6.1 - Planning Inspectorate · 14.1.6 A letter and pack of consultation documents including the Project News, Overview Report, Document Navigation Booklet, DVD, Feedback Form and

May 2014Application Reference EN020001

6.1.3Do

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Hinkley Point C Connection Project

Consultation Report Part 3 of 3Chapters 14 to 18

Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009 Section 37(3)(c) and (7) Planning Act 2008


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14 WIDER CONSULTATION

14.1.1 National Grid has a list of additional consultees with whom it voluntarily agreed to engage in consultation on projects of this nature. Throughout the development of the Hinkley Point C Connection project this list evolved to incorporate any additional organisations that requested further information. In order to help inform the development of the project, National Grid invited the views of these non-prescribed consultees on the proposed application. A list of those non-prescribed consultees who were proactively contacted is included in Appendix 48.

Local Bodies

14.1.2 National Grid consulted with a number of bodies and individuals who are not

defined as prescribed consultees in Schedule 1 of the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009. These local bodies included organisations such as the Avon and Somerset Wildlife Trusts and the National Trust and are detailed in the list presented at Appendix 48.

Members of Parliament

14.1.3 National Grid wrote to the following affected MPs at the start of the consultation period to offer a face-to-face briefing on the project and the consultation. These letters were followed up with phone calls and information packs (containing the Project News, Overview Report, Document DVD, Document Navigation Booklet and a feedback form) were sent to MP parliamentary and constituency offices. Copies of the letters can be found at Appendix 49.

Steve Webb MP (Thornbury and Yate);

Jack Lopresti MP (Filton and Bradley Stoke);

Charlotte Leslie MP (Bristol North);

Liam Fox MP (North Somerset);

John Penrose MP (Weston-super-Mare);

Tessa Munt MP (Wells); and

Ian Liddell-Grainger MP (Bridgwater).

Non-prescribed Consultees

14.1.4 In addition to local bodies, a number of other groups and organisations were consulted on the application. These consultees had either been previously engaged by National Grid on the project, responded to previous non-statutory consultations, or had requested to be included as a consultee during the course of the project. A list of these groups and organisations can be found at Appendix 48.

Other Stakeholders

14.1.5 Throughout the non-statutory stages of consultation, National Grid kept other stakeholders informed about the project and consultations. A list of these other stakeholders can be found at Appendix 48. To raise awareness of the


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consultation, emails were sent to these stakeholders at the beginning of the consultation period. A copy of the Project News and a poster outlining all the consultation events were attached to the emails. In addition, posters advertising the consultation events were sent to a range of venues including parish councils, village halls and tourist information centres. Copies of the letters can be found at Appendix 50.

14.1.6 A letter and pack of consultation documents including the Project News, Overview Report, Document Navigation Booklet, DVD, Feedback Form and Freepost envelope were delivered to the Planning Inspectorate on Monday 2 September. A copy of the letter and a delivery receipt can be found at Appendix 14.

14.2 Project Wide Responses Received

14.2.1 In accordance with the DCLG Guidance on pre-application consultation, this section of the report provides a summary of the relevant representations received from wider consultees relating to project wide issues during the statutory Stage 4 Consultation. A summary of National Grid’s response to the issues raised and a description of how the proposals were influenced by these responses presented in Section 14.4 of this document.

14.2.2 It should be noted that due to the detail presented in relation to the route proposals at this stage of the project the issues raised by consultees with regard to the overall scheme are significantly reduced when compared to previous stages of consultation. Within this stage of consultation the vast majority of responses and comments raised were specific to route sections and therefore are covered in more detail in Section 14.3 of this report.

Alternatives

14.2.3 Somerset Alliance Against Pylons expressed a preference for a sub-sea connection within their response, whereas, CPRE Somerset’s response supported either a sub-sea or an underground cable connection using GIL. CPRE provided extensive detail within their response that they felt indicated that these alternatives were technically feasible and argued that although these options were more

expensive consumers would be willing to contribute to that cost.

Consultation

14.2.4 Several comments were received which challenged the consultation process or the documentation provided. Somerset Wildlife Trust made specific comments about insufficient or inaccurate data or documentation in the PEIR and EIA and stated that the thematic groups have been inaccessible. The AWT also expressed concerns that the lack of detailed information in the PEIR prevented them from commenting fully on the proposals; they considered that this was exacerbated by perceived inaccuracies, particularly relating to Section F.

Cost

14.2.5 Whilst comments were received from wider consultees regarding cost these all related to specific sections of the route and are reported in subsequent sections of this report.


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Engineering and Construction

14.2.6 Only a very small number of comments from wider consultees were received with regards to engineering and construction issues which were not specific to a particular location. Somerset Wildlife Trust shared concerns regarding potential construction related impacts to local wildlife sites in Somerset, particularly where temporary culverting was required.

Environment

14.2.7 Somerset Wildlife Trust expressed concern about the construction impacts on wildlife and biodiversity, as raised in the PEIR. They also expressed concern about the cumulative impact of developments and called for further environmental

assessment particularly relating to the impact on Ramsar sites. They acknowledged that species-rich hedgerows had been identified in the PEIR but they expressed concerns that there was no reference to the species-rich ditches in the PEIR and therefore the potential impact on invertebrates had not been considered. Further concerns were highlighted with regard to impact on birds due to the bird flight path between the Somerset Levels and the Severn Estuary, and they indicated support for the RSPB’s submission in this regard.

14.2.8 The RSPB expressed significant concern at the failure to agree with National Grid the likely levels of water bird movement in the corridor between the Somerset Levels and the Severn Estuary. They noted a discrepancy between estimates provided by National Grid’s environmental consultants and data collected as part of a separate wind turbine application; they further noted that no reference is made to this discrepancy or the radar survey data in the PEIR. The RSPB further felt that despite the strategic importance of the project, the lack of engagement from National Grid had been disappointing and had failed to deliver a fair and transparent process for assessing impacts on Natura 2000 sites and species.

14.2.9 The Forest of Avon Trust made comments and suggestions about landscape mitigation. They requested that sufficient land is purchased around the infrastructure sites to ensure they blend with the wider landscape. They also requested that appropriate species are used and that a long term maintenance and management contract is incorporated. They suggested including tree planting, woodland management, hedgerow management, open-land conservation and access improvement schemes, across the entire Hinkley Point C Connection.

