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 12 September 2018
From 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

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