similar bodies. If you disagree with Government policy in this regard then you should contact your local member of parliament or write directly to the responsible government minister.

Its not unusual for private companies to carry out consultation in many walks of life. In doing so, they are required to act responsibly and in accordance with data protection legislation. The same is true of the consultation undertaken by National Grid in respect of this project. In this context it would not be appropriate for National Grid to share consultation responses sent to them with 3rd parties unless they are a public body that has a formal (legal) role in the application process, such as the Planning Inspectorate or Secretary of State.

The legislation that underpins the pre application process for nationally significant infrastructure projects is contained in the Planning Act 2008 and related regulations. In general terms, these set down a minimum standard that applicants must meet when consulting with local communities, technical bodies and others. When an application is submitted, the Inspectorate has 28 days to check the documentation and to make sure it is of a standard that is capable of being examined within the statutory 6-month timescale. One of the documents we will check is a Consultation Report. In this Report, applicants are required to document what consultation activity took place at the pre application stage and how they had regard to the views put to them. We will also ask for the views of the relevant local authorities about whether or not the consultation undertaken by the applicant was adequate.

The views collected by National Grid are primarily to assist them to develop and refine their proposals before an application is made. The applicant is not required to agree with all the comments or to amend their proposals, however, in the Consultation Report they are required to provide reasons about why they have or have not changed their proposals in response to the comments received. If the Inspectorate considers it necessary, we can ask an applicant to provide us with all the responses received during the pre application stage so that we can cross-check them against the information set out in the Consultation Report.

Ultimately, it is for National Grid to design their project and justify it in their application for development consent. Part of this may include providing adequate information about why alternative design solutions were discounted at earlier stages of the project evolution. Like any other private or public organisation or individual they have a right to make an application for development consent. It is at their own risk if they submit an application that is not fully-formed, justified or mitigated properly using the views and information gathered at the pre application stage, and as a result falls short of gaining development consent.

I can assure you that if the application is accepted for examination, the appointed Examining Authority will carefully scrutinise the proposals and test it against the relevant National Policy Statement on electricity transmission infrastructure. In broad terms, the role of the Examining Authority will be to weigh the impact of the proposals against the Government’s policy on new transmission lines. The recommendation made by the Examining Authority to the Secretary of State about the project will be evidence based, taking account of all matters they decide are relevant and important. The Secretary of State (an elected Minister) will make the final decision about whether or not to grant development consent. The examination is held in public and all documents and any oral evidence provided and submitted to the Examining Authority is published during the course of the examination.

Anyone can participate in the examination by registering a relevant representation at the appropriate time. If you would like to be notified about the formal events that take place after the application is submitted then please enter your email address in the Email Updates section of the North West Coast Connections project page of the National Infrastructure Planning website.

More information about the pre application process and future stages can also be found on our website.

03 January 2017
Edgar Busbridge
Enquiry received via email
response has attachments
Re National Grid North West coast connections proposals
I have great concern about the way in which these consultations have been structured. A major private company wishes to put a major infrastructure in place. They hold ‘consultations in areas that might be affected’ but do not publicise and inform the rest of the country? Why not? The Lake District is one of the most popular places in the country so it means millions of our own population visit it, these people would surely want to know if one of their favourite places to visit in the UK is to be decimated in this way? Surely it would be good practice to be required to share this information with the country- it is infrastructure of importance after all.
The consultation period was delayed twice in 2016. Yet no such extension period pro rata has been given to those who are being consulted. This means the overall time for responses to be in has been considerably shortened. The last consultation was around 8th December 2016 in Millom, so this community has less than 1 month to read and digest all the technical detail in all the vast number of documents. Is there any community or company that could do that so quickly?
At the initial consultation we had 3 options available. When the offshore connection was overwhelmingly chosen, this option was removed by saying it was not feasible!! How are private large companies like NG able to justify their behaviour in this way, within the ‘consultation’ exercise itself?
The response document is many pages long and highly complex with absurd questions such as Q6 appearing to act in a scare mongering way about the amount of money being spent, with no context of costs for each phase including the power station itself.NG also says anyone can respond but they make no effort to inform all those who visit or all those who might be interested in such developments. Children can respond but where is the child friendly document for all those future adults who will have to live with this decision?
Most importantly, the company NG is allowed to collect, monitor and grade the responses that they receive without scrutiny from the public who have responded. How is this democratic? No one in these communities trusts NG with their objections or their views (their overwhelming desire for offshore connections when first asked for their views were ignored despite this being one of the options available for the initial consultation) so why in this case of a national infrastructure development do we not have an INDEPENDENT company collecting, collating and reviewing the responses and at the same time being open to scrutiny re NG proposals. This is absolutely intolerable- it is equivalent to the Conservative or Labour party having the role of running the election.
Thank you for your email of 17 December regarding the pre application consultation undertaken by National Grid for the North West Coast Connections project.

