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Cabinet received report ES-0239 by Councillor Rivett, Deputy Leader and Cabinet Member for Economic Development, which sought authority to fully engage with the pre-examination and examination stages of the Development Consent Order process in relation to East Anglia One North (EA1N) and East Anglia Two (EA2) offshore wind farm projects. It was noted that ScottishPower Renewables had submitted two separate nationally significant applications for offshore windfarm developments off the East Suffolk coast with onshore infrastructure from the coast at Thorpeness via a cable route to the grid connection location to the north of Friston. The applications, EA1N and EA2 were submitted to the National Infrastructure Unit of the Planning Inspectorate (PINS) on the 25 October 2019 and accepted on 22 November 2019.
The proposals had been the subject of pre-application consultation with the local authority, with four formal rounds of public consultation, the last ending in March 2019. The Council was a statutory consultee in the decision-making process, with the Secretary of State for Business, Energy, and Industrial Strategy making the final decision on the proposals based on the recommendation of the Examining Authority (appointed by the PINS) following an examination process.
The report provided background to both of the projects, a summary of the current position of the Council in relation to the projects, and the Development Consent Order (DCO) procedure and proposals. It was noted that the Council had been working closely with the Department for Business, Energy and Industrial Strategy and others regarding the cumulative impacts of these proposed developments and that meetings had been held with the Minister of State for Business, Energy and Clean Growth to express the Council's concerns and seek the Government's assistance. Councillor Rivett reported that the two new windfarms would bring jobs to the District, citing up to 100 jobs that East Anglia One (EA1) would create within its operation and maintenance base which has been located in Lowestoft. East Coast College had also opened its Energy Skills Centre and had entered into a partnership with Maersk to deliver training there.
Councillor Rivett stated that the Council, as a statutory consultee and not the determining authority, needed to consider the proposals with its usual rigour, highlighting that 80% of planning decisions that had been reviewed on appeal by the PINS in the last three months had been upheld. It was noted that the Council had concerns about the cumulative impact of the proposals and this matter had recently been discussed by the Strategic Planning Committee. Councillor Rivett then invited the Senior Energy Projects Officer to make a presentation to the Cabinet.
The Senior Energy Projects Officer explained that the deadline for Relevant Representations to be submitted to the PINS was 27 January 2020. The Council, as host Authority, had pre-registered as an “Interested Party”, the Relevant Representation detailed a summary of the Council’s issues / response to the project. The examination was expected to start between March and May 2020; once started the examination process would follow a strict six-month timetable and a decision was expected in the Spring of 2021.
The key revisions to the proposals were highlighted since the Phase 4 consultation relating to seascape, highways, substation site masterplans, National Grid Electricity Transmission works, site drainage, cable route refinement, and working hours. The Cabinet was shown a map which demonstrated the proximity of the proposed offshore locations of EA1N and EA2 to other consented or proposed windfarms within the East Anglia Zone. The Senior Energy Projects Officer highlighted that the applicant had slightly increased the distance between the two developments by reducing the area at the northern end of the EA2 zone and that EA2 would be nearer to the coast than any of the other windfarms in the zone.
Members were provided with the statistics on EA1N and EA2 relating to their operational capacity, the number of households they could power, their distance from shore at its closest point, the number of turbines, the turbine tip heights, and the number and type of offshore platforms that would be required. The Cabinet were also shown images of the types of platforms that could be used. A map outlining where cabling would come ashore at Thorpeness and its route to the proposed substation site immediately north of Friston was displayed. It was confirmed that the onshore cabling would be underground, with the export cables coming ashore at least 85 metres back from the cliff edge to compensate for potential future coastal erosion. Those present received an example layout for the substations; each substation would measure a maximum of 190 metres by 190 metres. The Cabinet was also shown a picture of the existing substation for EA1. The maximum height of substation equipment would be 18 metres and the maximum building height would be 15 metres.
The Senior Energy Projects Officer noted the proximity of the Special Protection Area (SPA) and Site of Specific Scientific Interest (SSSI) to the cable route and detailed where the cable would run alongside the areas before crossing at the narrowest point. Some works to the overhead lines would be required at the substation site in order to connect the infrastructure to the National Grid network. The indicative positions for the onshore substations were also demonstrated. There would be one substation per offshore windfarm, along with a National Grid substation which would be shared by both projects.
