“Thank you for the opportunity to comment on the above recently accepted DCO. I have reviewed the submission and on the basis of my review to date, I have the following comments. Please note that the general point to these comments is as I have previously commented (see attached), to avoid SPM assets and to engage as much as possible where this is unavoidable. For this current consultation response, I have grouped my comments into key areas of the DCO submission as below: General These comments are made by SP Energy Networks which acts on behalf of SP Manweb, the licenced Distribution Network Operator (DNO) for the area covered by the onshore elements of the proposed scheme. SP Energy Networks operate and manage the electricity network up to 132kV. This electricity network in the area of the proposed development is shown on the attached plans. In general, SP Energy Networks has no objection in principle to the proposed renewable energy scheme, however, it must ensure the avoidance of any adverse impact on its network as we all drive to maintain a network that is capable of meeting the increase in demand from an all-electric economy. SP Energy Networks has started a process of developing investment targets from 2023 to 2028 to meet the UK and devolved Governments ambitious decarbonisation targets for Net Zero. The next decade will be crucial in preparing the grid for these changes and this is why we are very interested in being able to comment on the proposals which may undermine maintaining and developing a suitable future grid network. In relation to this scheme, to date, SP Energy Networks has initiated engagement on various matters relating to the impact of the proposals on its network assets including the s42 stage and so considers to be at the early stages of working with the applicant to avoid impacts on its network. This engagement is helpfully recorded in the Consultation Report in para 385 (where reference is made to SP Energy rather than SP Energy Networks). SP Energy Networks commented on the scoping report in 2020 and these comments are repeated in the Scoping Opinion. However, SP Energy Networks requests the applicant to engage further to agree as much as possible at these earlier stages of the DCO process. SPM Network assets SP Energy Networks has over the course of the past year or so sought to obtain from the applicant detailed plans showing where crossover points are between the existing SPM assets and the proposed AyM development. Whilst the applicant has provided a plan showing crossover points, it is unclear to SPM what these crossover points are and if they are all points of contact where there will be an impact on SPM assets. The current position is that SP Energy Networks has recently asked the applicant to provide an overlay plan showing SPM assets and the proposed DCO limits. which seems the clearest way of showing these crossover points with a schedule explaining what the crossover is, and is seeking detailed discussion on the information included in the DCO (Figures 5 to 14 in Chapter 1 of Vol 3 of the EDS and the Crossings Schedule in Vol 3 Annex 1.1) to better understand the referencing system and identify crossover points. It is unclear from the information presented in these references to the ES as to what the reference in the legend ‘Crossing Schedule (excluding utilities)’ means and what the obstacle ID refers to as there are some differences between SPM assets listed in the schedule and what is shown in the figures, and whether the schedule includes all the SPM assets affected. In addition, it is not clear how the obstacles might be affected. It would help if there is an assumed centre line that indicates the likely route of the proposed cable installation. Having reviewed the submitted plans, the key pinch points are south of B5119, A547, River Clywd, north of A55, Glascoed Road and south of Glascoed Road. SP Energy Networks would like to resolve matters as much as possible and would like to see clarification on the crossover points/SPM assets as soon as further details can be provided. Noting the reference to SP Energy Networks network assets in the scoping opinion and the crossover schedule, no regard is given in the Environmental Statement to the impact of the AyM scheme on existing electricity network assets. Therefore it is identified what environmental impacts there might be where network has to be diverted and whether any required consents and further environmental assessment for diverted network is needed. This matter should be resolved and included in the AyM scheme. SPM does not want to be left with having to consent and assess environmental impacts for network diverted outside of the order limits or not included in the order limits. Impacts and consenting SP Energy Networks needs assurances that any affected network requiring to be diverted is, once identified, included in the EIA and properly assessed and reported. Where necessary, any related consents for diverting network is included in the DCO. It is noted no reference is made to such consents in the Other Consents and Licences Report. The applicant should clarify these matters as soon as possible. Grid Connection No reference is made in the Grid Connection statement to impacts on the existing electricity network and how proposed measures for working with SPM assets will ensure the existing network is able to operate and deliver the power that the proposed AyM scheme will provide. Measures for agreed working (DCO) Having carried out an initial review of the draft protective provisions in Schedule 9 of the draft DCO, these are not consistent with the provisions SP Energy Networks has provided to the applicant. As such, the applicant is asked to continue to work with SP Energy Networks and agree as many areas of possible through the application stages. Land Rights SP Energy Networks will require all SPM land rights affected by the AyM scheme that need to be amended to be agreed in full agreement with SPM. Reference is made to the Book of Reference where SP Manweb interests are included. Reviewing the BoR and confirming existing and proposed rights is likely to be an expansive task and the applicant is asked to engage with SPM regarding a timetable and cost undertakings to support working with SP Energy Networks in this regard. There are a number of key areas to resolve in relation to SPM network, which is critical to protect as it is this network that will be relied upon to distribute the generation into local homes and businesses. Any adverse impacts on the SPM network that need to be resolved by SPM would impact on the benefits of delivering this proposed scheme. The applicant should discuss the above with SP Energy Networks as soon as possible as they have been requested to do for over the past year but without making much progress. Given the extent of the information prepared and submitted, it is a reasonable expectation for there to be a plan produced showing the SPM asset as likely to be most affected and how, and an SPM network diversions worksheet that outlines how this network will be managed within the proposed development. SP Energy Networks will continue to review the DCO application and may wish to raise further matters in due course. Lastly, on an administrative note, please note that in order to assist in mail outs, you can delete SP Distribution Plc from the database as this is the SP Energy Networks distribution licence holder in southern Scotland and the entry for SP Manweb Plc, as this is covered by the ‘S Edwards, :and Land Planning SP Energy Networks’ entry.”

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