Thanet Extension Offshore Wind Farm

The views expressed in this page do not represent those of the Planning Inspectorate. This page consists of content submitted to the Planning Inspectorate by the public and other interested parties, giving their views of this proposal.

Thanet Extension Offshore Wind Farm

Received 10 September 2018
From Kent County Council

Representation

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