The Senior Energy Projects Officer highlighted the concerns raised about the impact of these substations on the settings of nearby listed buildings, discussing how the relationship between the historic buildings and their settings would be disrupted. The construction of the substations would also require the diversion of a public right of way which follows a historic parish boundary. Officers also had significant concerns regarding the impact of operational noise from the substations and considered that this was not fully addressed by the applicant's submissions. Officers had noted that it was not clear within the submissions what impact the noise from the substations would have on both the local ecology and the character of the area and that this would need to be explored further. An illustrative masterplan for the site was displayed, which highlighted the additional planting proposed around the substation site. The presentation also included several visualisations provided by the applicant within their submissions of the proposed substation site, looking from various viewpoints. The visualisations included computer-generated imagery of the substation developments superimposed on to the site and gave examples of what the applicant considered the view would be both at the first year of operation and 15th year of operation. The visualisations were provided by the applicant to illustrate the level of screening they predicted would be present within these timescales.
The Senior Energy Projects Officer reported that there was concern that the proposed planting would not have reached the levels of maturity suggested by the applicant within the visualisations within 15 years and that the sites would not be screened from view to the degree the applicant had suggested. She outlined the issue of the cumulative impact of future projects including Sizewell C, National Grid ventures (interconnectors Eurolink and Nautilus), the Galloper extension, and the Greater Gabbard extension. Concerns were also raised about the substation site / Friston area becoming a strategic connection point for future energy projects should the National Grid substation be consented in the location proposed.
The Cabinet were reassured that officers had been reviewing the significant number of documents submitted by the applicant, in order to draft the Relevant Representations and Local Impact Reports that needed to be submitted to the PINS. The Senior Energy Projects Officer said that the Council will continue to work with the applicant to identify the means by which the impacts of the proposals could be mitigated and/or compensated.
The Leader of the Council took the opportunity to reiterate that East Suffolk Council was not the planning authority in this instance, it was only a consultee during this process. He confirmed that the Council would put forward its concerns and those of local residents, however local residents needed to be prepared that the project may be permitted in the future. It was important to listen to local people's views and to open up debate about this development.
The Leader then took the opportunity to read out a recent press release about this matter:
"While East Suffolk Council is strongly in favour of renewable energy, Cllr Gallant says he is "disappointed" with the submitted applications in their current form, which lead him to believe that the benefits will be considerably outweighed by the potential impacts of the proposals.
ScottishPower Renewables (SPR) have submitted two separate applications for offshore windfarm developments off the East Suffolk coast with onshore infrastructure from Thorpeness to a substation site immediately north of Friston. During Phase 4 of the consultation the Councils objected to elements of the scheme, with concerns ranging from visual impacts, to environmental concerns and the effect on tourism and visitor numbers.
The Council recognises the national benefit these projects will bring, but only provided this is achieved without significant damage to the local built and natural environment, local communities, and tourist economy. The local impacts of the projects and their cumulative impacts need to be adequately and better addressed.
While there will be positive benefits here and for the wider region, the negative impacts of the developments would be felt almost exclusively by local communities. The approach to these schemes is primarily commercially driven and until sensible and appropriate mitigation and compensation packages are proposed, we will continue to object to the proposals in their current form.
Cllr Gallant added that the Council will continue to make the necessary approaches to Government Ministers as well as working closely with Suffolk and Norfolk Councils who are experiencing similar pressures. He also compared the issues with the SPR development to the proposals for Sizewell C Nuclear Power Station, which East Suffolk Council were also seeking to resolve.
With Sizewell, again, the outcome of the Stage 4 consultation failed to answer questions which we have posed and we do need them answered in the DCO submission. However, we have not objected to the proposals so far because we can see the potential for benefits regarding highway improvements, skills improvements, education benefits and jobs for the local area.
East Suffolk Council's Cabinet would consider a report regarding the Scottish Power Renewables Schemes on January 7 2020. Among the recommendations, the report states: "That this Council continues to engage with SPR to identify means by which the impact of the proposals can be mitigated and/or compensated if the developments do take place and seek appropriate s106 agreements to secure the necessary mitigation and/or compensation."