14.2.10 Others consultees such as the Avon Wildlife Trust commented on the T-pylon design, questioning whether it would have greater potential impacts on bird strikes.

Health

14.2.11 There were a number of general concerns relating to health, related to the effects of EMF however, most of the comments were specific to particular sections of the route and are reported in subsequent sections of this report.

Mitigation

14.2.12 The Forest of Avon Trust suggested National Grid take a proactive, creative and flexible approach, working in partnership with landowners, local authorities and


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other stakeholders to identify and implement the most effective mitigation solutions.

Policy

14.2.13 Whilst comments were received from wider consultees regarding policy issues these all related to specific sections of the route and are reported in subsequent sections of this report.

Routing and Design

14.2.14 The RSPB are concerned that the T-pylon design suggested in the PEIR does not include any attempts to mitigate the risk of bird strikes; they note that this could be done effectively by repositioning the top earth wire within the cable cluster.

Safety and Security

14.2.15 Whilst comments were received from wider consultees regarding safety and security these all related to specific sections of the route and are reported in subsequent sections of this report.

Socio-Economics

14.2.16 Whilst comments were received from wider consultees regarding socio-economics these all related to specific sections of the route and are reported in subsequent sections of this report.

14.3 Location Specific Responses Received

14.3.1 This section of the report summarises the representations received from wider consultees which relate to location specific issues. National Grid’s response to these representations is presented in Section 14.4 of this report.

Section A: Puriton Ridge

14.3.2 Two responses from wider consultation organisations commented specifically on Section A. No comments were received relating to consultation, cost, engineering and construction, environmental issues, mitigation, policy, safety and security and socio economics. Comments received in relation to other topic areas are set out below.

Alternatives

14.3.3 CPRE Somerset expressed a preference for the sub-sea option or underground cables for the entire route to minimise the impact on the landscape. They also specified that a GIL connection would be an acceptable alternative. CPRE also expressed concerns that the true costs of alternatives had been overestimated.

Health

14.3.4 CPRE Somerset expressed concern on behalf of the community about the impact of overhead lines on health, specifically regarding noise pollution, and EMF, emphasising that these health risks would be eliminated or minimised by using underground cables or GIL.


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Routeing and design

14.3.5 CPRE Somerset suggested that underground cables in Section A should be explored.

14.3.6 National Trust commented on the choice of pylon design, emphasising that the T-pylon design is smaller than the proposed steel lattice pylons and is therefore preferred. They raised equity concerns regarding the decision to propose steel lattice pylons in this area.

Section B: Somerset Levels and Moors South

14.3.7 A total of six responses from wider consultation organisations commented specifically on Section B. No comments were received relating to cost, mitigation, policy and safety and security. Comments received in relation to other topic areas are set out below.

Alternatives

14.3.8 Pylon-Moor-Pressure stated their preference for a sub-sea cable as the least intrusive method of connection. Similar views were also expressed by Biddisham Against Pylons who contested that the route should not be overhead across the Somerset Levels and suggested alternative methods. The group believed that the proposed overhead line represents ‘100 year old technology’ and indicated that it favoured more modern techniques of electricity transmission.

Consultation

14.3.9 Biddisham Against Pylons noted that the village of Biddisham has several elderly residents who did not have access to the internet, or public transport access to the nearest consultation event (in Mark). In order to ensure that these residents were able to assess the difference in impacts of the proposed T-pylons against the traditional lattice pylon the group requested that National Grid prepare paper copies of images from the video materials and share these with residents through personal visits. After being informed that National Grid was not able to provide these images the group responded, questioning the cost of the overall consultation in relation to this request. Pylon-Moor-Pressure suggested that the computer visualisation used in the consultation appeared to show denser and taller vegetation and tree cover than was actually present, giving a misleading impression of the visual impact. These views were echoed by Somerset Alliance Against Pylons.

14.3.10 In a separate response to the consultation, Pylon-Moor-Pressure reiterated their criticisms towards the consultation documents describing them as confusing and urged Sedgemoor District Council to reject the consultation exercise due to its flawed nature. Calls for rejection of the consultation were also expressed by Somerset Alliance Against Pylons.

14.3.11 In a further response Biddisham Against Pylons asserted their strong belief that consultation has been inadequate due a lack of detail about the proposals.


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Engineering and construction

14.3.12 Biddisham Against Pylons considered that there was a lack of information presented in the documentation about the proposed works in Section B. In particular they questioned what traffic would use particular roads, including the A38 (which they noted is a designated ‘red route’) and the proposed access road from it.

14.3.13 The group questioned what vehicles would use this access route and Biddisham Lane, suggesting that the need for a new, stronger bridge over the River Axe undermines claims that it would only be used by maintenance vehicles.

14.3.14 The group further commented on the proposed crossing of the River Axe and the

lack of information relating to how the proposed route would cross the River, given the transition from underground cables to a bridge.

Environment

14.3.15 Pylon-Moor-Pressure commented on the visual impact of the proposed overhead line in Section B, arguing that the changes to the landscape would be exacerbated by the removal of hedgerows. The group also expressed concerns about the impact of construction on the environment more generally.

Health

14.3.16 Pylon-Moor-Pressure suggested that National Grid had failed to adequately address the potential impacts on the health of communities in the area; including the effects of EMF on childhood leukaemia, which they believed National Grid had previously acknowledged.

Routeing and design

14.3.17 The proposals in Section B were opposed by Biddisham Against Pylons who stating that the proposed overhead line would impact views from the village of Biddisham towards Brent Knoll, and that the CSE compound and proposed works

compound would be in view from the village.

14.3.18 Similar views were expressed by Pylon-Moor-Pressure, who described themselves as a campaign group for the village of Mark.

14.3.19 CPRE Somerset responded requesting full undergrounding or sub-sea of the route stating that this could be funded from the proposed Hinkley Point C profits which otherwise would go to foreign companies. They argued that the overhead line would destroy not only the environment but also would prompt local communities to leave the Levels.

14.3.20 The National Trust commented extensively on the proposed use of the T-pylon for the route as a whole. In relation to Section B they referred to visibility from Brent Knoll (a designated heritage asset) and questioned whether mitigation would be possible to limit impacts from this viewpoint. CPRE Somerset were critical of the T-pylon describing them as outdated.


