ALDRINGHAM-CUM-THORPE PARISH COUNCIL
SUFFOLK, IP16 4QH
Scottish Power Renewables EA2 and EA1N
11th November, 2018
Dear Sir / Madam,
EA1N and EA2 Offshore Wind Farms – Phase 3.5 Consultation – Introduction of Broom Covert to the potential sites for the onshore substations
The parish council are pleased that SPR have been able to respond to the consultation comments and included land at Sizewell as a potential site and is to be given appropriate consideration, although the consultation time is very limited, we appreciate the extension of a couple of weeks to 12 November in order to produce a considered response.
Due to National Grid line availability at this point on the coast the communities around Sizewell have suffered a great deal of disruption and distress over many years from a series of Power Generation Projects, including two Nuclear Power Stations and the Greater Gabbard and Galloper wind farms. There appears to be no respite in the disruption to our communities and damage to our landscape with the prospect of East Anglia ONE North, East Anglia TWO Offshore Wind Farms, Sizewell C Nuclear Power Station and the National Grid Ventures, Nautilus and Eurolink projects which also propose to bring cables ashore at Sizewell and will require two further substations and a connection point to the Grid System.
The Parish Council along with all local communities feel that they have done enough to support national infrastructure projects. East Anglia ONE North and East Anglia TWO Offshore Wind Farms, followed by the National Grid Nautilus and Eurolink Projects will result in our local community facing ongoing disruption for many years to come. It remains our overriding view that large scale industrial developments, such as wind farm substations, are inappropriate for this section of the heritage coast with its naturally flat and wildlife rich habitat.
If the projects are to proceed and the cables have to come ashore at Sizewell then the three supporting substations for the East Anglia Wind Farms, and the three required for the Nautilus and Eurolink Projects should all be sited as close to the existing energy infrastructure at Sizewell. Preferably adjacent to the existing Greater Gabbard and Galloper installations north of the Sizewell Gap road, and only spilling on to land south of the road into the northern sections of zone 2 and into zone 3 (identified by SPR) if absolutely necessary. It is essential that disruption and intrusion to local residents of the area, including those at Ivy Cottages, Halfway Cottages and Leiston Common is kept to an absolute minimum.
The area of land take for these substations is extensive and every effort must continue to reduce the footprint of the installations. More sympathetic positioning of the compounds closer to the Gabbard/Galloper complex and away from the more visible higher ground of Broom Covert is essential if they are to be located in this area. Broom Covert is already identified for reptile mitigation land for Sizewell C and cannot easily be replaced and provides an essential North/South wildlife corridor between Leiston and the existing energy infrastructure of the nuclear power stations and wind farm substations at a point where the AONB is at its narrowest.
Further consideration should also be given to adopting a holistic approach to all of the energy delivery projects that are proposed for this area, including East Anglia One North and East Anglia Two Windfarms, Nautilus and Eurolink interconnectors and Sizewell C Nuclear Power Station. If this is not achieved this area will suffer a series of similar consultations with even more restrictions on land availability.
Because of the sensitive nature of this coast, significant mitigations should be applied to all of the onshore works and facilities. These mitigations should include minimising the height of any installations, adopting appropriate colour schemes, providing adequate screening and noise reduction measures as well as reducing the building footprints to an absolute minimum. Once these substations have been completed the areas within the compounds should be maintained in such a way as to encourage biodiversity and as far as possible provide a positive contribution to the long-term viability to the AONB.
Any land taken for the laying of the onshore cables should also be restricted to agricultural land. This land should be purchased by SPR and following the works, gifted to the community for rewilding, giving long term benefit, and an overall improvement to the AONB, which should go some way to mitigate the presence of the substations within our beautiful and precious landscape.
As with the mitigation, amelioration measures put in place to compensate the affected communities for the disruption during construction and the ongoing impacts of operation should be considered holistically. It is essential that all projects are included and contribute to these measures in order to maximise the benefits that can be delivered.
Specific Concerns for the parish of Aldringham-cum-Thorpe
Regardless of the location of the substations, the landfall for the offshore cables is indicated to be just to the north of Thorpeness and as further information is becoming available we have taken this opportunity to bring to your attention some of our more specific concerns we have related to work that would have to be carried out within our parish.
Background information - Our plans for Thorpeness
We are currently working with Suffolk Coastal District Council (SCDC) and Orwell Housing and others on a feasibility study for the provision of Affordable Housing on the field to the north of the B1153, which is currently included in the area potentially required by SPR. We would not wish for any actions by SPR to impact on this.
Plans are underway to develop a new Community Centre on the Sports Ground adjacent to the area required by SPR, again we would not wish any works and activities to be carried out by SPR to impact on these proposals.
Plans have been produced to provide additional units at the Almshouses, adjacent to the land required by SPR, again we would not wish any works and activities to be carried out by SPR to impact on these proposals.
A great deal of work has been done with SCDC on the problems of the coastal erosion along the northern section of Thorpeness and the cliffs to the north. This part of the coastline is extremely fragile and is immediately adjacent to the proposed cable landing compound. Consultation is soon to be carried out with the community on these issues to which SPR should be aware.
Thorpeness and the surrounding area is a tourist hot spot and work is currently being undertake through the production of a Neighbourhood Plan to Manage the growing impacts on Thorpeness. We would seek to work with SPR to ensure that the economy of the area is not impacted by work carried out by SPR.
Cable Landfall location
It is our understanding that a significant area of land will be required to carry out the major works at this location, requiring a large amount of manpower, plant and materials. We are concerned by the potential disruption that will be caused by these works over an extended period of time as it located extremely close to the Northern edge of Thorpeness. This will only be exacerbated if the interconnector cables also come ashore at this point. It is therefore essential we have a continuing dialog to understand what is actually proposed for this location and how the impacts of the work will be mitigated to an acceptable level on:
The extensive area of land required within the AONB / Heritage Coast.