The Leader then invited questions from the Cabinet and those Members present.
Councillor Kerry queried the 300 metre height of the proposed turbines and how intrusive they would appear from the shore. It was confirmed that the turbines at Galloper and Greater Gabbard were approximately 180 metres high and they could be seen from land. The EA1N and EA2 turbines, which would be taller at 300 metres high, would be further away from the coast. Therefore the assessments provided within the applications have shown the turbines would appear at a smaller height to those of Galloper and Greater Gabbard when viewed from the coast. The offshore footprint of EA2 in particular however runs parallel to the coastline for a significant distance.
Councillor Burroughes raised concerns about the additional planting which was proposed, as the trees appeared to be deciduous and would therefore provide no screening or protection during the winter months. Councillor Rivett advised that there was no detail about the types of trees to be planted within the Cabinet report, however there was some disagreement regarding the suggested growth rates of the trees and the length of time required to provide sufficient cover. It was noted that these issues would be challenged robustly as part of the Council's response.
Councillor Bond commented that the proposed structures would be dominant and seen from all over that area. Councillor Rivett reported that the negotiations were ongoing, however Scottish Power Renewables were happy with the current suggested level of mitigation. He reported that there would be ongoing discussions and Ward Councillors were invited to take part in the various meetings with Scottish Power Renewables. The Leader confirmed that should there be any significant changes to any of the proposals, which could lead to the Council taking a different position on the applications, these would be brought back to Cabinet or Full Council for thorough consideration and debate.
Councillor Cackett queried which methods were being used to predict noise levels at the site and whether best practice was being followed. It was reported that there had been some ongoing disagreements between the findings of the various Noise Consultants and discussions were ongoing in relation to this matter.
Councillor Bond queried whether Scottish Power Renewables had produced any evidence regarding the benefits to the local residents of the development? It was confirmed that the main benefit was economically and related to the creation of jobs and investment through supply chains, but this was likely to be experienced in and around Lowestoft and not within the area immediately surrounding Friston.
Councillor Bond sought reassurance that the proposals would ensure that the local supply chain would receive an uplift from the development, rather than benefiting national or international companies. It was confirmed that reassurances and commitments were being sought in this respect. It was noted that the Head of Economic Development and Regeneration was working to get a Memorandum of Understanding (MOU) in place to provide greater confidence that local companies would be used where possible. It was important for the local area, County and Region to benefit as much as possible from this development.
There being no further questions, Councillor Rivett invited those present to debate the matter.
Councillor Mallinder stated that he had driven around the local area and had concluded that we are lucky to have such beautiful countryside in our district. He reported that he felt conflicted by the proposed development, as he supported any reduction in carbon which would be assisted by this development, however he also wanted to protect the countryside and wildlife from further development. He felt it was important to look at the bigger picture including the need for clean energy and protecting the environment.
Councillor Kerry reported that while he was an advocate of renewable energy, there were pros and cons with all development, it was important to do the best for local people. This was not an East Suffolk Council decision, however the Council could give its views and represent local residents and he supported the recommendations.
Councillor Elliott reported that this matter had been debated in depth by the Strategic Planning Committee at its meeting in December 2019 and it was important for East Suffolk Council to give a robust response, given the significant impacts on that part of the district. He commented that he felt the landscaping proposals were inadequate overall. He also commented on the fragmented and competition based energy market, which was not in the national interest, and which resulted in a disjointed and piecemeal approach to energy supply in the UK. It was important not to jeopardise the development, which was low carbon, however there should be a joined up approach in order to meet the needs of the country for years to come.
Councillor Bond reported that she had a letter which had been signed by 33 parishes, which had been sent to the Secretary of State in December 2019. She queried whether the Council would support this and undertake a review of the potential impact on the area. The Leader reported that he had been proud of the work of East Suffolk Council to date in this respect and the Council would continue to work to best represent the interests of its local residents.