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Socio-economics

14.3.21 Pylon-Moor-Pressure commented that the proposals would cause disruption to the daily life of the village of Mark during construction, as well as impacting on property values and affecting tourism via visual impact.

14.3.22 CPRE Somerset called for parts of the proposed Hinkley Point C Power station profits to be used for socially beneficial projects such as funding energy efficiency grants to households, research into smart storage of energy and finding a solution to nuclear waste.

Section C: Mendip Hills

14.3.23 A total of three responses from wider consultation organisations commented specifically on Section C. No comments were received relating to alternatives, consultation, cost, engineering and construction, health, mitigation, policy, safety and security and socio economics. Comments received in relation to other topic areas are set out below.

Environment

14.3.24 Avon Wildlife Trust shared concerns that the proposed underground cable passes through a Strategic Nature Area, could affect the Lox Yeo River, and the Wildlife Reserve at Max Bog, which they noted is hydrologically linked to the river. The Trust also indicated concern regarding potential impacts to field ditches and indicated that they considered more assessment was needed to understand the long term impacts to local hydrological processes.

14.3.25 The Trust were also concerned about the potential heating effects of underground cables on the soil structure and biodiversity in the AONB, noting that they had repeatedly requested research into this issue from National Grid but it had not been addressed in the PEIR or the subsequent EIA.

Routeing and design

14.3.26 All three wider consultation responses expressed concerns about the impacts of undergrounding in the AONB. The National Trust expressed their support for the undergrounding; however they remained concerned that the overhead lines visible from the AONB should be carefully considered including from viewpoints such as Crook Peak and Brent Knoll. They also requested that the route of the underground cables be restored as soon as possible with appropriate landscaping.

14.3.27 CPRE Somerset suggested that the connection should also be undergrounded in populated areas to minimise effects on local communities.

Section D: Somerset Levels and Moors North

14.3.28 A total of 5 responses from wider consultation organisations commented specifically on Section D. No comments were received relating to health, policy and safety and security. Comments received in relation to other topic areas are set out below.


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Alternatives

14.3.29 Both CPRE Somerset and the National Trust expressed their support for a sub-sea option. Whilst CPRE expressed their belief that these options were both technical feasibility and affordable the National Trust acknowledged that higher costs would be likely if National Grid pursued these options.

14.3.30 Nailsea Against Pylons noted their belief that local residents preferred the installation of an entirely undergrounded or sub-sea connection. They suggested that National Grid consider in greater detail underground cable options which they viewed as a means of minimising construction impacts. Nailsea Against Pylons also noted their belief that National Grid should further explore the use of GIL and

suggested that members of the public had been misled regarding the safety levels of this technique.

Consultation

14.3.31 The National Trust and Yatton and Congresbury Wildlife Action Group (Yacwag) both requested further discussions with the National Grid Project Team. The National Trust reserved their right to comment once more information on visual effects had been provided. Yacwag requested the publication of local biodiversity data collected by National Grid.

14.3.32 Nailsea Against Pylons made a number of detailed comments on the consultation process. They were concerned that National Grid had paid insufficient attention to local opinion regarding alternative methods of transmission and suggested that focus on the new T-pylon design is a diversionary tactic. They also highlighted perceived inaccuracies and obfuscation in the consultation documentation regarding the size of the T-pylon and problems associated with the 3D modelling of the new design.

Cost

14.3.33 Nailsea Against Pylons acknowledged the higher costs associated with sub-sea or underground connections, however they challenged National Grid’s assessment of

the cost of an underground connection suggesting it would be substantially lower than original stated. They also suggested that costs borne by the community had not been taken into account.


14.3.34 Comments made on engineering and construction tended to focus on environmental and social impacts and as such have been reported under the relevant subheadings.

Environment

14.3.35 Yacwag expressed concerns about the impact of construction activities on local otter populations and requested that National Grid provide appropriate mitigation measures. To facilitate implementation of these measures, they supplied National Grid with baseline data from 2009 to 2013. The group also expressed concerns that removal and undergrounding of existing 132kV overhead lines may have


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negative environmental effects, particularly where these cables would be routed across SSSI’s.

14.3.36 The National Trust raised concerns about the visibility of the overhead lines from Cadbury Camp and Tickenham Ridge and suggested a number of methods for minimising these effects.

14.3.37 Nailsea Against Pylons expressed concerns that the T-pylon design may have negative landscape effects in comparison with traditional pylon designs.

14.3.38 Native Nailsea Environment and Wildlife Trust highlighted that the Moorend Spout nature reserve is under their ownership in this area, and requested that National Grid add markers to the power lines to help water birds avoid the conductors.

14.3.39 Avon Wildlife Trust expressed concerns regarding replacement of the 132kV overhead lines around Nailsea with underground cables and suggested impacts on peat in this area should be investigated and reported. Avon Wildlife Trust also expressed concerns about the impact of the route on Sites of Special Scientific Interest (SSSI) and called for further consultation with other stakeholders; namely Natural England and North Somerset Council regarding impacts and mitigation, the EA for advice about how to traverse rivers and Wessex Water regarding interactions with work taking place to resolve pollution in the Nailsea storm drain.

Mitigation

14.3.40 Yacwag supported the idea of an environmental fund to finance community projects along the connection. They viewed the proposed substation at Sandford as an ideal opportunity for launching such a scheme and suggested that the Strawberry Line be extended through this site. They also suggested the construction of a bridge at Congresbury which would improve countryside access for local residents with disabilities.

14.3.41 Yacwag also suggested that potential environmental damage could be offset through the creation of similar habitat or general improvements to wildlife sites elsewhere.

14.3.42 The National Trust noted their dissatisfaction regarding landscape assessments given the perceived exclusion of visual impacts of the overhead line in Section D from Cadbury Camp and Tickenham Ridge. They suggested that the pylon proposed in this location is painted in muted colours or that the route is realigned to bring it closer to the existing overhead line.

Routing and design

14.3.43 Nailsea Against Pylons expressed concerns regarding impacts associated with the T-pylon design suggesting that its size and solid central column make this design an inappropriate choice as a form of landscape mitigation.

14.3.44 However, Nailsea Against Pylons welcomed proposals to remove and underground the two existing 132kV overhead lines in Section D which currently run in close proximity to a number of residential areas.


