On The Horizon and Coming Closer

THE RESPONSE MADE BY THE FRIENDS OF NORTH NORFOLK TO THE HORNSEA PROJECT THREE OFFSHORE WIND FARM DEVELOPMENT PRELIMINARY ENVIRONMENTAL INFORMATION REPORT CONSULTATION.

 

 

  1. The Friends of North Norfolk support green energy and the use of efficient offshore wind farms to produce clean electricity. However, such wind farms and the necessary offshore/onshore infrastructure must not be allowed to result in major cumulative harm to the environment, specifically the landscapes, seascapes and ecology, all of which constitute priceless heritage assets that are designated as of the highest importance both nationally and internationally. Hornsea Project Three will, on its own, be one of the largest offshore wind farms in the world and the scale of it, when considering Hornsea Projects One and Two (for which Dong Energy already have approval and are currently developing) is massive and it seems likely that Hornsea Project Four will very likely follow on.
  1. Dong Energy have applied what is known as ‘The Rochdale Envelope Approach’ and reserve the option to choose between High Voltage Direct Current, (HVDC) or High Voltage Alternating Current (HVAC) Transmission schemes if they receive approval for both within the one application. The Rochdale Envelope Approach enables a Developer to avoid repeated applications for approval to changes in the design of a project and consequential delays in implementation. It should be used to encourage better designs and allowance for rapid advances in technology, which can reduce environmental impacts. In short, it is to allow for a project to evolve over a number of years but within clearly defined parameters. However, we strongly argue that the Rochdale Envelope Approach should not be allowed in cases such as this when changes in the features/ specifications of the design options are so fundamental, and where it allows for a Developer to manipulate a consent for purely profit motives rather than to gain a superior solution from an environmental perspective.

 

  1. Guidelines regarding the use of the Rochdale Envelope Approach were issued by the former Infrastructure Planning Commission (IPC) in IPC Note 9 (February 2011). They still remain relevant to the assessment process.
  2. The PEIR and Consultation by Dong Energy fail to meet these guidelines.

 

  1. Further, they do not satisfy the underlying principles applicable to public consultation over new development requiring Environmental Impact Assessment. Unless they are adequately addressed this current process will be legally flawed.

 

  1. The details provided in the PEIR and Non-technical Summary do not describe the Proposal as clearly and simply as possible. There are no proper accurate and detailed photo montages/ wireframe images, particularly for the very large offshore or onshore HVAC Compensator/ Booster Station Installations to enable a ready visualisation/ appreciation of their visual impact. No proper description of the equipment e.g. lightning protection equipment which might be up to 17.5 metres in height which is 5 metres higher than buildings/ equipment.

 

  1. It is noteworthy that Dong Energy changed the original consent for Hornsea Project One to add the option to use HVAC Transmission and have subsequently chosen the HVAC Transmission option albeit in a less sensitive landfall and cabling area. In the case of Race Bank, Dong Energy have changed the position of offshore substations so that where originally they were to be out of sight over the horizon they have been moved to within the turbine array area and will now be visible from many highly sensitive viewpoints within the Norfolk Coast AONB and the Norfolk Coast National Trail.

 

  1. There are clear and significant advantages of HVDC Transmission over HVAC Transmission. HVDC is used in long distance sub-sea and underground transmission systems linked to offshore and on-land power generation operations. Indeed it has cost advantages in terms of fewer cables and lower power losses for transmission distances over 50km. Hornsea Project Three Transmission will be over 170km in total length from offshore substations to the proposed grid connection at Norwich Main Substation. Most importantly in this case HVDC would clearly have a much less harmful environmental impact since it will not require massive offshore or onshore Reactive Compensation Booster Stations sited and visible in extremely sensitive locations.
  2. The flexibility allowed by use of the Rochdale Envelope should only be available to provide a choice of which design/ configuration of HVDC Transmission System is eventually utilised. It should not be allowed to provide the Developer with the option of the far more ecologically and environmentally harmful HVAC Transmission System purely on grounds of finance.

 

  1. The consequences of allowing such an accommodation would be perverse since in the quest and overall desire for clean energy, great harm to ecology and environment of the highest value would result.

 

  1. Dealing with the Hornsea Project Three Preliminary Environmental Impact Report (PEIR) and impacts/ consequences for North Norfolk, we would wish to draw attention to the following:-

 

ï    Cumulative and inter-relational impacts of the various elements of the Project during all phases, but most crucially the operational phase, have not been fully assessed or have been inaccurately assessed.

 

ï    Individual impacts have been incorrectly assessed as not significant and even if accurately assessed as not significant become significant when their inter-relationship is assessed.

ï    Critically the cumulative effects/ impacts with other major developments (such as Race Bank, Dudgeon and Sheringham Shoal offshore wind farms and cabling works and potential proposals such as the Bodham and Selbrigg wind turbines and the Vanguard/ Boreas wind farm) have not been recognised, let alone given due weight.

 

  1. We question the many deficiencies in PEIR Volumes 2 and 3 and the areas where Dong Energy has failed to properly assess/ consider such cumulative impacts.

 

  1. PEIR Volume 2, which deals with offshore, impacts because of inter-relationship and cumulative harm to/ with onshore receptors, notably:

–     Chapter 4 Marine Mammals. The importance of both grey and common seal colonies, as an ecological and tourist asset.

–     Chapter 5 Offshore Ornithology.

–     Chapter 6 Commercial Fisheries.

–     Chapter 10 Seascape and Visual Resources.

