Thanet Extension Offshore Wind Farm

Representations received regarding Thanet Extension Offshore Wind Farm

The list below includes all those who registered to put their case on Thanet Extension Offshore Wind Farm and their relevant representations.

SourceRepresentation - click on an item to see more details
Members of the Public/Businesses
Ian Hide
"Environmental Impact - Noise affecting marine animals, impact on bird life. Visual impact on sea views of 250 meter high turbines very close to shore - 100 meters larger than existing turbines and also nearer the shore. Financial impact on electricity bills. "
Local Authorities
London Pilots Council
"Safety of Navigation for vessels boarding and landing Marine Pilots and transiting the North East Spit area."
Non-Statutory Organisations
United Kingdom Maritime PIlots' Association
"The UKMPA objects to the proposed TWE extension bin the grounds of its significant negative impact on the navigational safety of ships boarding and landing pilots at the North East Spit boarding ground south of the NE Spit buoy. The proposal will have a direct impact not only on ships' manoeuvring room but more importantly the increased undesirable effect on the potentially life threatening elements of already (globally recognised)generally hazardous but essential pilot boarding and landing operations from pilot boats in the area concerned."
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 Thanet Extension 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. "
Members of the Public/Businesses
Donna Carr
"I wish to comment on the potential impacts and proposed benefits of the development on local residents, opportunities for employment for local residents and plans for how Vattenfall will contribute to the development and regeneration of Thanet."
Non-Statutory Organisations
Topbond Plc
"As part of the drive to reduce carbon utilisation and create green and environmentally friendly energy we support the expansion of the wind farm. As a local marine and civil engineering contractor we are very interested in the scheme and any development projects relating to the project whether land or water based. "
Other Statutory Consultees
The Coal Authority
"I have checked the site location plan against the information held by the Coal Authority and whilst the southern area of the proposed wind farm (Preliminary Onshore Boundary) falls within the coalfield area, I can confirm that the area does not contain any recorded risks from past coal mining activity and there are no surface coal resources present. On this basis we have no specific comments to make."
Other Statutory Consultees
Ramsgate Town Council
"At its meeting held on 8 August 2018 the Planning & Environment Committee on behalf of the Town Council resolved to agree the following minute; EN010084 – Thanet Extension Offshore Wind Farm off the coast of Thanet, Kent For the development consent to construct and operate the Thanet Extension Offshore Wind Farm off the coast of Thanet, Kent (adjacent to the existing Thanet Offshore Wind Farm) with an installed capacity of up to 340MW and comprising up to 34 wind turbine generators and associated infrastructure, to be located approximately 8km offshore (at the closest point). Proposed by Councillor Campbell Seconded by Councillor Shonk that: Ramsgate Town Council Fully supports this application. RESOLVED "
Non-Statutory Organisations
response has attachments
UK Chamber of Shipping
"The UK Chamber of Shipping is the primary trade association and representative body of the UK shipping industry with some 200 members across the maritime sector. Our points in relation to the application will be focused on the impact to commercial navigation of ships and safety of life at sea of mariners, detailing the safety of navigation, environmental, and economic perspective of the UK shipping industry. Please see attached"
Other Statutory Consultees
Nemo Link Limited
"The Nemo Link Project is an electricity interconnector between the UK and Belgium: it will be the first electricity interconnector between these two countries, and it is a joint project between National Grid Interconnectors Limited, part of National Grid Plc and Elia Group, the Belgian electricity transmission system operator. The Nemo Link Project is a high voltage interconnector with an approximate capacity of 1GW and it will comprise two 130km HVDC subsea electricity cables, two 3.1km onshore HVDC underground electricity cables, an HVDC converter station located in the Richborough Energy Park to convert HVDC power to HVAC power, three HVAC underground electricity cables (one circuit) between the converter station and the substation and a connection bay at an existing substation located in the Richborough Energy Park. One of Nemo Link Limited’s (NLL) key concerns is to ensure that its infrastructure is properly protected in respect of potential impact from the construction and operation of the Thanet Extension Offshore Wind Farm Project. From a review of the application material provided, the Project has the potential to affect the integrity of the Nemo Link Project’s infrastructure and there is insufficient information provided to enable a full understanding of the impacts that the Project may have on the Nemo Link Project. Offshore, the Project’s electricity transmission cables will need to cross the Nemo Link Project’s subsea electricity cables at some point regardless of routing because the Project’s windfarm site is to the north of the Nemo Link Project’s subsea cables but the Project’s landfall is to the south of the Nemo Link Project’s subsea cables. The proposed method of this offshore crossing will need to be assessed and the impacts on the Nemo Link Project’s subsea cables will need to be fully understood. At present, there is insufficient information to allow this assessment to take place. The onshore route options are of particular concern to NLL, as part of the Nemo Link Project’s onshore cables have not been installed underground: instead, they are surface laid with a chalk bund constructed over them to provide protection. The potential for the Project’s construction activities to have impacts on the Nemo Link Project’s onshore infrastructure has also not yet been assessed and still needs to be fully understood. At present, there is insufficient information to allow this assessment to take place. NLL would object to the inclusion in the DCO of powers for the acquisition of land or rights that NLL has an interest in given the importance of the Nemo Link Project to the UK, and further and in any event given the proximity of the projects NNL requires that protective provisions are agreed and included in the DCO to protect the continued operation and maintenance of the Nemo Link Project. NLL notes it has begun to engage positively with the promoter in relation to agreeing protective provisions. "
Members of the Public/Businesses
Port of Sheerness Ltd (PEEL PORTS - LONDON MEDWAY) (Port of Sheerness Ltd (PEEL PORTS - LONDON MEDWAY))
"I refer to our original letter dated 10th Jan to Vattenfall: Our principle concerns are the significant disruption to our operations due to encroachment into existing shipping lanes and their well established shipping routes, necessitating considerable re-routing of traffic and potential loss of well established trade; the reduction of sea room and potential interference with marine navigational equipment causing an impact on navigational safety; the impact of additional transit time on the wear and tear of pilot launches and their suitability to undertake the revised passage. This has serious consequences for the area and we would be more than happy to host a visit to the Port to demonstrate the considerable regeneration that will be affected. "
Other Statutory Consultees
UK Power Networks (Operations) Limited (UK Power Networks (Operations) Limited)
"I am writing on behalf of UK Power Networks Ltd and the Licenced Distribution Networks Operator South Eastern Power Networks plc. South Eastern Power Networks plc is the occupier of premises in the land to be used under the above Order. It is also entitled to the benefit of rights in, over, on or under such land and is the owner of Electric Lines and/or Electrical Plant (as those terms are defined in Section 64(1) of the Electricity Act 1989) in, on, over or under the land to be acquired and/or temporarily used under the above Order. These premises, rights and apparatus have been acquired for and are used for the purposes of its statutory undertaking. South Eastern Power Networks plc objects to the making and confirmation of the Order unless at the cost of the acquiring authority there are first provided to it, on no less favourable tenure suitable alternative sites and suitable alternative rights in, on, over or under land in substitution to those to be acquired and/or temporarily used under the above Order and in, on over or under which there are first installed and commissioned Electric Lines and Electrical Plant in substitution for those in the land to be acquired and/or temporarily used under the above Order, before that land is acquired and/or temporarily used so that my client can carry out its statutory functions and contractual obligations no less efficiently than previously. Please treat this representation as an objection by South Eastern Power Networks plc to the relocation/extinguishment of rights and apparatus mentioned above because their relocation will be detrimental to the carrying on of its undertaking. No alternative land, rights and apparatus for those proposed to be acquired under the above Order are in place. South Eastern Power Networks plc reserves the right to amend or supplement its objections in the light of any information that later becomes available. The above objections will be deemed to be withdrawn upon signature of an appropriate deed of Undertaking by an authorised signatory of the Acquiring Authority. All future correspondence relating to this matter should be sent to Carl Bennett by hard copy to UK Power Networks Legal Department, Energy House, Carrier Business Park, Hazelwick Avenue, Three Bridges, West Sussex, RH10 1EX. Yours faithfully Carl Bennett Senior Surveyor UK Power Networks "
Non-Statutory Organisations
London Gateway Port Limited
"We have significant concerns regarding implications of the proposed Thanet Extension Offshore Wind Farm on shipping and accessibility to ports located on the Thames Estuary. In particular we are concerned regarding: • Encroachment into existing shipping lanes with resulting increases in commercial shipping journey times and distances and overall port accessibility • Implications for larger vessels wishing to access the NE Split pilot barding station, which we understand would offer significantly restricted access should the development proposals go ahead. This would have the effect of lengthening pilotage distances and making piloting operations less resilient to adverse weather conditions In citing the above concerns we make reference to the National Policy Statement for Ports (January 2012) which we believe is a material consideration in assessing the implications of the proposed development. In this regard we note that the Ports NPS: a) Defines a need for unimpeded access to ports with water deep enough for the largest ships in order to meet the forecast demand for additional port capacity (as defined in Paragraph 3.4.3) b) Confirms that ports play a vital role in support of the national and regional economy, trade and growth c) Identifies that “currently, the largest container and ro-ro terminals are in the South East” and that “much of the tonnage handled is concentrated in a small number of ports, with the top 15 ports accounting for almost 80% of the UK’s total trade” d) Identifies a need for ports to be efficient and competitive to enable them to contribute to long term economic growth and prosperity We take the opportunity to highlight that 2 of the top 15 ports in the U.K are located on the banks of the Thames Estuary and that, in 2016, Thames Estuary ports handle 10.7% of the total U.K throughput of goods (in tonnes – www.Gov.uk, Port Freight Statistics). We are therefore of the view that the need to support increased energy production from sustainable low carbon sources is balanced against the need to support shipping and port activities. We have examined the evidence submitted in support of the application including the Shipping and Navigation Report (Ref: 6.10.2), Pilotage Transfer Bridge Simulation Report (Ref: 6.4.10.2) and Navigation Document (Ref 1.4). Our examination of these documents has identified significant shortfalls in assessment methodology particularly with regard to proposed alternative pilotage operations, vessel management and navigation risks. Such matters require further scrutiny and consideration to allow the full impacts to be understood. "
Members of the Public/Businesses
response has attachments
Merlin Jackson on behalf of Thanet Fishermen
"The Thanet Extension project is being proposed in an area vital to the Inshore commercial Fishermen of Ramsgate, Broadstairs, Margate and Whitstable. The proposed TE array area and export cable are worked by Fishermen using multiple methods for a variety of fish and shellfish species. The area is fished using Lobster and Whelk pots, trawls, static nets, surface and bottom drift nets. Some of these methods will no longer be possible if the Thanet Extension wind farm is built and the ground will be lost. The inshore vessels are a non nomadic fleet and generally operate within a 25 mile radius of the harbour. The vast majority of the fleet is 10m and under in length. The Fishermen's Association and its members will be objecting to this project on the basis of loss of ground, loss of specific methods, cumulative impact with other projects and a direct impact on local Fishermen's earnings. "
Members of the Public/Businesses
Christopher Redmond
"as a fisherman from Ramsgate I will be directly affected by the Thanet extension project with the loss of fishing ground and fishing opportunity in and around the extension project which in turn will have a direct affect on my livelihood "
Members of the Public/Businesses
G Pulman