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Socio-economics

14.3.45 Nailsea Against Pylons expressed concerns that local communities would unfairly bear the cost of the project. They highlighted impacts to property prices and loss of tourism based revenue as potential effects which may occur in Section D.

Section E: Tickenham Ridge

14.3.46 A total of five responses from wider consultation organisations commented specifically on Section E. No comments were received relating to alternatives, cost, engineering and construction, health, mitigation, policy, safety and security and socio-economics. Comments received in relation to other topic areas are set out below.

Consultation

14.3.47 Avon Wildlife Trust challenged the information in the PEIR, suggesting a lack of detail, as well as inaccurate information and omissions.

Environment

14.3.48 The Forest of Avon Trust emphasised the importance of considering the approved Forest Plan which lays out strategies for increasing woodland cover in the area, the impact on wildlife, and the impact on amenity and recreation.

Routing and design

14.3.49 CPRE Somerset expressed the view that underground cables should be implemented across Tickenham Ridge, they consider that the underground cables proposed in the Mendip Hills AONB should be continued both South and North of that location.

14.3.50 The National Trust noted that they have no comments on Section E other than in support of the decision to avoid the designated heritage area of Tyntesfield. AWT welcomed the move away from Priors Wood.

Section F: Portishead (including Route Options A and B)

14.3.51 A total of five responses from wider consultation organisations commented specifically on Section F. No comments were received relating to alternatives, consultation, cost, engineering and construction, health, policy, safety and security and socio-economics. Comments received in relation to other topic areas are set out below.

Environment

14.3.52 The Avon Wildlife Trust expressed no preference on the proposed route options in Section F. They noted that Option A avoids the Portbury Wharf Nature Reserve which is under their ownership but raised concerns that this option crosses five Sites of Nature Conservation Interest (SNCIs). They suggested that Option B may create potential obstructions to a known flight corridor running between the estuary, the reserve and the Gordano Valley.


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14.3.53 The Trust also indicated concern regarding the undergrounding of the 132kV overhead lines at the reserve and noted that the land take required is double that suggested at a Joint Thematic Workshop in November 2012.

14.3.54 The Portbury Historical Association indicated concerns regarding the landscape impacts of Option A in the Portbury area and the setting of the Listed church in particular.

Mitigation

14.3.55 The Avon Wildlife Trust expressed support for the proposals to use an Ecological Clerk of Works during the construction phase, particularly at sensitive sites such as Portbury Wharf Nature Reserve. They suggested that this role be filled by them

given their in-depth knowledge which their ecological consultancy has of the site.

Section G: Avonmouth

14.3.56 No responses received from wider consultation organisations commented specifically on Section G during this period of consultation.

Section H: Hinkley Line Entry

14.3.57 No responses received from wider consultation organisations commented specifically on Section H during this period of consultation.

14.4 National Grid’s regard to Responses Received

Project Wide Issues

14.4.1 This section reports on National Grid’s response to the project wide issues raised by wider consultees during the Stage 4 Consultation and the changes to the project that were made in response to the representations. The issues raised are responded to under each of the following themes with further responses presented by organisation in the Tables at Appendix 79. The Consultation Summary Report presented at Appendix 27 provides further information on how the responses were coded and analysed.

Alternatives;

Consultation;

Cost;

Engineering and Construction;

Environment;

Health;

Mitigation;

Policy;

Routeing and Design;


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Safety and Security; and

Socio-Economics.

Alternatives

14.4.2 The main issues raised by wider consultees in relation to alternatives are set out in Table 14.1 below together with National Grid’s response to these issues and whether the representation resulted in a change to the proposals.

Table 14.1 Project wide issues relating to alternatives

Representation National Grid’s Response Change (Yes/No)

The connection should be sub-sea under the Bristol Channel or underground using GIL.

The ability to use GIL to facilitate the delivery of power from Hinkley Point C was considered within the further Strategic Options Report produced in August 2011 in support of the Stage 3 consultation and which is available to view on the Hinkley Point C Connection project website.

The report explains that GIL was not preferred for this scheme as its higher capital and lifetime costs, compared to the alternatives, could not be justified. In the section of the route which will be undergrounded XLPE cable is preferred to GIL due to its lower cost.

Subsea cables to facilitate the delivery of power from Hinkley Point C were considered within the SOR reports that National Grid prepared to support consultation Stages 1-3 of the project, and which are available to view on the Hinkley C Connection website.

The report concluded that a sub-sea connection did not best meet National Grid’s statutory duties because of its significantly greater capital and lifetime cost when compared to the alternatives.

No

No

Consultation

14.4.3 The main issues raised by wider consultees in relation to consultation are set out in Table 14.2 below together with National Grid’s response to these issues and whether the representation resulted in a change to the proposals.

Table 14.2 Project wide issues relating to consultation


There is insufficient or inaccurate data in the PEIR

The purpose of the PEIR was to present a preliminary assessment of the effects of the Proposed Development on the environment in sufficient detail to allow consultees to understand

N/A

Concerned that the lack of N/A


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detailed information in the PEIR prevented full comments on the proposals

the likely significant impacts. Where further work was required or information was missing this was clearly indicated within the document and is addressed within the respective chapters of the ES that accompanies the DCO application. Where wider consultees questioned the accuracy of the information presented within the PEIR these were discussed with them and if necessary changes incorporated in the ES.

The thematic groups have been inaccessible

The purpose of the Thematic Groups was to allow National Grid to gather information on appropriate baseline data, its interpretation and analysis and to inform its submission of an EIA Scoping Report to PINS. As a result, the membership of the Thematic Groups was limited to organisations with a statutory responsibility and those with a specialist professional background. However the invitee list did include representatives of both the Avon and Somerset Wildlife Trusts.

N/A

Cost

14.4.4 The main issues raised by wider consultees in relation to cost are set out in Table 14.3 below together with National Grid’s response to these issues and whether the representation resulted in a change to the proposals.

Table 14.3 Project wide issues relating to cost


Consumers would be willing to contribute to the cost of alternatives.

The mechanism by which the costs of the national electricity transmission system are recovered is governed by OFGEM. It would therefore be inappropriate for National Grid to ask “local people” to contribute to the cost of national infrastructure required for the benefit of all electricity consumers.

No


14.4.5 The main issues raised by wider consultees in relation to engineering and construction are set out in Table 14.4 together with National Grid’s response to these issues and whether the representation resulted in a change to the proposals.