 

  1. HVAC Booster Stations will be visible from very important sensitive areas of AONB, Heritage Coast, SSSI, and RAMSAR sites – as evidenced by PEIR Volume 2, Chapter 10, and Figure 10.3 Zone of Theoretical Visibility of Offshore HVAC Booster Stations.

 

  1. Please note that Race Bank Offshore Wind Farm was presented as being barely visible but in reality has a significant impact upon a very sensitive and important stretch of coast, which holds AONB, and Heritage Coast Designations. The turbines can clearly be seen inland from other sensitive and important SSSI areas e.g. Kelling Heath.

 

  1. PEIR Volume 3, which deals with onshore impacts. We have great concerns that the additional cables, very large offshore and onshore Reactive Compensation Installations and works which would be required if HVAC Transmission is used would have a major adverse impact on very sensitive Receptors taken cumulatively with other major developments, either recently completed or proposed. Both the Dudgeon and Sheringham Shoal Wind Farms make landfall at Weybourne; and if HVAC Transmission is utilised it will mean more and very much greater works over a prolonged period both to the East and West affecting a key part of the Norfolk Coast AONB, Norfolk Heritage Coast and the Norfolk/ English National Trail.

 

–     Chapter 4 Landscape and Visual Resources.

–     Chapter 5 Historic Environment.

–     Chapter 6 Land Use and Recreation.

–     Chapter 8 Noise and Vibration.

–     Chapter 11 Inter Related Effects.

 

  1. Mitigation proposals of whatever means are not acceptable for long-term adverse impacts, causing such harm to the Norfolk Coast AONB, Heritage Coast, Nationally and Internationally Designated Sites.

 

  1. The majority of the North Norfolk Coastline is recognised, both nationally and internationally, for its exceptional landscape and ecological value with a number of overlapping Designations including the Norfolk Coast AONB, the North Norfolk Heritage Coast, many SSSI, SAC, RAMSAR sites and Marine Protection Areas/ MCZs.

 

 

  1. Panoramic sea views of the Coastal Edge, and the interaction between the landscape and sea are an essential part of its unique character made up by the dynamic coastal landforms and processes, ecological interdependences, biodiversity and cultural, architectural, economic, historic and archaeological features.

 

  1. The Coastal Plain from Holme-next-the-Sea to Weybourne in particular has a wilderness quality, which is rare in lowland England. Nationally, it is one of the few remaining examples of undeveloped coast with such a sense of remoteness and tranquillity.

 

  1. The Consultation and Response Timetable has been too tight to properly assess such a massive project, and the volumes of data and information – beyond the resources of most authorities and public bodies, let alone ordinary folk.

 

  1. We, the Friends of North Norfolk, request that the deficiencies in the PEIR and Consultation Documents provided by Dong Energy, which we have briefly outlined are properly addressed.

 

  1. Most importantly we would challenge the use of HVAC Transmission when HVDC Transmission would achieve a win, win, outcome for North Norfolk, the Environment and the Nation’s energy supply in a viable and sustainable way.

 

  1. We understand that in order to make their final decision as to which system to adopt, DONG have promised to undertake a full technical/feasibility appraisal of HVAC and HVDC So as to fulfill that promise completely we request that the conclusions of this appraisal are made know to all consultees and within a time frame for them to respond

 

  1. In conclusion, we request that all the foregoing are adequately and properly addressed before DONG submit their proposals to the Planning Inspectorate.

 

Thank you.

 

The Friends of North Norfolk.

An appeal against NNDC’s refusal for two wind turbines of 256 ft and 216 ft respectively at Pond Farm Bodham has been allowed. To say that this is a tragedy for north Norfolk is an understatement. These monsters will be visible from as far away as Wells and Burnham Overy and be dominant from many other points within the AONB.  From a non-professional point of view such a decision seems completely crazy, it flies in the face of common sense and clearly lacks any real under standing of the setting; whether it is equally flawed in legal terms is something that must be clarified as it would determine whether a Judicial Review would be justified. Inspectors decisions are not easily overturned but I cannot believe that a decision as stupid as this one could not be thrown out.

The group called NOTTT have fought so hard against this scheme and must be broken hearted at this result, which from any rational expectation must be a shock. So I would request that all the Friends of North Norfolk rally to support any initiative they or NNDC may make in respect of this disaster.

Godfrey Sayers

Links to the apple decision can be found here.

Update re Three Owls, Saxlingham Road, Blakeney – PF/16/1254.

NNDC Planning Committee Members considered this Application at the Development Committee Meeting held in November 2016 and the decision was to ‘refuse’ . The Decision Notice refers to the siting of the proposed dwelling further away from the original bungalow – with encroachment further into the open countryside, the visually detrimental impact the Proposal would have on the character and appearance of the surrounding area, it detracting from the special qualities of the Norfolk Coast AONB and the adverse affect on the character and appearance of the Glaven Valley Conservation Area.

The Applicant has subsequently submitted an Appeal against the decision
– W/16/3163694 , which is currently being heard by an appointed Planning Inspector by way of written submissions and which will take into account all of the many comments and objections already lodged. Chris Wheeler has worked extremely diligently and has made further individual representations – he deserves special mention .

This is just one of many recent examples when the FNN feels that NNDC Planning Officers in their support of the Application have failed to properly appreciate the importance of the location of the Site and the damaging character / visual impact upon the Norfolk Coast AONB, important Conservation Areas, Landscape Character and in this case the Wiveton Downs / Blakeney Esker SSSI.