"Dear sir\madam my points are that I'm very worried of the extension and were it will go. It will affect all but I have 98% of my earnings come from around the farm. Mainly to the east and the south. Static and drift fishing. This will see me out of business on the drifting grounds. My nets are a one off for a certain area and are to heavy to work else where.Nylon and number 6 lead line. Working east of the farm for about 18 years now so also it's not that I know new grounds. This would need new gear. New gear on new grounds isn't the scenario i would like to try and breaking in ground ends in a lot of damage/lost gear. All I can say that this will cause massive disruption to me. The scuccor fish will show where I work. Sadly not enough to the south of the farm but that could change now our quotas seem to catching up with the amount of fish about. I hope this is the sort of thing you were after. Kind regards Mr Graham Pulman"
Members of the Public/Businesses
M Philbrick
"To Vattenfall Windpower Ltd I am writing to you to object on the Thanet Extension. For the reasons being what with London array and the thanet windfarms which have taken nearly all the ground I fish on,,and with this extension it will proberly make me bankrupt.,As where you are possibly extending to is my main drifting ground, which is west north west of the thanet windfarm ,and west of that is my main codding ground,and what with nemo as well is becoming a joke, as I am as are many other really struggerling to survive. Due to all theses works being carried out I lost my main drifting ground to London array,so I am left with very little ground,even if you was going east then that will push the other fisherman onto my ground I fish as you would of taken that away,All I am trying to do is pay my mortgage,I had to get rid of my crew as I could not afford to take a crew now,And as a safety aapect last year I fell overboard,but luckily and friend came with me for a day out,and after around an hour he managed to get me back onboard,,had to have 6 months off due to damaging all my tendons in my arms. Imjust hopeing you put it to the south but don’t spos we will be that lucky,just ESL and the FISHERMAN and PLA all want this to the south which would help everyone but for some reason I have heard you want to put it in everyones way,I.E to NORTH AND WEST AND EAST,IT COULD EASILY BE RESOLVED. As the bottom is the same all round ,as there is no rare species as this come,s up as it did with London array which I spoke to a guard vessel and they said they lie what they see to extend their guard work,, "
Members of the Public/Businesses
Peter John Nichols on behalf of Thanet Fishermen
"I represent the Fishermen of Thanet Fishermen's Association, encompassing the harbours between Whitstable and Ramsgate. The proposed Thanet Extension is in an area that is fished consistently by our vessels which includes all methods: Trawling/ Static netting/Bottom drifting/ Surface drifting/ Lobster and Whelk potting. We are extremely unhappy about the proposed extension due to the loss of ground and opportunity. The domino effect will have an impact on the smaller vessels which do not necessarily fish the site but will be directly impacted by the displacement of the vessels that do. The cumulative impact of multiple offshore projects, including the extension of Thanet Windfarm, is having an major adverse effect on the fleet. "
Other Statutory Consultees
response has attachments
Forestry Commission
"documents emailed"
Non-Statutory Organisations
Peri Percy and Martin Jackson on behalf of Commercial Fishermen's Rights UK
"I wish to make an objection upon behalf of the commercial fishermen from Ramsgate, Margate, and Whitstable, who use the fishing grounds where Thanet Array is situated, and will lose yet further fishing grounds, if the Thanet Array Windfarm Extension is granted. Local fishermen from the above Ports, have lost 75% of their fishing grounds in the past 50 years, and are about to lose further HISTORIC FISHING GROUNDS in the future. The value of fishermen "AS FOOD PROVIDERS", has been denigrated by successive UK Governments, and companies wishing to make "A PROFIT" from off-shore resources. I have stated before that Windfarmers are good neighbours to local fishermen, and at least pay some compensation for ground taken, BUT, the amounts which are paid in compensation are UNREALISTIC compared to fishermen's losses in real terms. So many different types of fish, and shell fish, can be caught in this area using a multitude of different fishing gear methods, deployed by fishermen coming from approximately a 20 mile radius, and sometimes further, that the extra ground required for the extension should be referred to as "PRIME FISHING GROUND" with the following list of species available to be caught:- LEMON SOLE, DOVER SOLE, COD, WHITING, SKATE, RED GURNARD, HERRING, MACKEREL, PLAICE, POUTAIN, DABS, SEA BASS, HORSE MACKEREL, CONGER EEL, GAR FISH, DOG FISH (NURSES), SPUR DOG FISH, SHELL FISH INCLUDE LOBSTERS, WHELKS, BROWN CRABS, VELVET CRABS, HERMIT AND SWIMMING CRABS, AND AS YET UNMARKETED IN THE UK, THE COMMON GREEN AND RED CRAB (THESE ARE FEED FOR MANY SPECIES OF FISH) AS ARE SAND EELS WHICH SEASONALLY FREQUENT THE AREA. If the project is justified as of "NATIONAL IMPORTANCE" i.e. the supply of electricity to the UK, then it should be noted, for the reasons above, this fishing ground is of "National Importance" also, to fishermen and stakeholders alike, who are the great British public who buy the product and enjoy it! Martin Jackson Commercial Fishermen's Rights UK 40 years a Trawler Skipper fishing the grounds in question, and many others"
Members of the Public/Businesses
David Edwards
"If the expansion of the windfarm how’s the head west would I as a pilot boat coxswain would be forced to serve ships a greater distance from our base in heavy whether this would be more dangerous as we would not have the lee of the shore And would mean travelling greater distance in heavy weather would also increase of fuel consumption regards David Edwards"
Members of the Public/Businesses
Estuary Sevices Ltd
"The planned extension will impead the safe boarding and landing of pilots from at the North East Spit pilot station. The North East spit pilot station serves ships bound for the ports of London and Medway, the extension plans cut right through the boarding area that the ships currently use."
Members of the Public/Businesses
Malcolm Gosman
"Hi, my name is Malcolm gosman I am a fisherman and a vessel owner, I am also a member of Thanet fisherman's accotiation. My objection with Thanet windfarm extension is the fact I will lose my main fishing ground which would have big implications on my business earnings we are already stretched to the limit with farms more would be disastrous! So I say no to more development. Thanks. Kind regards Malcolm gosman."
Members of the Public/Businesses
Richard Jackson
"I work as a launch coxswain for a marine pilotage support service (Estuary Services Ltd) and have done for the last 15 years. The area of operation for the vast majority of the shipping we serve is close to the western side of the existing TOW site. I feel that any migration west (as Vattenfall have proposed) will cause a very high level of congestion in an already high traffic area. The subsequent displacement of ESL, which I think is inevitable in order to keep our operation safe, will have a major impact on us as a viable business. "
Members of the Public/Businesses
Robert Pulman
"As an interested party whose employment is directly linked to the area of proposed expansion of the Thanet Offshore Windfarm, the primary points I'd like to raise include : 1)siting of turbines in relation to working areas of other interested parties 2)possible loss of employment due to proposed siting of added turbines 3)long term benefits to local residents versus long term costings including longevity of parts, in light of recent developments of other local Windfarms. 4)Reasons why the proposed extra turbines cannot be situated in a position that is satisfactory to all interested parties and not just for the profit margins of the Windfarms companies "
Members of the Public/Businesses
John Ramshaw Lowe
"Skipper owner “Solar Star YH481” Member of Thanet Fishermen’s Association The proposed Thanet Extension project will have a dramatic impact on my livelihood. I have been fishing this area using my lobster/crab pots for the past 35 years, and if the project goes ahead it will mean that I will no longer be able to support my family and household. When the original windfarm was constructed I lost a considerable part of my income. If the Thanet Extension goes ahead it will mean a stop in my fishing activity, 98% of my income is derived from the area proposed for development. It will impact on most members of the Thanet Fishermen’s Association in various ways either by stopping them fishing or from displacement of effort."
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 Thanet Extension Offshore Windfarm Development Consent Order. National Grid wishes to make a relevant representation to the Thanet Extension Offshore Windfarm 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 consented apparatus and land interests located within this area. 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 Richborough 400kV Substation: National Grid is concerned that the Richborough 400kV substation (currently under construction) is currently shown to be within the order limits and could be the subject to compulsory acquisition. The substation will form an essential part of the electricity transmission system and part of National Grid’s Electricity Transmission statutory function. Richborough Connection Project Order (2017): National Grid’s Richborough Connection Project Order (2017) which provides rights to acquire land and construct a new high voltage 400kV electricity connection between Richborough and Canterbury North 400kV Substations appears to overlap with the proposed order limits of the Thanet Extension Windfarm Project. Careful consideration will need to be given to ensure that National Grid’s rights are protected and safeguarded. If any of the rights provided by the Richborough Connection Project Order (2017) are proposed to be changed or removed then alternative rights will need to be provided by the Thanet Extension Offshore Windfarm Order that are acceptable to, and have been agreed by National Grid. Following a meeting with yourselves it appears unlikely that there will be a significant overlap in the construction of both projects. However, in the event that there is an overlap it will be essential to work together and agree a form of liaison procedure to ensure any potential interactions / conflicts can be proactively managed and resolved. 132kV underground cable: Between National Grid’s 400kV substation and UKPN’s 132kV substation will be a 132kV underground cable. Careful consideration will need to be given by the Thanet Extension Offshore Windfarm project team to ensure none of the proposed works impact on the integrity of this cable. Unfettered access to this cable will also need to be maintained at all times. 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 agreement. "
Members of the Public/Businesses
Ross Hambly
"I am with the Thanet fishing assiation when work commence,s I will lose fishing ground and income . Thanking you for looking into it if there’s anything I can assist you with send me an email ."
Local Authorities
Dover District Council
"Dover District Council hereby seeks to make a relevant representation being one of the Local Planning Authorities in which the development effects and with part of the proposed infrastructure being situated within the District. The representation shall relate primarily to the onshore aspects of the proposal which fall within Dover District. These include part of the cable route and the proposed substation. Nevertheless, due to the close proximity of the proposed works to the District’s Boundary other representations shall be made, where relevant, on other aspects and impacts of the proposal. The District Council is also on the National Nature Reserve (NNR) Management Steering Group and therefore has concerns regarding the impact on the NNR and its management, particularly in relation to the cable route selection and options appraisal, the decision making process and chosen cable route. The representation shall relate to the following points: • Impact of the new development in the District in particular the substation structure and associated works • Whether the cable route selection process has been addressed appropriately • The associated impacts of the proposed cable route • The visual and landscape impact of the proposed infrastructure • The impact on ecology • The level information supplied by the applicant to support their approach to the Habitats Directive. • Has the route selection been adequately addressed in respect of sufficient information for an Appropriate Assessment to be undertaken. These matters have been raised previously at the relevant stages and in the Council’s response to the Section 42 Consultation Process and shall be addressed in more detail in the Local Impact Report. "
Members of the Public/Businesses
Bircham Dyson Bell LLP on behalf of RiverOak Strategic Partners Limited
"Our client, RiverOak Strategic Partners Limited, is proposing to redevelop the currently closed Manston Airport into a new cargo hub airport with associated airport related development. It made an application to the Planning Inspectorate for a Development Consent Order for the project on 17 July 2018 (application ref: TR020002) which was accepted for examination on 14 August 2018. Our clients are in discussions with the promoters of the Thanet Extension Offshore Windfarm and seek to produce a Statement of Common Ground on matters relating to: - the potential impact of each proposed development on the other; - the cumulative effects assessment for each project; - flight paths from the proposed airport; and - radar systems at the proposed airport. Our client may seek to make further comments in these areas during the examination for the Thanet Extension Offshore Windfarm. Yours faithfully, Bircham Dyson Bell LLP"
Members of the Public/Businesses
Thomas Henry Brown on behalf of Thanet Fisherman
"I am lodging this objection on behalf of the members of Thanet fishermen's Association Ramsgate. The sea area that the Thanet Offshore Wind farm occupies is extensively fished by Thanet fishermen.The main fishing methods employed are Gill netting, Trawling, Whelk potting and Lobster potting. The construction of the present Wind-farm has had an effect on the fishing. Some methods have been seriously restricted such as Gill netting and Trawling, Potting not so much. There has been much industrial development in the Thames estuary regarding Gravel extraction, Dredging, Power cables and Wind-Farms, All undeveloped seabed is precious to the fishermen, the expansion of the TOW site will have a definite adverse effect on the local fishing."