Tourism and economy of the area
Footpaths and general access to the area
The SSSI (Thorpeness Common)
The fragile coastal margins
Community and wellbeing, particularly to the vulnerable people associated with the Almshouses in Thorpeness and at Wardens (Ness House)
The environmental impacts during construction, including, Noise, Light, Dust pollution and the added concerns of out of hours working.
The ‘Concerto’ submarine cable that runs through the landfall compound.
Long term access to the cable transition pits.
As previously mentioned the field adjacent to the B1353 Thorpe road between the Thorpeness Almshouses and The Sports Ground is particularly important to our future plans and is currently being shown as required for the works. The Almshouses provide homes for infirm and elderly residents who would find the disruption particularly hard to bear. In addition, this field has been identified as a possible exception site to accommodate affordable housing for the village. It is also an extremely dangerous location to gain access to Thorpe Road. If access is required from the B1353 Thorpe Road to the cable Landfall site, then further discussion is required to identify a more appropriate location.
Wherever the substations are located there will be a requirement for the cables to be routed from the landfall site to that location, again we are concerned by the potential disruption that will be caused by these works over an extended period of time, as previous we are very concerned by the impacts of these works and how they will be mitigated to an acceptable level, including:
The area of land required within the AONB / Heritage Coast
Tourism and economy of the area
Footpaths and general access to the area
Environmental impacts during construction, including, Noise, Light, Dust pollution and the added concerns of out of hours working.
If the location of the substations remains west of the B1122 then we also require further discussion on the impact of the cable route at the pinch point across the B1122 to the south of Aldringham Court, a listed building of local and historical importance, where it is essential that works are carried out in the most sympathetic way to preserve as much of its character as possible with minimum loss of trees and maintaining this much needed natural wildlife corridor across the B1122, whilst ensuring minimum traffic disruption though the village of Aldringham.
1. Traffic and Transport
The following comments are made with reference to East Anglia ONE North and East Anglia TWO Offshore Wind Farms Consultation Information leaflet (September 2018) and Traffic and Transport Factsheet (October 2018), with particular regard to the HGV Route though Aldeburgh, along the B1122 to Aldringham cross roads and along the B1353 Thorpe Road.
Wherever the substations are located there will be a requirement to service the project with HGVs and other associated vehicles. We are concerned by the potential disruption that will be caused to current road users, businesses and the tourist industry, by the increase in traffic on our already busy roads, particularly at peak times when we already experience a significant increase with holiday traffic.
We recognise that whilst taking a sympathetic approach to the cable route at the crossing point of the B1122, it is also desirable to balance this with the requirement to ensure minimum traffic disruption though the village of Aldringham. Therefore, further dialog is required on this issue.
The B1353 from Aldringham cross roads to Thorpeness is a particularly narrow road and is extensively used by cyclists and some pedestrians who already use this road at some risk. There is a particularly bad section at the old Thorpe crossing where the road is badly aligned and where golfers have to cross the road. This has been the location of a number of accidents The Size of the and number of additional HGVs in relation to the width of the road is of great concern. To mitigate these issues consideration should be given to providing a footpath/cycle route alongside the road from Aldringham to Thorpeness and a small realignment of the road at Thorpeness crossing.
The location of the site access from Thorpe Road to the cable landfall site is of great concern as this is a very narrow stretch of road which is bounded by high hedges just as it enters the village. We ask that SPR work with the Parish Council to find an appropriate solution for all the projects (see section 1 above) which require access at this point.
With the increase in the traffic, particularly HGVs, using these roads, we are concerned that the degradation which is already evident along the B1353 is not made worse and that the additional maintenance required will be supported by SPR.
Although the B1353 Aldringham Lane to the west of Aldringham crossroads has not been included as a designated route it is essential that safeguards are put in place to prevent its use. This lane is already a concern for residents owing to its use by numerous large agricultural vehicles and increasing commercial traffic that already cause many problems made worse with the increasing traffic flow we are seeing from new housing in Leiston and will be increased again by the 40 new houses proposed for Aldringham.
This part of the coast has a high number of visitors and the local tourist industry makes an essential contribution to maintaining a viable local economy to which Thorpeness in particular is heavily reliant. Therefore, it is important that disruption to visitors is kept to an absolute minimum and they are not discouraged from visiting the area. It is also essential that access to the coastal strip and the numerous footpaths across this part of the AONB and beyond are kept open and available to both residents and tourists who make extensive use of them. The reptile mitigation land that is required to be relocated from Broom Covert should not be sited where it will impose any restriction to the access to that land.
As further issues come to light when the exact locations of construction and service compounds are being determined, we request that early discussions are facilitated in order for us to make informed decisions and comment.
Mitigation and Legacy
The EA1N and EA2 Offshore Wind Farm projects are going to create considerable disruption to all the local communities over a significant period of time. Our communities demand to be adequately compensated for this disruption, with the provision of substantial mitigation and compensation measures.
It is essential that complete and affective restoration of the landfall site and the cable route is carried out to a standard that is appropriate for the AONB and where possible the areas of natural sandling vegetation should be enhanced and extended to improve the long term viability of the area.
Although many of the mitigation measures identified above, if conceived and delivered in an appropriate way have the potential to deliver long term benefit they should not be considered on their own as sufficient to provide the level of compensation required. We expect a substantial legacy in the form of improvements to infrastructure, community assets and coastal defences for example, that will make a significant contribution to the sustainability of our local communities, and are of a sufficient substance and quality to ensure that residents, business and visitors can continue to enjoy the standard of wellbeing and prosperity that they do today and they are not impacted or disadvantaged by any of the undertakings of SPR.