We are responsible for administering the development consent process and for providing advice to members of the public and others about the process. If and when the application is submitted to us, we will formally request the views of the relevant local authorities about whether or not NG complied with the commitments they set out in their Statement of Community Consultation (SoCC). The SoCC is a document in which NG were required to explain the way in which they intended to consult the local communities affected by the proposals, including the duration of the consultation, the types of activities that were intended to take place and the geographical coverage of the consultation activity. NG were required to consult the relevant local authorities about their consultation methodology before implementing it. As such, if you have strong views about the way in which local communities have been consulted on this project we would advise you to forward these to your local authority who may use them to inform their representation to us about the adequacy of NG’s pre application consultation, at the time the application is submitted.

If and when an application is submitted to the Planning Inspectorate by NG we will check all the documents and plans to make sure they are of an acceptable standard and are capable of being formally examined. One of the documents we will check is the Consultation Report which should describe the consultation NG did before they submitted their application and to report on how they had regard to the views put to them by consultees. In checking the veracity of the Consultation Report, the Planning Inspectorate can ask NG to provide some or all of the responses provided to them by consultees. We can use these to check that the identification of issues in the Report is an accurate reflection of the views provided to them.

At the pre application stage, NG is required to publicise their proposals in local and national newspapers under s48 of the Planning Act 2008. The responses to this publicity also need to be included in the Consultation Report.

If you would like more information about the development consent process we have produced useful videos and written material on our website here:

[attachment 1]

20 December 2016
Lucy Gilbert
Enquiry received via email
response has attachments
Please find attached Weddicar Parish Council's representation on the NWCC Consultation. While teh council understand that the Planning Inspectorate will not consider comments on the proposed works at this time, we draw your attention to section 2: Adequacy of consultation statement. In this, we raise concerns about the duration of the consultation process given the size of the project. We would appreciate your consideration on these concerns.
Thank you for your email of 16 December regarding the pre application consultation undertaken by National Grid for the North West Coast Connections project. We are responsible for administering the development consent process and for providing advice to members of the public and others about the process.

If and when an application is submitted to us, we will formally request the views of the relevant local authorities about whether or not NG complied with the commitments they set out in their Statement of Community Consultation (SoCC). The SoCC is a document in which NG were required to explain the way in which they intended to consult the local communities affected by the proposals, including the duration of the consultation, the types of activities that were intended to take place and the geographical coverage of the consultation activity.

NG were required to consult the relevant local authorities about their consultation methodology before implementing it. As such, if you have strong views about the way in which local communities have been consulted on this project we would advise you to forward these to your local authority who may use them to inform their representation to us about the adequacy of NG’s pre application consultation, at the time the application is submitted.

If you would like more information about the development consent process we have produced useful videos and written material on our website here:

[attachment 1]

20 December 2016
Weddicar Parish Council - Ralph Mitchell
Enquiry received via meeting
response has attachments
Update in relation to the North West Coast Connections Project
See attached meeting note

08 December 2016
National Grid - anon.
Enquiry received via post
response has attachments
See attachment
see attachment

18 October 2016
Parish Council Coordination Group - D Savage
Enquiry received via meeting
response has attachments
North West Coast Connection project update
Please see attached meeting note

16 September 2016
National Grid - Richard Gwilliam
Enquiry received via email
National Grid provided their draft section 48 publicity notice and draft consultation report structure to the Planning Inspectorate for comment.
The following advice was provided.