Members of the Public/Businesses
Merlin Jackson on behalf of Barry Parker
"I am a Thanet Fisherman and part of Thanet Fishermen's Association. The proposed Thanet Windfarm extension and the export cable route will affect all of the Fishermen that work on this part of the coast, directly and indirectly, myself included. The extension area is used for all methods of fishing and so is the cable route. There are so many marine licenses being granted for projects in the Inner and Outer Thames Estuary, it has become over run. I do not think this project should go ahead as it will directly affect commercial fishing for our small vessel fleet and the livings of the Fishermen that work here."
Members of the Public/Businesses
Christopher Howland
"I am owner of Stella Maris moored in Ramsgate Harbor, a commercial fisherman of over 30 years and a member of Thanet Fishermans Association. The planning proposition for this infrastructure will cause more loss of fishing grounds; this is all prime fishing ground for drift netting, static netting, potting and trawling. Until the current wind farm already in place came along, this was the best fishing ground. The positioning of the turbines also means the displacement of boats that currently fish the area, which would cause the boats to move onto different areas where there are already boats, overpopulating the area and putting strain onto it as too many will be trying to fish in the same vicinity. I can state this as I have already witnessed the movement happen due to previous placements of the current turbines. Of what is not much left of over development of wind farms, cable laying, dredging, closed areas etc, we cannot afford to lose more grounds. "
Members of the Public/Businesses
Kevin Castro
"I am a registered commercial fisherman (boat is Endurance R80) and use the surrounding area on the inside edge of where the existing wind farm is. I have lobster pots there 9 months of the year and also use nets to catch seasonal fish. To build more wind farms in and around the area will limit the fishing area even more and therefore have further impact on my earnings. "
Members of the Public/Businesses
Ben Cooper
"I along with my brother are directors in R. Cooper & Sons Fisheries Ltd, we run 2 small inshore fishing boats MFV SUVERA and MFV SALVA MEA based in whitstable. As an associate member of the TFA (Thanet Fisherman's Association) I share similar concerns over the proposed thanet windfarm extension. We use a variety of fishing techniques including trawling, potting and gill netting, all of which will be negatively impacted upon, both during the construction, and after completion, due to the loss of fishing grounds. My concern is that this proposal is yet another nail in the coffin of not only my business, but the whole of the north Kent inshore fishermen."
Members of the Public/Businesses
Jack Ryan
"The area of extension to the Thanet windfarm will hugely affect my own income aswell as the income of the family business that I will be taking over in the future. These are major fishing grounds that we work on throughout the year and losing that specific area will make a huge difference on me now and in the many future years of my fishing career."
Members of the Public/Businesses
Jason Lee Ryan
"Due to the proposed area of extension to the Thanet windfarm, our family business and annual income will be hugely affected and reduced as a result of losing major fishing grounds. These fishing grounds are not only a sustainable part of our income but are also a major food source supplying the whole Thames estuary of which we fish in all year round."
Local Authorities
Kent County Council
"Re: Application by Vattenfall Wind Power Limited for an Order Granting Development Consent for the Thanet Extension Offshore Wind Farm – Relevant Representation Submission Following the Planning Inspectorate’s acceptance (23 July 2018) of an application for a Development Consent Order (DCO) for the Thanet Windfarm Extension, Kent County Council (KCC) requests to be registered as an Interested Party at the Examination. This letter provides a summary of the main aspects of the proposal which KCC agrees and/or disagrees, together with an appropriate explanation, in accordance with the Planning Inspectorate Advice Note 8.3. In summary, an outline of the principal submissions that KCC intends to make in relation to the application will concern: - Highways and transportation, as the Local Highway Authority for Kent; - Country Parks, as land owner and manager of Pegwell Bay Country Park; - Waste; - Biodiversity; - Heritage; and - Public Rights of Way (PRoW). Highways and Transportation KCC has agreed that no further capacity assessment of the highway network is required, beyond that already included in the application. The proposed site access points have been agreed in principle between Vattenfall and KCC. Full details will need to be submitted and agreed by KCC as the Local Highway Authority. The principles of traffic management and mitigation during construction are acceptable, but details will need to be agreed through the submission of the Construction Traffic Management Plan. Country Parks Pegwell Bay Country Park is a coastal public park and community asset, providing recreation and leisure opportunities with flat access paths, a car park, picnic area, toilets, refreshments and play park. The site is managed for its wildlife, habitat and customers, and KCC has invested in the site to deliver improved access and community facilities, with increased usage as a result. The site is accessed by a wide range of users, from families to Park Run, dog walkers and wildlife enthusiasts and is used as a gateway to the National Nature Reserve and the wider landscapes around Pegwell. The scheme currently puts forward a range of options for cabling across the park. One option (option 1) looks to underground the new cable across the park. From a park management perspective, running an underground cable is the preferred option. An over ground berm (option 2) would not be acceptable from a park management perspective, particularly considering the impact resulting from the previous cable that was installed through the Nemo Link project. The Nemo Link project is not regarded by KCC as a good example of how the County Council would like to see another cable project delivered in the park. There are also concerns that the cumulative impact of a second over ground berm, for option 2, is not sufficiently assessed in the application. In addition, KCC notes that option 2 is presented within the Outline Landscape and Ecological Management Plan (OLEMP; 2.1.19), with the over ground berm proposed to run parallel to the Nemo Link. This would create a double berm structure (an ‘M’, in effect). This would create difficulties for grazing and access in the park and would not be supported by the County Council. It would also have a detrimental visual impact by significantly altering the natural landscape features of the flat coastal park. The mitigation for the final option will need to be included in the LEMP and this will need to be agreed by KCC, to ensure that any structure is appropriate within the park and blends in with the surrounding land. The County Council supports the running of an underground cable as the preferred option (option 1), with the next most favourable option as trenching the cable (option 3). The site investigations in the landfill site will determine whether excavation within Pegwell Bay Country Park is feasible. If site investigations show that neither option 1 or 3 are viable, then KCC will expect that the developer works closely with the County Council to assess the full implications of an over ground berm and fully mitigate its effects (option 2). However, as mentioned above, this option is not supported by the County Council from a park management perspective. The options for landfall at Pegwell now include an option to install cable ducts under the sea wall that forms the boundary of Pegwell Bay Country Park. This option will depend on the site investigations by using Horizontal Directional Drilling (HDD) to reduce the interaction with the saltmarsh and sea wall. Waste Any incursions into the landfill site or breaches of the sea wall (which would be required for options 1 and 3) will need to be engineered to consider the historic potential environmental difficulties associated with this site. In particular, this would include ensuring that no new pathways for the migration of landfill gas or leachate are created. It is also advised that any Environmental Permits obtained in connection with this project will need to be the sole liability of the developer and that none will be transferred to, or later by default become incumbent on, the County Council. Biodiversity It is understood that the ‘Benthic Subtidal and Intertidal Ecology’ report utilises information that was originally submitted as part of the Nemo Link application, which involved cabling over ground. However, the County Council would like to highlight the importance of using ongoing monitoring to inform detailed mitigation strategies. The report also states that a ‘Saltmarsh Mitigation and Reinstatement Plan’ will be produced. Due to the high impact that this proposal will have on the habitat, the County Council would expect the plan to be submitted as part of the application. A Habitat Regulation Assessment (HRA) screening report has been submitted and confirms that a full HRA will be required. The Planning Inspectorate will need to carry out the HRA so sufficient information will need to be submitted by the applicant to enable this to be completed. Heritage Onshore Historic Environment Overall, KCC is satisfied that the Environmental Statement has taken account of the comments previously provided as part of the Section 42 PEIR consultation, with respect to the Onshore Historic Environment. KCC have provided some detailed representation on the Environmental Statement below. The mitigation proposed, as detailed in Volume 3 Chapter 7 (7.11.1 to 7.11.9) of the Environmental Statement is considered appropriate. KCC would advise that if non-designated assets associated with the defenses are encountered along the cable route, then it may be appropriate (depending on their form and preservation) for consideration to be given to avoiding physical impacts through the design of the cable route, rather than a programme of recording. The County Council disagrees with the mitigation proposed for the effects of the excavation of the cable route on potential (and presently unidentified) buried anti-invasion heritage assets. The general approach to mitigation set out in paragraph 7.16.1 is supported, as is the commitment to submit an Archaeological Written Scheme of Investigation in due course. Offshore Historic Environment KCC advises that an Archaeological Written Scheme of Investigation is required, to include an Archaeological Exclusion Zone, which will need to be agreed with KCC and Historic England. Public Rights of Way (PRoW) KCC notes that the application includes a surfacing specification. The County Council requests that the finished surface specification is agreed with KCC before works are undertaken along the England Coast Path/ Viking Coastal Trail. Given the popularity of this route, KCC would like to remind the applicant that temporary closures should be avoided. If path closures are required, they should be kept to a minimum to minimise disruption for path users and an alternative route should be provided for the duration of the closure. KCC’s PRoW Officers would need to be consulted on any closures and alternative routes so that the Council can update and inform coast path users and the National Trail website. The County Council looks forward to working with the applicant and Planning Inspectorate and welcomes the opportunity to comment on matters of detail throughout the Examination. Should you require any additional information or clarification, please do not hesitate to contact me. Yours sincerely, Katie Stewart Director - Environment, Planning and Enforcement "
Other Statutory Consultees
The Corporation of Trinity House
" 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. We submit that the development would create an unacceptable increase in risk to the safety and navigation of mariners at sea, therefore we OBJECT to the proposed red line boundary (as revised) within the plans. Our concerns include, but are not limited to, the following: - The proposed boundary reduces the space available for shipping between the windfarm and Kent coast. We are particularly concerned about the accumulation of traffic and ease of navigation between the north-west and westerly boundary. - The risk mitigation measures, in our opinion, do not reduce the risk to an acceptable level. - We find the statement within the Navigation Risk Assessment executive summary referring to the “…. Increase in collision rate from once in six years to once in four years” an unacceptable situation. Vattenfall have shown they consider the reduction in the red line boundary has now made this one in 4.5 years, which in our opinion remains unacceptable. We look forward to discussing the matter and finding an amicable solution at the examination stage of this process. Please direct correspondence regarding this application to the following email addresses: [email protected] and [email protected]"
Members of the Public/Businesses
Christopher Attenborough
"I am a sixth generation fisherman who has made their living off the grounds of the Thames estuary. The ground that has been designated for the thanet offshore windfarm is of greatest importance to earning my livelihood. it is a very diverse piece of ground giving me all year round fishing for soles, bass, smoothounds in the summer to cod and skate in the winter. This did extend into the area of the existing windfarm but has become non-commercially viable ground since the construction. With the unprecedented rate of offshore construction off the kent coast we are seeing an alarming amount of ground becoming non-commercially viable through fish not returning after construction. This in turn is displacing fishing vessels onto smaller, diminishing areas of ground that are commercially viable. I fear this project will have a very negative effect on this area and will mean I will have to push even further out to sea in an under 10 metre boat."