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Table 14.4 Project wide issues relating to engineering and construction


Concerns regarding potential construction related impacts to local wildlife sites in Somerset, particularly where temporary culverting is required

During construction National Grid will employ a range of working practices and implement appropriate mitigation to ensure that effects on local wildlife sites are minimised as far as possible. Further information on the construction methods and mitigation proposed is presented in the CEMP at Volume 5.26 and BMS at Volume 5.26, Appendix 2 of the ES which accompanies the DCO application. Upon completion of the works all land affected or used during construction would be reinstated in accordance with the DEFRA Code of Practice for the Sustainable Use of Soils on Construction Sites.

No

Will the T-pylon design have greater potential impacts on bird strikes.

An assessment of the T-pylon and its potential for impacts on birds compared to traditional pylon designs is presented in Volume 5.8, Chapter 8 of the ES and the HRA report (Volume 5.20). Although there is no scientific literature directly addressing the collision risk to birds of T-pylons, the assessment reviews existing literature regarding the reasons for collision with overhead lines and applies this to the T-pylon design.

No

Environment

14.4.6 The main issues raised by wider consultees in relation to the environment are set out in Table 14.5 below together with National Grid’s response to these issues and whether the representation resulted in a change to the proposals.

Table 14.5 Project wide issues relating to the environment


Concern about the construction impacts on wildlife and biodiversity

National Grid will employ a range of construction techniques and mitigation measures to ensure that construction works avoid adverse effects on wildlife. These include timing works to avoid the most sensitive ecological seasons, implementing appropriate protective fencing and employing wildlife friendly construction methods. Further information on the methods to be employed are presented in the CEMP, Volume 5.26, which accompanies the DCO application.

N/A

Concern about the cumulative impact of developments and further environmental assessment should be undertaken

The developments to be considered in the cumulative effects assessment were agreed with the local authorities and the cumulative effects assessment is presented at Volume 5.17, Chapter

N/A


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particularly relating to the impact on Ramsar sites

17 of the ES submitted with the DCO application.

The process of HRA has involved National Grid engaging with Natural England, RSPB and other specialist interest groups over a sustained period as the Project design has developed. Detailed discussions regarding the differences, in terms of bird collision and displacement, between the T-pylon, the 400kV steel lattice and the 132kV steel lattice pylons were held. The information provided in the PEIR was preliminary and full baseline data and assessment of effects is provided in the HRA Report (Volume 5.20) and Volume 5.8, Chapter 8 of the ES.

There was no reference to the species-rich ditches in the PEIR and therefore the potential impact on invertebrates had not been considered

At the time of the publication of the PEIR surveys and assessments in relation to the ditches and rhynes by invertebrates were still ongoing. These surveys were subsequently completed and are presented within Volume 5.8, Chapter 8 of the ES that accompanies the DCO application.

N/A

Concerns were highlighted with regard to impact on birds due to the bird flight path between the Somerset Levels and the Severn Estuary

Throughout the development of the project, National Grid undertook a range of wintering bird surveys over multiple years. These surveys informed the selection of a preferred route corridor, the identification of potential routes, the selection of a preferred route and the selection of the pylon design to be adopted. National Grid also liaised extensively with Natural England both through one-to-one meetings and the Thematic Groups and the local authorities over the scope of surveys undertaken and their findings.

There is currently no evidence that confirms movements of SPA species across the existing 132kV overhead line and the proposed route of the 400kV overhead line that will replace it, particularly at heights that would pose a collision risk. However, a degree of residual uncertainty remains. National Grid’s approach to dealing with this uncertainty is a three pronged approach:

Replacement of the steel lattice design is Section A and B with the T-pylon design;

Installation of bird diverters at three locations where landscape features indicate flight lines are most likely to occur;

Implementing a monitoring strategy along additional sections of the overhead line where radar data has indicated potential movements of duck species (and diverters are not proposed).

N/A

There is significant concern at the failure to agree with National Grid the likely levels of water bird movement in the corridor between the Somerset Levels and the Severn Estuary

N/A

No reference is made to National Grid consulted with Natural England, N/A


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the radar survey data in the PEIR

RSPB and the authors of the radar study to examine the apparent discrepancies between the findings of National Grid’s vantage point surveys and the radar studies commissioned by wind farm developers. The result of these consultations is described in Volume 5.8, Chapter 8 of the ES Ornithology Appendix and is also fully considered in the HRA Report (Volume 5.20).

National Grid notes that EIA and HRA must primarily concern itself with regular bird flight patterns, such as migratory paths and daily flights between feeding and roosting grounds. Movements associated with especially adverse weather conditions (i.e. weather patterns that are extremely unusual and unpredictable) can only be given limited weight in impact assessment.

An assessment of the T-pylon and its potential for impacts on birds compared to traditional pylon designs is presented in the ES and the HRA report. Although there is no scientific literature directly addressing the collision risk to birds of T-pylons, the assessment reviews existing literature regarding the reasons for collision with overhead lines and applies this to the T-pylon design.

Arising from these assessments, National Grid and Natural England have agreed an approach to reducing collision risk through design, mitigation, monitoring and research. This approach, (which includes the use of T-pylons, fitting of bird flight diverters, monitoring specific sections of route, application of National Grid’s Bird Flight Diverter Protocol and contributions to local research) is described in Volume 5.8, Chapter 8 of the ES and HRA Report (Volume 5.20).

Despite the strategic importance of the project, the lack of engagement from National Grid had been disappointing and had failed to deliver a fair and transparent process for assessing impacts on Natura 2000 sites and species

N/A

Sufficient land should be purchased around the infrastructure sites to ensure they blend with the wider landscape

At the proposed substation site at Sandford and the CSE sites at Bridgwater Tee and South of the Mendip Hills National Grid has acquired additional land for the purposes of landscaping. As part of the PEIR that was published to accompany the statutory Stage 4 consultation full details of the landscaping schemes proposed were published. Further information on the landscaping proposals (which were updated following discussions with the local authorities and statutory consultees) is presented in Volume 5.7, Chapter 7 of the ES which accompanies the DCO application.