Draft Consultation Report Structure:

It would be helpful if you could provide a summary table of all consultation and engagement undertaken (within part 5). For example, using similar headings to those used for the Richborough Connection project: Stage, When, What, Who.

There are some grammatical errors however we have not drawn attention to these as we are aware this is an early draft of the contents page/structure.

Should section 11 and 12 fall under section 10?

It is not clear where the s48 publicity will be explained and reviewed.

In regard to Appendices Part 10, are you proposing to include all responses received within the consultation report?

Are you intending on providing a list of those persons consulted during the non-statutory rounds of consultation?


Draft section 48 publicity notice:

The numbering requires review.

It would be helpful if National Grid could explain or provide an overview of the documents being consulted on (in addition to the PEI), see regulation 4(3)(e) of the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009 as amended.

Please state the cost (for receipt of copies of the consultation documents), as required by Regulations 4(3)(g) of the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009 as amended.

Could the language be clearer here regarding ‘Any response or representation in respect of the proposed Application’?

25 July 2016
National Grid - Richard Gwilliam
Enquiry received via meeting
response has attachments
Meeting with National Grid to discuss progress on the proposed North West Coast Connection project
see attached meeting note

22 July 2016
National Grid - Richard Gwilliam
Enquiry received via email
response has attachments
With regard to the issue of the timing of the Moorside and NWCC applications, I do wonder if both applications are submitted at the same time, whether there would be the possibility that Step 2 of the Aarhus Convention’s model on public participation in decision making may not be adequately met. This states:
“Reasonable time frames means allowing sufficient time for informing the public and for the public to prepare and participate effectively in the decision making” (see page 20 of this document [attachment 1] )

If the public and organisations such as ourselves are unable to participate effectively because of overlapping of written submission deadlines and hearing preparations for the two applications, then this would give rise to concerns that the consultation process was unfair because of time pressure and resource capacity. Preparation and involvement in one NSIP is a complex and time consuming process. Involvement in two at the same time, which are intimately linked to each other will be almost impossible for members of the public and small organisations such as ourselves who do not have the benefit of funding for resources via Planning Performance Agreements that the LPAs and statutory agencies have.

I would be grateful for PINS view on this.
In regard to whether there would be any breach of the Convention, I believe this would ultimately be a matter for the Aarhus Convention committee, therefore I would not be able to provide any comment on this.

We have previously asked the developers to consider the potential resource implications of submitting their proposals at a similar time, and I would advise you to raise your concerns directly with NuGen and National Grid.

The Planning Inspectorate must comply with the statutory deadlines in the Planning Act 2008 when accepting and examining an application, however when setting the timetable we will do our best to avoid overlap/clashes of dates where possible. The pre-application consultation stage is a fundamental part of the overall process and we would encourage Friends of the Lake District to engage fully in this process by commenting on the proposals prior to submission, we are aware that NuGen is currently undertaking its statutory consultation now, ahead of the National Grid statutory pre-application consultation phase.
If you have any further queries please do not hesitate to contact me

21 June 2016
Friends of the Lake District - Kate Willshaw
Enquiry received via email
response has attachments
I would like to raise a concern with you regarding the proposed timings for both the Moorside and the NWCC Examinations in 2017-2018. We are aware that NuGen is keen for both Examinations to run concurrently from March or April next year. This is going to put an inordinate amount of pressure on consultees who will be trying to deal with two of the largest infrastructure projects in the UK being examined at the same time. It is also likely to hinder proper public engagement in both of the examinations.