Members of the Public/Businesses
Graham Hambly
"As a member of the Thanet Fishermans Association and owner of two fishing boats with the go ahead off the Thanet Windfarm extention we are going to loose vital and very important fishing grounds like we did when the windfarm was constructed originally , The larger fishing boats get pushed off the groungs with a knock on effect to the smaller boats one of my boats does go to the designated area while the smaller one stays closer to the harbour , Not only does the building works stop the fish from coming through but the larger boats are displaced and fish more intense on the inshore grounds so the smaller boats have less chance of earning a living therefore some fishermen will have to stop fishing altogether and be faced with loosing their vessels and then a life on benifits as fishing is all they know and is away of life . This is very destressing in such a tight industry."
Members of the Public/Businesses
David Ninnim
"I oppose the wind farm extension due to the fact that the existing farm, in its current form, already causes a hinderence to shipping. The planned extension, should it be approved will only make matters worse. This will affect trade to and from the Thames and Medway. Vattenfall have chosen the cheapest option by submitting plans to extend to the west and north and not to the east which would have a less effect on shipping routes. They have built wind farms up to 90km off of Denmark so there is no reason why they cannot extend to the east rather than west, other than that of money. But any extension is not good for the shipping industry and the cost of transporting goods to and from this country."
Other Statutory Consultees
response has attachments
Environment Agency on behalf of Environment Agency
" The Infrastructure Planning Commission Temple Quay House Dear Sir/Madam Application for a Development Consent Order - Thanet Extension Offshore Wind Farm Having reviewed the application details for the above proposal we have the following relevant representation to make: The Role of the Environment Agency The Environment Agency has a responsibility for protecting and improving the environment, as well as contributing to sustainable development. We have three main roles: We are an environmental regulator – we take a risk-based approach and target our effort to maintain and improve environmental standards and to minimise unnecessary burdens on business. We issue a range of permits and consents. We are an environmental operator – we are a national organisation that operates locally. We work with people and communities across England to protect and improve the environment in and integrated way. We provide a vital incident response capability. We are an environmental advisor – we compile and assess the best available evidence and use this to report on the state of the environment. We use our own monitoring information and that of others to inform this activity. We provide technical information and advice to national and local governments to support their roles in policy and decision-making. One of our specific functions is as a Flood Risk Management Authority. We have a general supervisory duty relating to specific flood risk management matters in respect of flood risk arising from Main Rivers or the sea. Outstanding information and issues of concern Our relevant representation outlines where further work, clarification or mitigation is required to ensure that the proposal has no detrimental impact on the environment. Our comments –in relation to the impact on the Pegwell Bay saltmarsh and the Water Framework Directive assessment- raise concerns which we believe need to be addressed prior to a development consent order being granted. Please do not hesitate to contact me if you require any further information. We look forward to continuing to work with the applicant to resolve the matters outlined above, and to ensure the best environmental outcome for this project. Yours faithfully Ms Jennifer Wilson Planning Specialist Direct dial 0208 474 6711 Direct e-mail [email protected] Relevant Representations On behalf of the Environment Agency Environmental Statement Volume 2 Chapter 5: Benthic Subtidal and Intertidal Ecology Saltmarshes are ecological important features for birds, fish and invertebrates, they are an important source of carbon to adjacent features such as mudflats and act as natural sea defences. The importance of Pegwell bay saltmarsh is discussed in more detail later in this response. Table 5.9: Valued Ecological Receptors (VERs) within the Thanet Extension benthic ecology study area, their conservation status and importance Comment: Unfortunately this table does not include saltmarsh present, which is a valued ecological receptor and has high conservation importance. Table 5.10: Maximum design scenario assessed Permanent loss of saltmarsh from an extension of the seawall seawards of a curved structure (155 x 18.5 m) for worst-case this will result in loss of 0.0014 km2 loss of saltmarsh habitat (which represents 0.13% of the saltmarsh present within the SAC – noting that this is the smallest designated site at Pegwell Bay and therefore representing the worst-case in terms of percentage habitat lost). Comment: This is the narrowest section of saltmarsh to the north of the River Stour but any seaward extension at this point (as detailed in report being 18.5m seaward) will effectively bisect the continuous saltmarsh habitats that is present to the north and south of the country park fragmenting the saltmarsh habitats. There is no evidence that new saltmarsh will establish itself in front of this proposed seawall extension and it is more likely this structure will cause local erosion of saltmarsh immediately adjacent to it. 5.10.25 The magnitude of the impact (taking the embedded mitigation into consideration) has been assessed as Low, with the sensitivity of the saltmarsh being assessed as Medium. Therefore, the significance of effects from direct disturbance occurring as a result of the export cable installation activities is Minor adverse, which is not significant in EIA terms. Comment: This statement only applies to temporary disturbance to the saltmarsh and is not applicable to permanent saltmarsh loss and bisection of saltmarsh habitat as detailed previously. Therefore we disagree with this statement. 5.11.19 The total maximum area of saltmarsh loss due to the sea wall works described in Table 5.10 is predicted to be 0.0014 km2. This equates to 0.13% of the saltmarsh habitat within the Thanet Coast and Sandwich Bay SAC (it should be noted that the saltmarsh is not a feature of this SAC). Given that this habitat is widespread and common throughout the area, this represents a very small footprint compared to the overall extent. The area of permanent loss of saltmarsh has a maximum extent of 18.5 m from the existing sea wall. The saltmarsh in this area of Pegwell Bay extends between approximately 45 – 110 m from the existing sea wall out to a maximum width of 155 m; consequently, the extension to the sea wall will not give rise to any separation of areas of the saltmarsh habitat. While the impacts will be permanent, the impacts will be localised and will not split the habitat; therefore, the magnitude of the impact is assessed as low. Comment: We disagree with their conclusions because this location is the narrowest section of saltmarsh, this will cause significant bisection of the habitat and no supporting evidence is provided to show that further erosion by the addition of a protruding section of new seawall will not cause local erosion of existing saltmarsh adjacent to this landfall location. 5.11.21 While the saltmarsh is a feature of the SSSI, it is not a feature of a Natura 2000 site. The proposed landfall area is an area that is considered to be generally lower value saltmarsh as a result of the areas of saltmarsh being elevated above the wider area such that it is not regularly inundated by tidal water and therefore being dominated by Spartina and grasses. It is therefore considered to be lower quality when compared to other areas of the saltmarsh within Pegwell Bay. The low quality and low potential to improve, combined with the status of the designation, means that the sensitivity of the habitat to the permanent loss of this area of saltmarsh is assessed as medium. Comment: From personal observation, this area does get inundated on high tides. Accordingly, we do not where this evidence for these statements come from. We would like to know if there is there a typographic survey and a Pegwell Bay wide saltmarsh quality assessment and would like to have the opportunity to comment on it. Saltmarsh Mitigation, Reinstatement and Monitoring Plan 4.1.2. Saltmarsh is common throughout Pegwell Bay and is present throughout the proposed cable installation site. The quality of the saltmarsh increases to the south of the Stour, with patchier, less diverse assemblages being found to the north of the Stour. Pegwell Bay saltmarsh is not a recognised feature of the Sandwich Bay SAC. However, it is included as a supporting habitat for roosting and feeding activity for the designated bird species golden plover and turnstone within the Thanet Coast and Sandwich Bay SPA/ RAMSAR and is also a feature of the Sandwich Bay to Hacklinge Marshes SSSI. Comment: Whilst Saltmarsh is present within Pegwell Bay, it only occupies a relatively small area of the total intertidal area and is concentrated around the river mouth. This statement implies that is a common feature and is of less importance. Regionally this area of saltmarsh is extremely important as the map below shows: Unlike the Thames estuary/southern North Sea, the Eastern Channel waters have very little saltmarsh available to support the huge range of species that depend on this habitat. Numerous studies (e.g. S.Colclough,et al 1995, Bell F.W. 1997, Boesch D. & Turner R. 1984) have shown the ecological and economic value of saltmarsh in particular relation to commercial and recreational fisheries. Surveys undertaken by the Environment Agency and the Kent and Essex Inshore Fisheries and Conservation Authority (IFCA) in Pegwell Bay show how even single saltmarsh creeks can provide shelter and feeding grounds for a wide range of marine fish species e.g. a survey on 11th August 2010 found these species around a single saltmarsh creek at Pegwell Bay. a) River in front of Saltmarsh Common name Number Range in mm (Fork length) Flounder 2 41 - 59 Sprat 24 45 - 63 Bass 40 12 - 20 Sand/Common Goby 100 <20 Crangon 1 b) Shore and saltmarsh Common name Number Range in mm (Fork length) Golden-grey mullet 2 94 Sprat 5 36-39 Sand smelt 4 50-53 c) Upper saltmarsh creek Common name Number Range in mm (Fork length) Herring spp * 4 20-23 Sprat 17 40 - 52 Bass 2 37-38 Sand/Common Goby 30 <20 * To be identified d) Lower saltmarsh creek Common name Number Range in mm (Fork length) Mullet spp c.200 25-30 Bass c. 60 18-24 3-spined stickleback 1 n/a Sand/Common Goby 100 <20 The presence of large numbers of juvenile Bass, Mullet, Herring, Sprat and lesser species show that if these results are scaled up the value to fisheries alone in Pegwell Bay is highly significant and this is one of only two areas of permanent saltmarsh in the Eastern Channel waters between East Sussex and Thanet. Environment Agency’s view of landfall options: With regard to the landfall options, we consider that Option 1 is the less damaging to the saltmarsh habitats and should be given highest priority. Option 3 is the second least damaging but has a larger impact upon the saltmarsh than Option 1.These impacts were assessed to be temporary and we agree with this assessment provided careful mitigation measures are taken during the construction phase and baseline topographic heights are reinstated. Option 2 is potentially the most damaging of all and could result in permanent fragmentation of a regionally important habitat. We object to this option. There does not appear to be a clear evidence pathway that fully explains why alternative landfall sites were discounted, what the constraints were and why options such as running up the river Stour channel were not assessed other than potential movement of the river channel (this point needs to be explained why it is not feasible in the projected life of the wind farm infrastructure – i.e. is there evidence that the river channel has moved significantly over last 25 years?). References Bell F.W. (1997) The economic valuation of saltwater marsh supporting marine recreational fishing in the south eastern United States. Ecological Economics 21, 243–254. (PDF copy attached) Boesch D. & Turner R. (1984) Dependence of fishery species on saltmarshes: the role of food and refuge. Estuaries 7, 460–468. (PDF copy attached) Colclough S., Fonseca, L, Astley T., Thomas, K. & Watts W. (2005) Fish utilisation of managed realignments Fisheries Management and Ecology, 2005, 12, 351–360 (PDF copy attached). Environmental Statement Volume 4 Annex 3-1: Water Framework Directive Assessment The Water Framework Directive (WFD) and its daughter directive the Environmental Quality Standards Directive (EQSD) sets forth the chemical concentration limits for controlled substances in the water of EU designated coastal and transitional waterbodies, and provides a classification method to describe the chemical and ecological status of each waterbody, using a variety of classification tools of which water quality is simply one element. The aim is to prevent deterioration