No

Appropriate species should be used and a long term maintenance and management contract should be incorporated

Embedded mitigation works identified in the ES will be secured by requirements set out in the DCO and are separate to the work proposed in the Hinkley Point C Connection project OSPES (Volume 5.25). The OSPES includes landscape

N/A


741


Tree planting, woodland management, hedgerow management, open-land conservation and access improvement schemes, across the entire Hinkley Point C Connection

works to further reduce the adverse residual effects on landscape character and views of the Proposed Development. National Grid would enter into an agreement with relevant local authorities to fund the planting and enhancement works set out in the OSPES. The OSPES includes an NBS specification, plant species list and management operations.

N/A

Health

14.4.7 The main issues raised by wider consultees in relation to health are set out in Table 14.6 below together with National Grid’s response to these issues and whether the representation resulted in a change to the proposals.

Table 14.6 Project wide issues relating to health


Concerns were raised regarding the potential health effects of overhead lines and EMFs

Electric and magnetic fields (EMFs) are produced wherever electricity is used, and there have been suggestions that exposure to these fields might be a cause of ill health. National Grid fully recognises people’s concerns and the uncertain scientific position on this subject.

National Grid takes this issue very seriously and relies on authoritative and independent scientific organisations such as the World Health Organisation (WHO) and Public Health England (PHE) to review the worldwide body of scientific evidence on EMFs and health rather than relying on its own assessment of the science. We believe it is right that the decision on what is acceptable or not is made independently of National Grid.

Health considerations are given a high priority in the process by which National Grid arrive at any proposals for new electricity circuits. Assessment of compliance with national guidance and policies is key to National Grid’s approach. The UK has a carefully thought-out set of policies for managing EMFs, which includes both numerical exposure guidelines to protect against established, acute effects of EMFs, and precautionary policies to provide appropriate protection against the possibility of chronic effects of EMFs at lower levels, including, specifically, the possibility of a risk for childhood leukaemia. These policies are incorporated into the decision-making process for Development Consent in National Policy Statement EN-5.

N/A


742


National Grid’s approach is to ensure that all of its assets comply with those policies, which are set by Government on the advice of their independent advisors PHE. This ensures that health concerns are properly and adequately addressed. The evidence concerning compliance with these policies as specified in EN-5, including the numerical guidelines are fully and publically documented in Volume 5.16, Chapter 16 of the ES.

Mitigation

14.4.8 The main issues raised by wider consultees in relation to mitigation are set out in Table 14.7 below together with National Grid’s response to these issues and whether the representation resulted in a change to the proposals.

Table 14.7 Project wide issues relating to mitigation


National Grid should take a proactive, creative and flexible approach, working in partnership with landowners, local authorities and other stakeholders to identify and implement the most effective mitigation solutions

Site specific mitigation details were developed through discussions with the local authorities and statutory consultees and are provided in Volume 5.7, Chapter 7 of the ES and details of the offsite measures proposed are presented in the OSPES Volume 5.25.

N/A

Policy

14.4.9 Whilst comments were received from wider consultees regarding policy issues these all related to specific sections of the route and are reported in subsequent sections of this report.

Routeing and design

14.4.10 The main issues raised by wider consultees in relation to routeing and design are set out in Table 14.8 together with National Grid’s response to these issues and whether the representation resulted in a change to the proposals.


743

Table 14.8 Project wide issues relating to routeing and design


The T-pylon design suggested in the PEIR does not include any attempts to mitigate the risk of bird strikes

Throughout the development of the project, National Grid undertook a range of wintering bird surveys over multiple years. These surveys informed the selection of a preferred route corridor, the identification of potential routes, the selection of a preferred route and the selection of the pylon design to be adopted. National Grid also liaised extensively with Natural England both through one-to-one meetings and the Thematic Groups and the local authorities over the scope of surveys undertaken and their findings.

There is currently no evidence that confirms movements of SPA species across the existing 132kV overhead line and the proposed route of the 400kV overhead line that will replace it, particularly at heights that would pose a collision risk. However, a degree of residual uncertainty remains. National Grid’s approach to dealing with this uncertainty is a three pronged approach:

Replacement of the steel lattice design in Section A and B with the T-pylon design;

Installation of bird diverters at three locations where landscape features indicate flight lines are most likely to occur;

Implementing a monitoring strategy along additional sections of the overhead line where radar data has indicated potential movements of duck species (and diverters are not proposed).

No

Safety and security

14.4.11 Whilst comments were received from wider consultees regarding safety and security these all related to specific sections of the route and are reported in subsequent sections of this report.

Socio-economics

14.4.12 Whilst comments were received from wider consultees regarding socio-economics these all related to specific sections of the route and are reported in subsequent sections of this report.

Location Specific Issues

14.4.13 This section reports on National Grid’s response to the location specific issues raised by wider consultees during the Stage 4 Consultation and the changes to the project that were made in response to the representations. The issues raised


744

are responded to under each of the following themes with further responses presented by organisation in the Tables at Appendix 79. The Consultation Summary Report presented at Appendix 27 provides further information on how the responses were coded and analysed.

Alternatives;

Consultation;

Cost;

Engineering and Construction;

Environment;

Health;

Mitigation;

Policy;

Routeing and Design;

Safety and Security; and

Socio-Economics.


14.4.14 The main issues raised by wider consultees in relation to Section A - Puriton Ridge are set out in Table 14.9 below together with National Grid’s response to these issues and whether the representation resulted in a change to the proposals.

Table 14.9 Issues Relating to Section A


Alternatives

The connection should be made using underground cables or GIL.

The ability to use underground cables and GIL to facilitate the delivery of power from Hinkley Point C was considered within the further Strategic Options Report produced in August 2011 in support of the Stage 3 consultation.

The report explains that underground cables and GIL were not preferred for this scheme as their higher capital and lifetime costs, compared to the alternatives, could not be justified. In the section of the route which will be undergrounded XLPE cable is preferred to GIL due to its lower cost.

No

The costs of alternative connection options have

National Grid supported the production by the IET of an independent transmission cost study.

N/A


745


been overestimated. The IET Report, which was based on 2011 prices, sets out that for a 75km medium rated overhead line is £1.6m per km and for a 15km medium rated direct buried cable is £17.53m per km. These cost estimates are broadly similar to those used by National Grid.

Health

The impact of overhead lines on health would be eliminated or minimised by using underground cables or GIL.