At Friends of the Lake District I am dealing with both of the consultation/Examination processes. If I am asked to provide relevant representations/written representations for both NWCC and Moorside at the same time, I will not be able to give either of them the attention that they need because I will be trying to deal with both. There is also the scenario that hearings may occur at the same time or close together meaning that my capacity for gathering evidence for those hearings or even appearing at them would be compromised.

I am also concerned that running the two Examinations at the same time will reduce the ability of the public to engage adequately in the process, and may also confuse members of the public about which NSIP is being dealt with.

There needs to be proper time separation of the two Examinations to enable stakeholders, consultees and the public to engage adequately. It needs to be a fair process and putting the burden of Examining two very large infrastructure projects at the same time on the people and organisations of Cumbria is very unfair.

I would be happy to discuss my concerns about the consultation timetables with you further.
We spoke at the Moorside Technical Group Meeting on 12th May and you asked to what extent the NuGen application and examination will review any potential effects resulting from the National Grid electric line connection, mainly regarding landscape and visual impacts.

Schedule 4 Part 1 of the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 (as amended) states the following information should be included in Environmental Statements:

‘A description of the likely significant effects of the development on the environment, which should cover the direct effects and any indirect, secondary, cumulative, short, medium and long-term, permanent and temporary, positive and negative effects of the development, resulting from:
(a) the existence of the development;
(b) the use of natural resources;
(c) the emission of pollutants, the creation of nuisances and the elimination of waste,
and the description by the applicant of the forecasting methods used to assess the effects on the environment’.

Developers are therefore required to describe the likely cumulative effects of the development within their applications. Therefore when commenting on the NuGen proposal during this current stage of pre-application consultation you may wish to view the preliminary environmental information report (for example section 3.4 of Technical Folder 1); and during the examination stage, the environmental statement, to comment on any potential cumulative impacts. The Planning Inspectorate has also published an advice note for developers proposing Nationally Significant Infrastructure Projects which provides guidance on the assessment of cumulative effects which is available here: [attachment 1]. It should be noted that this is only advice and it is not mandatory for any developer to follow it.

If the Moorside proposal was accepted for examination, the Examining Authority would also have to take the provisions of National Policy Statements into account, with regard to the cumulative landscape and visual effects from Moorside proposal and the North West Coast Connection.

Thank you for your email dated 17 May 2016, explaining your concerns regarding NuGen and National Grid’s intentions to submit their applications to the Planning Inspectorate at a similar time. We are aware of this and we have previously spoken to both developers and have asked them to consider the resourcing implications this may have on some parties. The Planning Inspectorate will allocate separate Examining Authorities for these projects if they are accepted for examination, and whilst we will aim to hold similar hearings for each project on different days, it is highly likely that the written submission deadlines will overlap if both projects are submitted around the same time. We will do our utmost to ensure that our correspondence is clear in highlighting to which project it relates.

26 May 2016
Friends of the Lake District - Kate Willshaw
Enquiry received via meeting
response has attachments
The Planning Inspectorate provided a presentation to the North West Coast Connection project local authorities.
Please see attached presentation.

11 May 2016
Local Authorities
Enquiry received via meeting
response has attachments
Joint meeting to discuss the Moorside Nuclear Power Station proposal and the North West Coast Connection project proposal.
Please see attached advice

14 April 2016
National Grid and NuGen - anon.
Enquiry received via email
response has attachments
In response to the Planning Inspectorate's advice provided on 29 February 2016, Power Without Pylons sent the following enquiry:

It implies to me that, in relation to this project, it would therefore be at the discretion of National Grid as to whether to include a potential sub-sea element as part of the proposed NSIP.
Would you be able to confirm that?

If so, would it be possible, at this stage in the project, to remove the southern route entirely from the NSIP application if National Grid decided to opt for the HVDC sub-sea option for that part of the project?
The Planning Inspectorate provided the following advice:

We are aware that following earlier rounds of consultation, National Grid is no longer progressing the ?offshore south? HVDC route option for this scheme. Please follow this link which provides further information on the proposed route and information on why certain options, including ?offshore south?, were not taken forward: [attachment 1]

We strongly advise you to contact National Grid with any comments you may have on this proposal, to enable them to consider your points prior to submission of an application to the Planning Inspectorate.