of status and manage improvements towards good status. Activities requiring a marine licence must be assessed for the potential impacts upon the status of the waterbody and their potential to prevent the achievement of good status (or other alternative objectives as set out in the river basin management plan) for that waterbody in the future. We publish guidance on how to conduct an assessment for WFD risk, https://www.gov.uk/guidance/water-framework-directive-assessment-estuarine-and-coastal-waters This guidance includes how to scope in/or out any activity from a further “impact assessment” stage, by considering each of the elements contributing towards WFD status. Water quality elements are considered within the water quality section of the scoping form , which asks the applicant relevant questions, the answers leading the applicant to either scope out the activity form further assessment or to conduct a full impact assessment, where relevant evidence and arguments must be presented to justify acceptable risk levels for WFD compliance . In the case of water quality there are clearly defined concentration limits for whole suites of chemicals which must not be exceeded, and are necessarily numerical and complex in order to justify whether sufficient dilution of contaminant chemicals is available in cases where sediment may be disturbed which contains any of the chemicals for which standards exist in WFD and EQSD. Bathing and shellfish waters are also included as protected elements of WFD water quality, and here the triggers for compliance /non-compliance relate to bacterial concentrations in water and in shellfish flesh respectively. There being no accepted methods to characterise the bacterial levels in sediments, it can be complex and expensive to attempt to predict the transfer of sediment bacteria into the water column (where it might affect bathing water compliance) or from the water column to shellfish flesh, and often it is more sensible to be precautionary about timing the activity to avoid the bathing season altogether (ensuring certainty that bathing waters classification cannot be affected) than take risks which are assumed to be low but are, in reality, unknown due to uncertainty in sediment bacterial concentrations. The water quality elements of the WFD Assessment, which the applicant claims to have undertaken using the Environment Agency’s own (Clearing the Waters for All) published guidance for conducting such an assessment, lack any rigorous numerical justification of WFD compliance, and do not provide any justification for “scoping out “water quality from a more detailed impact assessment. Had the applicant followed our guidance correctly, then they would have identified a potential risk from disturbing sediments which contain “substances on the EQSD list AND substances on the CEFAS list at levels above CEFAS Action level 1”-and this would be an automatic trigger NOT to scope out water quality, but to proceed to “impact assessment” stage- where we would expect more detailed and numerical consideration of the potential impacts on water quality. We would expect consideration of the existing background concentrations of these chemicals in the waterbody, and a numerical calculation with any assumptions justified, of the load transfer of each chemical from sediment to water, to calculate what uplift, if any , in the ambient water column concentration would occur at the site where the disturbance of sediment is taking place, how long such uplifts will last and what area of waterbody, if any, may suffer uplifts in concentration that would exceed the EQS limits for the waterbody. There being two standards for some substances (Annual Average, and Maximum Allowable Concentration) for which Environmental Quality Standards (concentration based limits for water) exist, both need consideration where both have limits. No figure for dilution capacity in the receiving water body has been provided, so the conclusions that the activity remains WFD compliant for water chemistry remains opaque. Similarly the conclusions regarding the activity being benign for bathing water quality are largely based on drawing parallels with earlier activity, which is no guarantor of future bathing water quality, as the bacterial levels in the sediments were not tested either then or now, and the prediction of compliance is based entirely on the assumption that there will be adequate dilution of any mobilised load before it reaches the bathing water. Again no dilution factor is actually provided so this is speculative, and as the initial load (bacterial concentration in sediment) is unknown anyway, there may or may not be sufficient dilution. As the actual risk is unknown, it would be safer to have a requirement within the Development Consent Order which allows for a temporary cessation of works should the bathing waters be seen to deteriorate when work is in progress. This would probably be a more proportionate and acceptable option than to require that the sediment disturbing operations are limited to occur outside the bathing waters monitoring period – which is the only certain means of ensuring the activity cannot impact upon bathing water quality if the sediments do contain significant bacterial loads at the time of disturbing them. This is not to say that we believe the activity will result in a WFD deterioration, the general points made about high (but unspecified) levels of dilution may well suggest compliance, but we consider that the current assessment does not provide the detailed “impact assessment” arguments of a more technical and numerical nature that we would consider a proper part of the WFD water quality assessment. Arguments for compliance need to be supported by evidence. Environmental Statement Volume 5 Annex 6-1: Phase 1 Geo-environmental Desk Study The phase 1 geo-environmental report submitted with the application states: This Phase 1 report constitutes a robust characterisation of the receiving environment to support the EIA. The site reconnaissance and desk-based assessment has identified a number of potential contaminant linkages and geo-environmental constraints associated with the proposed onshore development. In order to gain a more detailed understanding of these constraints, further SI and assessment would be required post-consent as part of the detailed design process, prior to construction. As additional site investigation works are required to assess the on-shore impacts as part of the detailed design process we request these elements are included in any consent requirements. The wording in the draft DCO appears to cover these issues adequately and further investigation and relevant actions should follow CLR11 protocols to comply with these requirements. The CLAIRE Definition of Waste: Development Industry Code of Practice (version 2) provides operators with a framework for determining whether or not excavated material arising from site during remediation and/or land development works are waste or have ceased to be waste. Under the Code of Practice: • excavated materials that are recovered via a treatment operation can be re-used on-site providing they are treated to a standard such that they fit for purpose and unlikely to cause pollution • treated materials can be transferred between sites as part of a hub and cluster project formally agreed with the Environment Agency. • some naturally occurring clean material can be transferred directly between sites. Developers should ensure that all contaminated materials are adequately characterised both chemically and physically, and that the permitting status of any proposed on site operations are clear. If in doubt, the Environment Agency should be contacted for advice at an early stage to avoid any delays. • The Environment Agency recommends that developers should refer to: • the Position statement on the Definition of Waste: Development Industry Code of Practice and; • The Environmental regulations page on GOV.UK Any re-use of excavated materials not undertaken formally using the CLAIRE DoWCoP would require an environmental permit for deposit, unless materials are solely aggregates from virgin sources, or from a fully compliant Quality Protocol aggregates supplier. Any deposit of materials outside of these scenarios could be subject to enforcement actions and/or landfill tax liabilities. Environmental Statement Volume 5 Annex 6.2: Flood Risk Assessment Provided the recommendations and guidance provided within the submitted Flood Risk Assessment are followed, we have no flood risk related concerns or requirements related to the development proposed. As per our previous response, we would encourage further engagement with us once more is known about the chosen option for the Transition Joint Bay (TJBs) (i.e. the general areas where the cable comes ashore and the associated transition arrangements). We would also recommend that we are contacted to discuss the means of crossing the Minster Stream, along with any other works within 16m of the tidal River Stour (or within 8m of the Minster Stream). Any such works will require a Flood Risk Activity Permit prior to the commencement of any construction within the byelaw margins. This is of particular concern owing to the outlined proposals for the required reconstruction of the existing culvert. Draft Development Consent Order (DCO) Due to our concerns in relation to the proposed landfall options - the potential significant the loss of saltmarsh, as well as the additional clarification needed with regards to the Water Framework Directive - we consider that the draft DCO does not adequately deal with these issues. The current draft DCO looks at addressing all the landfall options by considering the worst case scenario (Option 2) which we have previously advised 2 should not be an option in our opinion. We do not provide detailed comments on the draft DCO at this stage as we consider there are still fundamental issues that need to be overcome, specifically a decision on which landfall option the applicant intends to progress with. Please see attached. "
Members of the Public/Businesses
Winckworth Sherwood LLP on behalf of Estuary Services Limited
"Estuary Services Limited ("ESL") is a company jointly owned by Port of London Authority and Peel Ports, set up in 1988 to provide pilot boarding and landing services at the North East Spit (from Ramsgate) and The Warps (from Sheerness). ESL serves approximately 10,000 vessels per annum – c7,000 at the NE Spit area – and employs 35 seagoing staff, some with over 30 years’ experience in fast pilot launch boarding and landing operations in the area. ESL is concerned about the proposals to extend the existing Thanet Offshore Wind Farm, located in the Thames Estuary in the area served by ESL, due to their potential impact on the safety of navigation and the efficiency of ESL’s maritime operations. The wind farm extension proposals are in close proximity to the boarding locations utilised by ESL, with that at the North East Spit most affected. ESL considers that any extension to the west of the existing wind farm will significantly increase the risks to navigation, particularly for vessels using the North East Spit pilot boarding and landing area to enter or depart the Thames Estuary. The North East Spit boarding and landing area was created as a result of the construction of the existing wind farm, being the next most suitable location for the serving of the majority of vessels. The outer Tongue boarding and landing area was later instated due to concerns from some larger ships in approaching the hazard of the wind farm. The Applicant’s proposals would force more vessels to use the outer Tongue pilot boarding station, which would itself be pushed further from the shore. This would adversely affect where ESL operates, and lengthen transfers, necessitating additional vessels, maintenance, fuel and personnel. The longer distance to run launches would result in a lesser service and longer delays, particularly in heavy weather where safe transfer of pilots would be at risk. As such, the proposals would have a significant impact on the efficient operation of ESL’s boarding and landing service, seriously diluting the level of service to the ports. Navigational safety is also a concern for ESL. The proposals would reduce the sea room to the west of the existing wind farm, affecting the shipping corridor running north west/south east between the wind farm and the shore. Even with the Applican’ts modifications, the proposals would push vessels further west towards shallower waters and reduce the width of the sea room in this area by 50%. The North East Spit boarding and landing area may well become unusable, particularly at certain tides and where the prevailing south-westerly wind would tend to push vessels towards the wind farm turbines. Other impacts of the proposals in respect of navigational risk include loss of the line of sight where inbound vessels may no longer be visible to outbound vessels, backscatter of lights and possible loss of radar targets. ESL seeks protection within the Order against sedimentation of the channels in the approach to the Port and for measures to minimise navigational risk. "
Members of the Public/Businesses
Estuary Services Ltd
"Safe navigation of vessels into and out of The Thames estuary. How much of an eye sore....!!! we all ready have....!!! , Cost and how much more of taxpayers money is going to be wasted...!!! Damage to the local fishing industry ( fishing grounds )."