Electric and magnetic fields (EMFs) are produced wherever electricity is used, and there have been suggestions that exposure to these fields might be a cause of ill health. The NPS EN-5 highlights at paragraph 2.10.6 that ‘the balance of scientific evidence over several decades has not proved a causal link between EMFs and cancer or any other disease’


Health considerations are given a high priority in the process by which we arrive at any proposals for new electricity circuits. Assessment of compliance with national guidance and policies is key to our approach. The UK has a carefully thought-out set of policies for managing EMFs, which includes both numerical exposure guidelines to protect against established, acute effects of EMFs, and precautionary policies to provide appropriate protection against the possibility of chronic effects of EMFs at lower levels, including, specifically, the possibility of a risk for childhood leukaemia. These policies are incorporated into the decision-making process for Development Consent in National Policy Statement EN-5.

National Grid’s approach is to ensure that all of its assets comply with those policies, which are set by Government on the advice of their independent advisors PHE. This ensures that health concerns are properly and adequately addressed. The evidence concerning compliance with these policies as specified in EN-5, including the numerical guidelines are fully and publically documented in Volume 5.16, Chapter 16 of the ES. Additionally, in developing a route for the connection National Grid sought to maximise the distance from settlements and residential

No


746


properties as far as possible on the grounds of general amenity.

National Grid operates an EMF information website and telephone helpline to answer any questions and concerns from members of the public. People requiring further information can look at the EMFs information website at www.emfs.info, or alternatively contact the EMF Helpline on 0845 702 3270 or via email – [email protected]

Routeing and Design

T-pylons should be used in Section A

As part of the development of the proposed application, National Grid undertook an appraisal to consider the use of a new pylon design, the T-pylon, as an alternative to the traditional steel lattice design for the overhead line sections of the connection. This appraisal is documented in the ‘Pylon Design Options Report’ and demonstrates how statutory duties, policy considerations and environmental issues have been considered and makes recommendations for a pylon design that National Grid should take forward to consultation for the Hinkley Point C Connection Project. This appraisal concluded whilst the T-pylon is lower in height and offered advantages in certain sections of the route over the steel lattice pylons, it was more prominent when viewed at close proximity due to its solid central column and cross beam. In Section A (Puriton Ridge) the Pylon Design Options Report concluded that due to the presence of existing overhead line infrastructure of lattice steel construction and the presence of a number of receptors in close proximity to the route the steel lattice pylon was marginally considered preferable.

In response to numerous representations received regarding the choice of pylon on Puriton Ridge National Grid back checked and reviewed its previous decisions. In this area due to the marginality of National Grid’s original preference and the strong support for the T-pylon expressed in the representations received National Grid is proposing to include this change in its final proposals.

Yes

The connection should be underground in Section A.

The COR which was published as part of the Stage 3 Draft Route consultation assessed overhead line and underground cable options on Puriton Ridge against a range of various factors and policy provided in the National Policy Statement for Electricity Networks (EN-5). In this area the COR concluded that the benefits from the use of underground cables as an alternative to an overhead line would not clearly outweigh any extra

No

http://www.emfs.info/

mailto:[email protected]


747


economic, social and environmental impacts. As a result undergrounding would not be justified within Study Area A.

Section B: Somerset Levels and Moors

14.4.15 The main issues raised by wider consultees in relation to Section B – Somerset Levels and Moors are set out in Table 14.10 below together with National Grid’s response to these issues and whether the representation resulted in a change to the proposals.

Table 14.10 Issues Relating to Section B


Alternatives

The route should not be overhead across the Somerset Levels

The COR which was published as part of the Stage 3 Draft Route consultation assessed overhead line and underground cable options within Section B (Somerset Levels and Moors) against a range of various factors and policy provided in the National Policy Statement for Electricity Networks (EN-5). The COR concluded that the benefits from the use of underground cables as an alternative to an overhead line would not clearly outweigh any extra economic, social and environmental impacts. As a result undergrounding would not be justified and therefore National Grid was unable to accommodate this suggestion within its proposals.

No

The proposed overhead line represents 100 year old technology. and indicated that it favoured more modern techniques of electricity transmission

The National Policy Statement (EN-5) recognises that the use of overhead line technology is not generally incompatible with developers’ statutory duty under section 9 of the Electricity Act to have regard to amenity and to mitigate impacts. As part of the development of the proposals National Grid considered a wide range of technologies (including both overhead lines and underground cables) for the connection and concluded that a predominantly overhead line connection best accords with its statutory duties and licence obligations. This consideration was documented in the COR that accompanied the Stage 3 Draft Route Consultation.

No

Consultation

The village of Biddisham has several elderly residents who did not have access to the internet, or public transport access to

Following discussion with the local parish council at which an additional date on the consultation vehicle programme was suggested, National Grid identified a safe and available local venue at Tanyard Farm Nurseries, Turnpike Rd, Axbridge,

Yes


748


the nearest consultation event at Mark.

BS26 2JG and held an event on Saturday 12 October 2013. National Grid was pleased to provide this additional opportunity for the local community to engage in the consultation.

National Grid should prepare paper copies of images from the video materials.

In response to this request and following a conversation with a member of Biddisham Against Pylons at a public exhibition, National Grid provided the requested stills.

N/A

The computer visualisation used in the consultation appeared to show denser and taller vegetation and tree cover than was actually present, giving a misleading impression of the visual impact.

A 3D computer model which allowed an “interactive” fly-through perspective of the proposals was produced for the statutory Stage 4 Consultation and was based on technically accurate mapping of the proposals and detailed photographic surveys. Given the size of the area over which the connection is proposed it was not possible to apply the same levels of detail to all parts of the model however, sufficient detail was included provide consultees with a realistic impression of the proposals and of the landscape within which they would appear. It also offered the option to compare existing infrastructure, the T-pylon and the equivalent 400,000 volt steel lattice pylons.

N/A

The consultation documents are confusing as information on the T-pylon and the height of pylons is inaccurate

Project News and the Public Consultation Overview Report are part of the series of regular public information updates published by National Grid during consultation on the proposals since 2009. In the September 2013 edition of the Project News and the Overview Report an illustration was provided to indicate the difference in height between the traditional 400kV steel lattice pylons (approximately 46.5m high) and the T-pylon (approximately 34.5m high). The Pylon Design Options Report which was also published to accompany the statutory Stage 4 Consultation included detailed information on each of the pylon types and a plan illustrating the differences in size and height between the 400kV steel lattice pylon, the 400kV low height steel lattice pylon, the T-pylon and the existing 132kV steel lattice pylons. This plan was also available in the Q&A section of the project website. National Grid also developed a 3D computer model which was available to view at the public Information Hubs at Avonmouth, Nailsea and Bridgwater and at well-advertised public events along the proposed route.