To answer your query, developers would need to consider a number of matters when deciding whether or not to include HVDC within their NSIP application for an overhead electric line. For example, there is the legal context as to whether HVDC offshore cables can be described as integral to or associated with the overhead line NSIP, also developers must be careful not to ?salami slice? their proposals into smaller separate applications where it could appear that an Environmental Impact Assessment would not be required, or that each part of the proposal had a reduced impact on the environment compared with the scheme in its entirety. However please note that it is the Secretary of State?s decision, following the examination of the application and recommendation made by the Examining Authority at the Planning Inspectorate, as to what can be consented as part of the project.

To date we have not dealt with a submitted overhead electric line NSIP application which had both overhead onshore and HVDC offshore lines. We have however dealt with: applications for overhead lines which included a section of undergrounding (onshore); an underground electric line and offshore HVAC connection which was Directed to be considered an NSIP under section 35 of the Planning Act 2008; and also offshore generating stations which include HVDC connections to land.

08 March 2016
Graham Barron Power Without Pylons
Enquiry received via email
This is an enquiry on behalf of the Power Without Pylons campaign group (PWP).
As you will be aware, this project is due to be submitted to the Planning Inspectorate next year, 2017.

National Grid (NG) needs to provide a new 400kV grid connection for the proposed Moorside power station, to connect it to the grid at Heysham, near Lancaster. All the options involve a double 400kV circuit heading north from Moorside, and a double 400kV circuit heading south.

Northern section - this is proposed as a conventional AC OHL line.

Southern section :
At the 2nd stage consultation in 2014 they consulted on 3 options for the southern section:
1.Onshore South
2.Onshore South, with Morecambe Bay tunnel.
3.Offshore South ? this would be an HVDC sub-sea cable connection. It would run as a (trenched) sub-sea cable connection all the way from the Moorside power station to Heysham.

PWP contacted the Office of Nuclear Regulation. In reply they stated:
?subsea transmission would not be a Nationally Significant Infrastructure Project? (NSIP).

Can you confirm that a HVDC sub-sea southern route from the proposed Moorside power station would not be treated as an NSIP?
The Planning Inspectorate provided the following advice:

The Planning Act 2008 details the thresholds at which certain projects are considered to be Nationally Significant Infrastructure Projects (NSIPs). In regard to electric lines, this is explained in section 16 of the Planning Act 2008.

Section 16 explains that above ground electric lines in England and Wales, of 132kV and above, and 2km or over in length (amongst other criteria) are considered to be NSIPs. However, where an above ground electric line NSIP proposal also includes some undergrounding or HVDC, some developers may describe these to be integral to, or associated with, the overhead line and therefore they might still be included in the NSIP application.

If the proposal was solely for an underground or HVDC line (without a generating station or an above ground electric line included in the application), it would not be considered a NSIP, however applicants have the option to apply for a section 35 Direction where the Secretary of State can direct that the proposal is treated as a NSIP.

29 February 2016
Graham Barron Power Without Pylons
Enquiry received via meeting
response has attachments
The Planning Inspectorate and National Grid held a telecon to discuss the North West Coast Connections project
Please see attached note.

29 January 2016
National Grid - anon.
Enquiry received via meeting
response has attachments
Project update meeting with National Grid regarding the North West Coast Connection Project
Please see attached note.

12 August 2015
National Grid
Enquiry received via meeting
response has attachments
Project update meeting with National Grid regarding the North West Coast Connection Project
Please view attached note

15 July 2014
National Grid
Enquiry received via meeting
response has attachments
Project Update Meeting for North West Coast Connection Project, held at The Planning Inspectorate Offices
Please see attached meeting note

25 September 2013
National Grid - Andrea Key
Enquiry received via meeting
response has attachments
Update meeting on the proposed North West Coast Connections Project
Please see attachments

25 May 2012
National Grid - Peter Fendley