Members of the Public/Businesses
Hazel Soper
"I object to the extension in that Vattenfall Wind Power Ltd has not made it known it is a wholly owned subsidiary of the Swedish State, with the confirmed intention to retain state ownership and not to allow privatisation. As such its interests are solely to benefit its shareholders, the Swedish State. Vattenfall has disseminated a leaflet in Thanet which says "Many told us they wanted to recognise Thanet's world leading role in renewables". In that case, many have made clear they wish Thanet to have a world leading role, they have not expressed a want for the Swedish State to have such a role in Thanet. The educational benefits in Thanet appear limited to education in energy consumerism. As a state backed operation there has been no open competition, and unless there is some sharing with the UK state, there should be more investigation into Vattenfall/Sweden's activity in UK waters. "
Other Statutory Consultees
Historic England
"On 1st April 2015 Historic England was vested (retaining the formal title of the Historic Buildings and Monuments Commission for England) and is now the government service championing England’s heritage and giving expert, constructive advice. Historic England has had significant pre-application discussion with the applicant, providing comments on the Scoping and PEIR stage. Historic England has maintained a constructive partnership and been fully engaged with the applicant at this stage of the planning process on all aspects of the historic environment and its heritage assets, on land (onshore) and on the seabed (offshore). We summarise our representation regarding this proposed project as follows: 1. We note that the levels of harm caused by the proposal to onshore designated heritage assets have been amended since the PEIR report. We are not in a position to comment in detail on these amended levels of harm, but will provide substantive comments at the DCO response stage. We do however question the report’s assessment of the harm to Margate’s Conservation Area which has been assessed as negligible and the assessment of the relationship between the buildings within it to the sea. 2. We do not agree with the stated level of impact upon onshore geoarchaeological deposits. Further assessment of this impact, and appropriate geoarchaeological mitigation, should be discussed with Ben Found of Kent County Council (KCC). The availability of geoarchaeological data is disparate for the area; any further geoarchaeological assessment should therefore be undertaken with the aim of contributing to an overall, integrated deposit model for the Wantsum Channel Area. 3. Further assessment of the potential for 20th century anti-invasion defences at and buried archaeology relating to the possible Caesarian invasion site (both in Pegwell Bay), may also be necessary to inform design of a route that will avoid harm as far as possible; these matters should be discussed further with Ben Found. 4. KCC’s Heritage Team is best also placed to advise the applicants about their detailed scheme design and archaeological work, but we are ready to contribute if we can add value, particularly if archaeology of national significance emerges. Archaeological mitigation of unavoidable harm is likely to be necessary. 5. With regard to implementing the Offshore Written Scheme of Investigation (WSI), in accordance with any Development Consent Order (DCO) (including a Deemed Marine Licence) secured for this proposed project, Historic England considers clear and systematic time-framed method statements will be required to optimise survey opportunities. Each planned package of work - in addressing the need for appropriate mitigation for predicted impacts to potential archaeology - should also include the objectives of local and national research frameworks. 6. We note and welcome (from the Offshore Archaeology and Cultural Heritage – Document Ref: 6.2.13, para. 13.4.26 and WSI respectively) that gaps in existing geophysical/geotechnical data will be acquired prior to construction. In the planning of the geotechnical survey it is important that the appropriate depth for continuous stratigraphy is incorporated - to mitigate impacts to deposits of high archaeological potential. Additionally boreholes should be stored and maintained to maximise archaeological objectives. 7. Within the Draft DCO (Document Reference 3.1), the wording under the subheading ‘Pre-construction plans and documentation’ in Schedule 11 (Deemed Licence under the 2009 Act – Generation Assets) and Schedule 12 (Deemed Licence under the 2009 Act – Export Cable System) requires amendment and we will supply revised wording in our Written Representation. 8. Close to the proposed development is the Goodwin Sands, an extremely dynamic mobile sand bank, well recognised as a major seafaring navigational hazard over the centuries, containing sediments conducive to the preservation of significant heritage assets. Added to this, at times, sediments can cover heritage assets at substantial depths masking their identification by standard methods of geophysical survey techniques. The applicant is therefore encouraged to accurately address and consider the changing nature of the seabed, in relation to the total depth and width of the trenches required for the installation of the export cables, and in respect to the high potential for buried objects of archaeological interest."
Non-Statutory Organisations
Kent Wildlife Trust
"Kent Wildlife Trust (KWT) is the county’s leading nature conservation charity which manages over 60 nature reserves covering over 8,000 hectares across Kent. We are supported by over 31,000 members and some 1,000 registered volunteers. KWT aims to protect and improve habitats in the countryside, coasts, seas and towns for the benefit of wildlife. This representation focuses on our longstanding strong objection to the onshore cable landfall route, and includes comments regarding offshore cables and monitoring proposals. Onshore landfall option: We strongly object to the chosen landfall option of Pegwell Bay due to the direct impacts on its important nationally and internationally designated habitats. Sandwich and Pegwell Bay comprises a National Nature Reserve (NNR), Site of Special Scientific Interest (SSSI), Special Area of Conservation (SAC), Ramsar site and Special Protection Area (SPA). We believe that alternative routes with less of an impact on designated areas have not been adequately assessed. KWT has repeatedly requested the evidence behind the claim made by the applicant that there is ecological parity between the chosen landfall (Pegwell Bay) and other potential (since discounted) landfall options; however the evidence provided to date has been limited. When an onshore ecological surveying programme was circulated by the applicant, it was stated that ecological surveys would be carried out along two potential onshore cable routes (Pegwell Bay and Sandwich Bay landfall route options). However, the majority of ecological surveys (with the exception of ornithological surveys) were only carried out along one route – the Pegwell Bay landfall route. The applicant has therefore not provided comparative ecological data from other potential onshore options. Full and comparable ecological surveys should have been carried out on both potential onshore routes before the landfall decision was made in order to influence this decision. Without adequate evidence KWT cannot accept arguments of parity since the original options show high levels of variability in areas of designated onshore and intertidal habitats affected. KWT therefore maintains its overarching objection to this development. Assessment of Impacts: KWT do not agree that examining the features of designated sites in isolation (for instance, when conducting recommended Marine Conservation Zone (rMCZ) assessments, SSSI assessments) is sufficient. A more thorough and comprehensive approach is to conduct full assessments which encompass the designated site as a whole, not just the designated features. The Marine Management Organisation (MMO) has granted permission to the Dover Harbour Board to dredge part of the Goodwin Sands rMCZ, which is in close proximity to the proposed development. Therefore, the applicant will need to evaluate the cumulative impacts of the proposed dredging activity alongside the current proposal. Benthic Cabling Impacts: We approve of the turbines and offshore export cable corridor being micro-sited to avoid areas of biogenic reef. However, we would like to see the evidence behind the suggestion that biogenic reefs are likely to reform over the top of buried offshore cables. We seek reassurance that the offshore cables will be buried to a sufficient depth (at least 1m) in order to reduce the impacts of Electromagnetic Field (EMF) on benthic species and reduce the likelihood of the cables becoming exposed. Monitoring: We believe that post-construction benthic monitoring should be incorporated into the conditions of the Deemed Marine Licence (DML). This will provide comparative data for pre- and post- construction conditions in and around the windfarm which can be added to existing datasets and literature on UK windfarms to help inform future offshore developments. This would also follow best practice and is a way of examining whether the pre-construction assumptions made by the applicant were accurate. We suggest that post-construction monitoring of the cable route is carried out to measure the presence or absence of biogenic reefs and species on the sediment overlaying the cables. "
Members of the Public/Businesses
response has attachments
Marine Management Organisation
"Dear Sir/Madam Due to the word limit in this section, please refer to the email sent on the 12 September 2018 to the following email address [email protected], for the Marine Management Organisation's relevant representation. This document comprises the MMO’s initial comments in respect of the DCO Application. Please see attached"
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. This includes maintaining our obligations under The United Nations Convention of the Law of the Sea. In the early stages, MCA raised concerns regarding extent of the red line boundary to the west, and requested that specific impacts were thoroughly assessed in the Navigation Risk Assessment (NRA). Vattenfall have considered these issues in line with our guidance MGN 543, and our published risk assessment methodology. The NRA deems the increase in risk to be tolerable; that pilot boarding is still feasible, the increase in vessel routing is not significant, that vessels will be constrained and that these issues are manageable. The NRA also states that the increase in risk is further mitigated by a reduction of the redline boundary, as submitted in the application for consent. The MCA does not accept that the increase in risk is tolerable with the current proposed redline boundary, considering the collective impact and the resultant changes that will be required in an already highly complex area for navigation. There will be more pressure on pilots, additional burden on the PLA within their VTS jurisdiction, operational implications, and more pressure on mariners with a reduction of available sea space on the western extent. The MCA’s view is that the reduction to the redline boundary was not to the extent we were expecting in response to the concerns raised during the pre-application consultation, and we cannot conclude that the risks are reduced to ALARP with the risk controls identified in the NRA. The MCA strongly recommends that Vattenfall reconsider the western boundary, and we would welcome the opportunity to discuss further options with Vattenfall until such time the risk is considered to be acceptable by MCA and its stakeholders. The MCA must take into account the significant concerns raised by our stakeholder regarding this extension, and we support the representation submitted by the SUNK VTS User Group, which includes representatives of both Navigation Safety Branch at MCA and HM Coastguard. "
Other Statutory Consultees
Maritime and Coastguard Agency
"This response is written on behalf of the Sunk User Group, and endorsed by the Chairperson, representatives of HMCG and the Vessel Traffic Services Policy Steering Group (VTS PSG). This VTSPSG was established by the MCA to help meet the United Kingdom’s obligations under SOLAS Chapter V Reg. 12 and the EU Traffic Monitoring Directive. The Sunk User Group is a principal stakeholder forum chaired by MCA, to ensure co-operation between relevant key stakeholders for the safe and efficient operation of the Sunk Vessel Traffic Services (VTS). This Forum concluded at its meeting on 25th July 2018 that the significant concerns raised by its stakeholders remain, despite the mitigation proposed in the Navigation Risk Assessment (NRA) and the reduction in the red line boundary. The forums’ opinion on the recent alterations to the red line boundary is extant in the understanding that it has not addressed the issue. Whilst it is understood that the NRA mentions only a limited impact to traffic routing, it is evident that the traffic passing between the windfarm and the Kent coast will be squeezed further to the west. The sea-room for pilot boarding and landing at the NE Spit will be significantly reduced, forcing more vessels to use the Tongue, which will also be forced to be relocated further out to the north east. This will further impact on pilotage transfer times and piloted voyage times and in worse weather will reduce the availability of the pilot stations altogether. There is also concern regarding the required 500m safety zones around windfarms, further reducing navigable sea room, unless Vattenfall do not place any turbines within 500m of the red line boundary. The forum agrees that the current NRA is not detailed enough and do not believe this to be a true reflection of the operations within the area. This is particularly evident in the pilotage study which appears to have been completed in sterile conditions, using experienced pilots and not unfamiliar overseas Masters’, as is the clear risk to navigation within the area. The current NRA relies heavily on the others to change their operation to fit with the development, particularly with regards to buoyage, pilotage, communications and traffic. It is felt that this will put extra pressure on coordination on the movement of ships and efficiency of operation, which could impact safety within the area. Previous mitigation methods included a Marine Coordination Centre, which Vattenfall have since removed. The forum is not certain that the risk to navigation is suitably mitigated following the removal of this, however it was never determined who would coordinate the traffic. It also appears that the recommended watch of radar and CCTV during construction and decommissioning by Vattenfall would be limited due to the lack of coverage over other vessels. In conclusion, the current NRA does not appear to have suitably mitigated the risks with regards to current or anticipated future traffic to the area. "
Other Statutory Consultees
Ministry of Defence