Councillor Byatt felt that the development would be a blot on the landscape and he queried whether the site of Sizewell A could be redeveloped and reconfigured, instead of using proposed site? He felt that the land should be saved for future generations and that an off shore ring main should be created instead. The Head of Planning and Coastal Management reported that officers were regularly meeting with senior civil servants regarding this development and raising concerns as appropriate. He reported that Sizewell A would need to be decommissioned for many years prior to any potential redevelopment and was therefore not suitable in relation to this project. He stated that an off shore ring main would take approximately 10 years to plan and build and it would be a complex development. Therefore although it may provide a potential solution in the future, the infrastructure could not be provided in time for the current projects. The Head of Planning and Coastal Management reported that approximately 40% of the UK's off shore energy was being or was proposed to be routed through or fully accommodated in Suffolk and Norfolk and the region was receiving only limited, but important economic benefit, from these proposals whilst they would be environmentally damaging, and with it some significant community/social impacts. If these projects are to progress, further discussions with government need to take place to seek to address compensation for the disruption that would be caused.
Councillor Rivett proposed the recommendations contained within the report and these were duly seconded by Councillor Gallant. Upon being put to the vote it was
RESOLVED
1. That the Head of Planning and Coastal Management in consultation with the Deputy Leader and Cabinet Member with responsibility for Economic Development be granted authority to fully engage with the Pre-examination and Examination stages of the Development Consent Order process in relation to EA1N and EA2 offshore wind farm projects. This will include:
• Submission of Written Representations to expand upon the Relevant Representation where necessary,
• Submission of Statements of Common Ground between the applicant and the Council,
• Attending/authorising technical officers to participate at Preliminary Meetings/hearings/accompanied site visits,
• Responding to Examining Authority’s questions and requests for further information,
• Commenting on other interested parties’ representations and submissions as appropriate,
• Signing planning obligations if required.
• Any other requirements not yet identified.
2. That the Head of Planning and Coastal Management in consultation with the Deputy Leader and Cabinet Member with responsibility for Economic Development be authorised to make amendments to the draft Relevant Representation and early draft Local Impact Report as agreed with appropriate representatives of this Council prior to their submission to PINS.
3. That following agreement by the Cabinet of East Suffolk Council, the draft Relevant Representation set out in Appendix A and summarised below, subject to any agreed amendments, be submitted to PINS.
4. That PINS be informed by the Relevant Representation that East Suffolk Council recognises the national benefit these projects will bring in meeting the renewable energy targets and creating sustainable economic growth in Suffolk provided this is achieved without significant damage to the local built and natural environment, local communities and tourist economy. Notwithstanding this, the Council has significant concerns on the following matters:
• Landscape and Visual Effects
• Noise
• Design and Masterplan
• Traffic and Transport
• Seascape and Visual Effects
• Cumulative Impacts
• Measures to address residual impacts of the projects
The Council also has concerns or wishes to make representations in a number of additional areas which have been outlined below:
• Socio-Economic Impacts
• Heritage
• Air Quality
• Public Rights of Way
• Flood Risk
• Ecology
• Coastal Change
• Archaeology
• Construction Management
East Suffolk Council is supportive of the principle of offshore wind development, recognising the strategic need for zero carbon energy and the contribution the industry can make to sustainable economic growth in Suffolk. This must however be achieved without significant damage to the environment, local communities and tourist economy of East Suffolk. The projects as designed to date will result in significant impacts as set out above, particularly in relation to the environment
around the substation site and significant effects on the designated landscape. Based on the current submissions East Suffolk Council objects to the overall impact of the onshore substations and raises significant concerns regarding the significant effects predicted from the offshore turbines on the Suffolk Coast and Heaths AONB.
5. That following agreement by the Cabinet of East Suffolk Council, the early draft Local Impact Report set out in Appendix B, subject to appropriate amendments, be submitted to PINS by the relevant deadline.
6. That this Council continues to engage with SPR to identify means by which the impact of the proposals can be mitigated and/or compensated if the developments do take place and seek appropriate s106 agreements to secure the necessary mitigation and/or compensation.
7. That Cabinet notes the continued work with Government, namely MHCLG and BEIS with regards to the cumulative impacts on East Suffolk of the numerous energy projects existing and forthcoming.