NuGens Moorside Project in West Cumbria
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.
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.