"I write to confirm the safeguarding positon of the Ministry of Defence (MOD) in relation to the above application to construct and operate the propsoed Thanet Extension Offshore wind farm. I am writing to tell you that the MOD has no objection to the proposal. The application is for 34 turbines at 250.00 metres to blade tip. This has been assessed using the grid references below for the boundary outline as based upon the coordinates detailed in the application documentation: Turbine Easting Northing 1 656,669 181,338 2 658,777 179,199 3 656,879 170,961 4 650,579 171,197 5 649,998 171,787 6 648,983 172,817 7 646,312 175,599 8 646,432 179,616 9 647,608 180,705 10 652,279 173,381 11 656,466 173,384 12 656,342 175,996 13 652,489 179,863 14 650,119 179,748 15 648,019 177,656 The turbines and some of the associated tall ancillary offshore structures will affect military low flying training activities conducted in this area. As such it will be necessary for these structures to be fitted with appropriate aviation warning lighting to maintain the navigational safety of military aviation. The MOD has assessed the effects of the proposed wind farm development upon the effective operation of its air traffic and air defence radars. It has been confirmed that the proposed wind turbines will not be in line of sight or detectable to MOD air traffic radars and are not expected to impact upon the operation of air defence radars. However, the MOD has recently identified that in certain conditions the performance of air defence radars may be adversely affected by large scale offshore wind farm developments when they become operational. Based upon the technical evidence currently available the MOD does not identify a need for any form of mitigatory measures to address this potential issue to be implemented in relation to the scheme for which consent is currently sought. If consent is given the MOD will need to be advised of the following prior to commencement of construction; • the date construction starts and ends; • the maximum height of construction equipment; • the latitude and longitude of every turbine. This information is vital as it will be plotted on aviation charts which are used in the management of military low flying activities conducted in the area. I hope this adequately explains our position on the matter. If you require further information or would like to discuss this matter further, please do not hesitate to contact me. "
Other Statutory Consultees
response has attachments
Natural England
"Dear Sirs, Natural England is the statutory adviser to government on nature conservation in England and promotes the conservation of England's wildlife and natural features. We wish to be registered as an interested party, however we have a number of comments to make in our relevant representations. As a result, we have emailed a copy of our full response letter and associated appendices to the project email address. I would be grateful to receive confirmation that our response has been received. Kind regards, Will Hutchinson. "
Members of the Public/Businesses
Winckworth Sherwood LLP on behalf of Port of London Authority
"The Port of London Authority (“PLA”) is the statutory port and harbour authority for the tidal River Thames. The PLA is concerned about the proposals to extend the existing Thanet Offshore Wind Farm, which is located in the Thames Estuary in the approaches to the Port, due to their potential impact on the safety of maritime operations in one of the busiest parts of UK coastal waters. Whilst the proposals are outside the PLA’s statutory limits, they are in close proximity to the PLA’s pilot boarding locations, with that at the North East Spit most affected, and, moreover, the proposals have the potential to impact on the operation of the Port. The proposals would encroach into the existing shipping lanes, lengthening journey times into the Port for commercial services that would have to re-route around an extended wind farm. The existing wind farm already presents challenges to pilot operations, especially during busy times and strong winds, causing delays to vessel arrivals within the Port; these challenges would be exacerbated by the proposed extension. The PLA considers that any extension to the west of the existing wind farm will increase significantly the risks to navigation for all types of vessels, especially those using the North East Spit Pilot Boarding and Landing Area to enter or depart the Thames Estuary. The proposals would force more vessels to use the outer Tongue Pilot boarding station, which would itself be pushed further from the shore, adding significant costs to the service by lengthening the pilotage act, necessitating additional vessels, fuel and crews. This would also make the Port less resilient in bad weather, as pilots would be less able to board in heavy seas. The Applicant has recently modified its proposals by decreasing the western extent of the Order limits. However, this does not address the PLA’s concerns regarding the reduction in sea room to the west of the wind farm which will affect the shipping corridor running north west/south east between it and the shore. Even with the modifications, the proposals would push vessels further west towards shallower waters and reduce the width of the sea room in this area by 50%. The PLA has some concerns about Navigational Risk Assessment including the data used, the validity of specific studies, identification of relevant hazards and impacts, and the validity of the NRA methodology. Other impacts of the proposals in respect of navigational risk include loss of the line of sight where inbound vessels may no longer be visible to outbound vessels, backscatter of lights and possible loss of radar targets. In addition, the PLA remains concerned about the potential migration of sandwaves into navigable waters between the North East Spit and the shore. The proposals would result in an adverse impact on coastal processes, reducing further the amount of sea room within the navigational channel into the Port. The PLA seeks protection within the Order against sedimentation of the channels in the approach to the Port and for measures to minimise navigational risk. "
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 considered the submitted documentation and have considered the potential public health impacts arising from air quality, contaminated land and exposure to electric and magnetic fields. 1) Air Quality The submitted assessments have considered the potential impacts of the proposed development on air quality in the vicinity of the development, including the adjacent air quality management area. We are satisfied with the approach and methodology used to assess both baseline air quality and the potential impacts arising from both the construction and operational phases of the development. We note that the immediate and cumulative impacts are assessed as negligible and, subject to the local authority being in agreement with your conclusions, do not believe that the proposed development poses a significant risk to public health in terms of air quality. 2) Contaminated Land/ Risks to controlled waters. The proposed development requires the running cables thorough a closed landfill site at Pegwell Bay following landfall. We are satisfied that the assessment followed standard UK process and good practice and notes the conclusion that the potential impacts on both the environment and on public health can be adequately managed by industry good practice measures and the integral design of the installation. The Local Authority (LA) and Environment Agency (EA) are the lead agencies for contaminated land and potential impacts on controlled waters. Subject to both the LA and EA being satisfied with the proposed design and mitigation measures We are satisfied that the contaminated land issues can be adequately managed and that the development should not pose a significant risk to public health. 3) Electric and Magnetic Fields We note that the submitted documentation includes an assessment of the potential impact of electric and magnetic fields. We are satisfied with the assessment methodology used by the applicant and that the development should not pose a significant risk to public health. We have registered an interest on the Planning inspectorate Website, including the above comments. Please do not hesitate to contact us if you have any questions or concerns. "
Members of the Public/Businesses
response has attachments
Charles Russell Speechlys LLP on behalf of Ramac Holdings (Trading) Limited
"These representations are made on behalf of Ramac Holdings (Trading) Limited (‘Ramac’), in response to the application for a Development Consent Order (“DCO submission”) submitted by Vattenfall to the National Infrastructure Directorate on 27 June 2018. The Development Consent Order Pre-Application Consultation Response submitted by Glenny LLP on 12 January 2018 is referred to as PCR. Concerns raised in the PCR by Ramac have not been addressed by the DCO submission, and Ramac formally objects to the DCO application both for the reasons set out in the PCR and those summarised below (and as expanded in the more detailed submission provided to the Planning Inspectorate in hard copy). The content of Ramac’s PCR is quoted verbatum in the DCO submission appendices document, Ref. 5.1.1 and, in particular, Appendix G2.2 and against each detailed concern raised by Ramac, Vattenfall’s response is simply that “Land ownerships are still under a consultation with all relevant parties and will be taken forward in the Post-Consent phase”. Vattenfall has failed to address any of the issues raised by Ramac in its PCR and in particular but not restricted to the following:- 1) The proposed project has an anticipated lifespan of 50 years and it is not therefore necessary for Vattenfall to acquire a freehold interest. 2) None of the alternative locations proposed in the PCR have been given any consideration whatsoever. 3) Technical questions raised by the PCR involving the extent of the land required for the substation and the alternative design solutions which may result in no/a reduced permanent land requirement have not been considered. Ramac is concerned that if terms cannot be agreed , the DCO in its present form would enable the Acquiring Authority to take their freehold interest in the majority of Richborough Port and the case for this is not properly addressed. In accordance with Sections 42, 47, 48 and 49 of the Planning Act 2008, Vattenfall has a “duty to take account of responses to consultation and publicity” (Section 49). For the reasons set out above and in the more detailed submission, Ramac considers that inadequate consultation has taken place Referring to the ‘Advice Note 9: Rochdale Envelope’ published by Infrastructure Planning Commission February 2011, the question of flexibility is addressed. On page 10 it states:- “Under the 2008 Act it is important to consult comprehensively on the project and to report fully on that consultation. The process should be clear and thorough.” Ramac considers that Advice Note 9 has not been followed in the DCO process and the application now made. The Rochdale Envelope makes clear that “flexibility” is not to be abused, and “does not give developers an excuse to provide inadequate descriptions of their projects”. Ramac is not concerned with wind turbines but rather the proposed location and size of the substation which Ramac submits Vattenfall have failed to justify or explain. Ramac is willing to engage in constructive dialogue with Vattenfall for early agreement in respect of the project. However, until this process has been completed or negotiations have been exhausted, Ramac objects to the the DCO in its present form for the reasons set out and reserves its rights to provide further submissions (beyond those provided to date) during the course of the DCO examination process. Please see attachment "
Non-Statutory Organisations
Royal Society for the Protection of Birds (RSPB) (Royal Society for the Protection of Birds (RSPB))
"Our involvement with Thanet Extension Offshore Wind Farm The Royal Society for the Protection of Birds (the RSPB) has been involved with the Thanet Extension Offshore Windfarm (TEOW) project as a member of the Onshore Ecology and Offshore Ornithology Expert Topic Group (ETG). Through this process we have endeavoured to inform the design of the scheme to minimise the risk of harm to its ornithological interests. Despite welcome constructive pre-application consultation and discussions, serious concerns with the offshore aspects of the Application remain. As it stands, we do not agree that the current assessment enables a conclusion of no adverse effect on the Special Protection Area (SPA) sites and their species. Due to resource constraints, this representation comprises the RSPB’s final submission to the Examination however we reserve the right to add to or change this submission should the design of the scheme change and/or significant new information is submitted. Onshore Ornithology The RSPB is content that, on the basis of the data provided, this project will have no significant impact on the SPA, Ramsar site or SSSI bird features (1). For clarity we wish to add that whilst we agreed that little terns are unlikely to be affected, this is due to the location of the historical nesting site being at a safe distance from the development area and therefore there will be no risk of being affected, not because little terns are not currently nesting on site. We are aware that the Kent Wildlife Trust will be raising other concerns relating to, among other things, intertidal habitat and we defer to them on those habitat concerns. Offshore Ornithology The proposed Thanet Extension Offshore Wind Farm (TEOWF) is 8km offshore from the Kent coast and surrounds the existing Thanet Offshore Wind Farm. The Outer Thames Estuary SPA, which is classified for its population of non-breeding red throated divers, is approximately 4km from the closest proposed Turbine location. Key elements of the assessment of offshore ornithology, as presented in the Environmental Statement (ES), do not follow SNCB guidance or advice given by Natural England (NE), nor our suggested approach during consultation. We find that the information presented, especially in relation to displacement, to be unsatisfactory, in terms of presenting an assessment of impacts, which does follow recommended guidance, alongside that given in the ES. In addition, some apparent errors in the tables and text, and lack of detail in places, has resulted in an unclear assessment in relation to offshore ornithology, parts of which we consider to be inadequate. These concerns are set out below. Methodology Displacement assessment • Red throated diver: This is a species of key concern within the region that the proposed Thanet extension is situated. Several aspects of the assessment do not follow SNCB guidance (SNCBs (2017)), or the advice given by NE (which we support) during consultation. Specifically, the rates of displacement (82% during construction and 73% during operation) and the spatial extent used (i.e. that consideration have been given to the windfarm area only without any buffer zone). This is justified on the basis of the evidence provided from post-construction monitoring (Royal Haskoning DHV, 2013). Whilst ‘local’ data and knowledge can be useful in informing an assessment, the report cited has limitations, for example the use of boat-based surveys and the limited buffer-size of the survey area. More robust sources of ‘local’ information, include the post-construction reporting from London Array (APEM, 2016); which shows evidence of displacement to at least 6km. We maintain that, in light of this and the wider evidence base suggesting that displacement of red throated divers goes beyond the wind farm footprint, a precautionary approach would be to follow SNCB guidance and assume that up to 100% of birds within the 4km buffer are subject to displacement during both construction and operation. • Auks: The assessment for both razorbills and guillemots during construction and operation, also fails to follow SNCB guidance; both in relation to the spatial extent covered and displacement rates used. It is unclear (due to inconsistencies in the text/ table legend) if 500m or 1km buffers were used for razorbill but neither species was assessed using the 2km buffer recommended. • Gannet: Again, SNCB guidance, to include birds within a 2km buffer, has not been followed. Collision risk modelling • Option 2 (using generic flight height distributions) of the Band model is presented within the ES chapter. It is preferable that site-specific data is used to inform collision risk (option 1); if available and robust. Specifically, the data collected during the Offshore Renewables Joint Industry Programme (ORJIP), study of collision and avoidance, which was conducted at Thanet Offshore Wind, are one potential source of site-specific data. We note that in Annex 4-4 these data were not used due to ‘ongoing uncertainties’ in relation to the Band model. Whilst we agree that the avoidance rates derived in this study are subject to such uncertainty, it is unclear why the flight height data could not be used. Greater detail, in relation to the ORJIP, historical and recent survey data is needed to explain why option 1 was not presented in the ES. Both options 1 and 2 are provided in Annex 4-4; it would therefore be helpful if an indication were given as to how reliable the figures given for option 1 are thought to be (if unreliable, it is unclear as to why they are presented). • We do not agree with the use of revised Nocturnal Activity Factors in the CRM. For kittiwake and large gulls, there is no peer reviewed evidence for a change in the factor used. The current factor is derived from the expert opinion collected by Garthe and Hüppop (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. For gannet, there is a peer reviewed paper with revised rates (Furness et al., 2018). While we welcome this review, we are concerned that the mortalities predicted using revised nocturnal activity rates for gannet are potentially underestimated, because they do not account for the fact that the timing of bird surveys might not coincide with peaks in foraging activity at first and last light (see Fig. 3 in Furness et al., 2018). As well as gannet, this is true for all other species concerned. In addition, 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. The reduced factor, now used for gannet in the CRM, equates to 0% nocturnal activity. Evidence shows that gannet will forage at twilight, and so these flights are excluded when using the revised activity factor. All of the above means that the figures presented in the ES for collision risk may represent an underestimate for all species. Cumulative and in-combination assessments • Displacement: We have concerns with the methodological approach used to assess cumulative and in-combination displacement for red throated divers. To date, we have not been provided with sufficient detail to enable us to determine its robustness or suitability. Such detail is not provided in the ES or Annexes. For example, apparent inconsistencies in the predicted increase in background mortality in relation to the impact of ‘Thanet Extension alone’ on the Outer Thames Estuary SPA, presented in paragraph 11.4.12 (at 0.7%) and Table 12.13 (at 0.024%) of the Report to Inform the Appropriate Assessment (RIAA), are of concern and need further explanation. • Collision: The in-combination assessment of collision impacts, within the RIAA, focuses on the contribution made by this extension application rather than the total impact ‘in-combination’ from across all sites. Offshore ornithology impacts • Red throated diver: Had SNCB guidance been followed, 696 divers would be subject to displacement impacts vs the 195 (construction) or 174 (operation) presented in the current assessment. We therefore consider the current magnitude of the impacts of displacement on red throated divers to represent a substantial underestimate. Lack of clarity and the uncertainties surrounding the methods used for the cumulative assessment of displacement, mean we cannot currently agree with the conclusions in relation to the magnitude of this impact on red throated diver. For the in-combination assessment of red throated diver displacement, presented in the RIAA, lack of detail relating to the methods, especially in relation to assessing the absolute impact (additional mortality) mean we cannot currently agree with the conclusion of “no potential for AEoI to the red-throated diver feature of the Outer Thames Estuary SPA in relation to in-combination disturbance and displacement effects”. The consequences of changes in background mortality (even of a small magnitude) on red-throated diver populations are not currently well understood. In order for a clearer understanding of this, particularly in relation to the in-combination impacts, we recommend that a population model is run, and that counterfactual output metrics are presented (Cook & Robinson, 2017); pending the resolution of the issues surrounding the assessment methods used. • Auks: For guillemots the annual estimate given in the ES of 552 individuals subject to displacement falls within the range of 336-782 that would have been estimated, if the recommended 30-70% displacement including a 2km buffer had been used. For razorbills this is less clear, as it was not possible to compare the annual displacement due to an apparent error in table 17 of annex 4-3. However; the ‘spring’ data for razorbills suggest displacement of 33 individuals (given in the ES) was an underestimate (38-87 would have been estimated if SNCB guidance were followed). Overall, it is likely that auk displacement has been underestimated (relative to the most precautionary 70% displacement), but less severely than for red throated divers. • Collision risk: It is the RSPB opinion that the overall in-combination impact cannot be considered non-significant based only on an assessment of the magnitude of the extension application’s contribution. This is especially pertinent when it comes to gannets and kittiwakes since very large impacts have already been predicted on these SPA populations in the southern North Sea (for example see East Anglia Three, in-combination totals (Royal Haskoning DHV et al., 2015). (1) Bird features include: - Thanet coast &Sandwich bay SPA designated species: ruddy turnstone, European golden plover and little tern - Thanet coast to Hacklinge Marshes SSSI: dunlin, oystercatcher, curlew, redshank, grey plover, sanderling, ringed plover, mallard, shelduck, brent goose - Thanet coast &Sandwich bay Ramsar site: turnstone, ringed plover, golden plover, grey plover, sanderling and Lapland bunting References APEM (2016). Assessment of Displacement Impacts of Offshore Windfarms and Other Human Activities on Red-throated Divers and Alcids. Natural England Commissioned Reports, Number 227. APEM Ltd. Band, W. (2012). Using a collision risk model to assess bird collision risks for offshore windfarms. Guidance document. SOSS Crown Estate. Cook, A. S., & Robinson, R. A. (2017). Towards a framework for quantifying the population-level consequences of anthropogenic pressures on the environment: The case of seabirds and windfarms. Journal of environmental management, 190, 113. Furness, R. W., Wade, H. M., & Masden, E. A. (2013). Assessing vulnerability of marine bird populations to offshore wind farms. Journal of environmental management, 119, 56-66. Furness, R. W., 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. 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(4), 724-734. Royal Haskoning DHV (2013). Thanet Offshore Wind Farm Ornithological Monitoring 2012-2013 (Post-construction Year 3). Royal Haskoning DHV Report for Vattenfall Wind Power Limited. Royal Haskoning DHV, MacArthur Green, & APEM (2015). East Anglia THREE: Information for Habitat Regulations Assessment. Report for Vattenfall Wind Power Limited & Scottish Power Renewables. SNCBs (2017) Joint SNCB Interim Displacement advice note. Wade, H. M., Masden, E. A., Jackson, A. C., & Furness, R. W. (2016). Incorporating data uncertainty when estimating potential vulnerability of Scottish seabirds to marine renewable energy developments. Marine Policy, 70, 108-113. "
Local Authorities
Thanet District Council
"Thanet District Council are supportive of proposals which generate renewable energy as a key tenant in the economic, social and environmental dimensions of sustainable development within the National Planning Policy Framework. The issues outlined in the Council’s pre-application response comprised the visual impacts of the development, potential impact on air quality from the on-shore construction works, noise and nuisance impacts from on-shore work, impact on land quality from ground works during construction, socio-economic and tourism impacts and shipping and navigation issues. The Nationally Significant Infrastructure Project (NSIP) application has taken account of the matters raised throughout the process by the Council. It is considered that the main issues to be considered by the Examining Authority from Thanet District Council’s perspective are: - The visual impact of the new turbines on the seascape and landscape character area designations within the district. - Impacts from the construction works and operation on land quality, human health, controlled waters and ecological receptors from onshore development. The Council does not object to the development on the issues raised above, however believes that these matters should be carefully considered by the Examining Authority. In particular, the Council raises concern at this stage over the short-term construction and long-term operational impacts from noise from the substation at night on residential receptors in Ebbsfleet, and the potential impacts from contaminant releases at the landfill site during the construction phase. The Council’s concern on noise impact from construction and operation of the substation relates to 8 residential receptors (denoted as LT4 within the Environmental Statement Volume 3 Chapter 10) and we will continue to assess the information provided with the application and engage with the applicant on this matter. The requirement for intrusive site investigation works and groundwater monitoring prior to construction, necessary to inform appropriate mitigation, and how this is secured through the Development Consent Order requirements, will be assessed in subsequent submissions by the Council. The Council does not raise any objection with the assessment of significant effects within the Environmental Statement on the matters within the application as submitted, except for significance of impact on residential receptors at LT4 from noise. The Council does not wish to raise objection in terms of air quality following the analysis of the applicant’s submission, which appropriately assesses any significant adverse effects or unacceptable risks. The Council are content that the Thanet’s historic landscape has been considered in the submission and that the conclusion that the impact on the overall character and significance of the heritage assets in the district (above ground) would be limited. Concerns previously raised regarding the potential impact on the tourism economy relate to the impact on the seascape and landscape character areas designations from the development. This impact is not quantifiable and therefore is not brought forward as a main issue by the Council, but as a general concern. The Council considers that the submission deals with the concerns raised in relation to shipping and navigation issues through the changes made to the project. With regard to other matters such as traffic and transport, archaeology and ecology, we would defer to the appropriate agencies and organisations already involved in the process. "
Other Statutory Consultees
The National Trust
"The National Trust is a leading conservation charity with over 4 million members, which has a statutory duty ‘to promote the permanent preservation of places of historic interest and natural beauty, and their enjoyment by the public, for benefit of the nation, forever, for everyone”. The National Trust does not consider that para 2.6.81 of the Renewable Energy Infrastructure (NPS EN-3) statement has been adequately addressed. It is considered that the explanation for the choice of cable landfall across the Pegwell Bay inter-tidal mud flats (owned by the National Trust) is insufficient. The National Trust supports the objection of the Kent Wildlife Trust (who lease and manage the on shore areas owned by the National Trust) as follows; “Alternative routes with less of an impact on designated areas have not been adequately assessed. KWT has repeatedly requested the evidence behind the claim made by the applicant that there is ecological parity between the chosen landfall (Pegwell Bay) and other potential (since discounted) landfall options. Without this we cannot accept arguments of parity since the original options show high-levels of variability in areas of designated onshore and inter-tidal habitats affected.” Para 4.2.8. of the Environmental Statement Volume 1 Chapter 4: Site Selection and Alternatives notes that; “….. (NPS EN-3) states at paragraph 2.6.81 that the applicant should include an assessment of the effects of installing cable across the intertidal zone which should include information, where relevant, about: “any alternative landfall sites that have been considered by the applicant during the design phase and an explanation for the final choice” Our issue relates to the screening out of the Joss Bay route options 1 & 2 at the initial options appraisal stage. Para 4.8.15 notes the impact of the landfall at Joss Bay on the chalk habitats, but the stated reason in the summary of initial appraisal (table 4.6) is that; “Landfall through hard ground present representing significant challenge to offshore burial that it was not considered could be overcome with appropriate engineering solutions. Onshore route generally acceptable with land use considerations/agricultural land being primary issue.” Requests for further information in support of the screening out of Joss Bay have not provided any additional detail about the impacts on the chalk habitats or the engineering solutions required to overcome the ‘hard ground’ challenge. As the initial assessment accepted that the route was otherwise viable, this information is significant in the screening out of this option. Given the lack of this information regarding the screening out of the Joss Bay options relating to the inter tidal route at Pegwell Bay and the mixed information provided in the summary, the National Trust is unable to assess the planning balance made in the selection of the Pegwell Bay chosen route over the rejected Joss Bay route. The National Trust maintains its objection to the site selection process and the inadequacy of the level of information given in the Environmental Statement to justify the option chosen. "