No

The consultation has been inadequate due a lack of detail about the proposals

National Grid formally consulted on detailed proposals for the proposed Hinkley Point C Connection project under sections 42 and 47 of the Planning Act 2008 between 3 September and 29 October 2013. This followed nearly 4 years of regular engagement with communities, their

No

Insufficient information has been provided to enable

No


749


wide consultative engagement

representatives and a range of statutory consultees at each key stage in the development of the project.

The purpose of the PEIR was to present a preliminary assessment of the effects of the Proposed Development on the environment in sufficient detail to allow consultees to understand the likely significant impacts of the Proposed Development. Where further work was required or information was missing this was clearly indicated within the document and is addressed within the respective chapters of the ES that accompanies the DCO application. National Grid also liaised extensively with the Thematic Groups over the scope of surveys undertaken and their findings. Information from these discussions was also used to inform the development of the proposed application.


National Grid have not provided sufficient information and a lack of detail on the works compound at Biddisham/Tarnock and the associated highway matters from the A38 and surrounding roads.

National Grid engaged with stakeholders and local communities at key stages in the development of the proposals for the Hinkley Point C Connection since 2009, at each stage introducing and explaining the key features of the proposals and how decisions had been influenced by feedback from earlier pre-statutory stages of consultation. Between 3 September and 29 October 2013, National Grid consulted on detailed proposals and preliminary environmental information. Having developed detailed proposals it was possible also to describe the requirements and potential impacts of construction of the new connection in specific detail for the first time. This included the proposals for a temporary construction compound near Tarnock and arrangements for construction traffic access which are described in the PEIR. The consultation period provided 8 weeks to comment on this, and all other aspects of the detailed proposals.

No

What vehicles would use Biddisham Lane

National Grid can confirm that it is not proposing to use Biddisham Lane for construction traffic.

N/A

What size would the construction compound at Tarnock be.

The construction compound illustrated in the statutory Stage 4 Consultation was larger than the actual area that will be required for the construction compound to allow consultees provide feedback on its exact location. The construction compound will be approximately 100m x 100m (approximately 10,000m2 or 2.5 acres) and will contain single storey office accommodation, welfare facilities, loading and unloading areas for materials, car parking areas and storage areas. The compound

N/A


750


will be surrounded by a landscaping bund which will help to screen the development and a fence will be installed around the perimeter for security reasons.

Why is a bridge crossing required for the River Axe.

As part of its DCO application National Grid has included two options for crossing the River Axe. One option would involve the use of HDD to pass under the River and the other would involve the construction of a cables bridge to carry the cables over the River. Details of both options were contained within the information published as part of the Stage 4 consultation and both options were assessed in the PEIR that accompanied the consultation.

N/A

Environment

Concerned about the visual impact of the proposed overhead line in Section B

The potential for effects on landscape and views in the Somerset Levels and Moors were an important consideration for National Grid in the development and design of the project. In this area National Grid is proposing a number of measures to minimise effects, these include the removal of an existing 132kV overhead line, maximising distance from properties and settlements wherever possible and utilising the low height T-pylon design.

Further consideration of the effects on views in Section B – Somerset Levels and Moors is presented in Volume 5.7, Chapter 7 of the ES.

No

Health

National Grid had failed to adequately address the potential impacts on the health of communities in the area; including the effects of EMF on childhood leukaemia

Electric and magnetic fields (EMFs) are produced wherever electricity is used, and there have been suggestions that exposure to these fields might be a cause of ill health. The NPS EN-5 highlights at paragraph 2.10.6 that ‘the balance of scientific evidence over several decades has not proved a causal link between EMFs and cancer or any other disease’


Health considerations are given a high priority in the process by which we arrive at any proposals for new electricity circuits. Assessment of compliance with national guidance and policies is

No


751


key to our approach. The UK has a carefully thought-out set of policies for managing EMFs, which includes both numerical exposure guidelines to protect against established, acute effects of EMFs, and precautionary policies to provide appropriate protection against the possibility of chronic effects of EMFs at lower levels, including, specifically, the possibility of a risk for childhood leukaemia. These policies are incorporated into the decision-making process for Development Consent in National Policy Statement EN-5.

National Grid’s approach is to ensure that all of its assets comply with those policies, which are set by Government on the advice of their independent advisors PHE. This ensures that health concerns are properly and adequately addressed. The evidence concerning compliance with these policies as specified in EN-5, including the numerical guidelines are fully and publically documented in Volume 5.16, Chapter 16 of the ES. Additionally, in developing a route for the connection National Grid sought to maximise the distance from settlements and residential properties as far as possible on the grounds of general amenity.

National Grid operates an EMF information website and telephone helpline to answer any questions and concerns from members of the public. People requiring further information can look at the EMFs information website at www.emfs.info, or alternatively contact the EMF Helpline on 0845 702 3270 or via email – [email protected]

Routeing and Design

The proposed overhead line would impact views from the village of Biddisham towards Brent Knoll, and that the CSE compound and proposed works compound would be in view from the village

National Grid acknowledges that the pylons and CSE compound proposed in the northern extent of Section B will be visible from some receptors in Biddisham. As part of the development of the route, National Grid sought to maximise the distance of the overhead line from the settlement by adopting a route further west than the existing 132kV overhead line. It also sought to minimise the visibility of the CSE compound by siting it distant from the settlement and proposing an extensive scheme of landscaping.

No

Views towards the Mendip Hills AONB will be despoiled by the proposals.

The Mendip Hills AONB is the only nationally designated landscape along the length of the connection and therefore was an important consideration in routeing from the outset of the project. The importance of this area both in landscape terms and as a recreational and tourist resource was also highlighted in numerous public

No




752


and statutory representations submitted during the various stages of pre-application consultation. As a result of the statutory protection afforded to this landscape and the representations received, National Grid proposes to underground the connection within this designated area. In order to minimise effects on the setting of the AONB National Grid is also proposing to extend the undergrounding approximately 1km south and north of the AONB boundary.

Further information on the effects of the proposals on public and private views in the areas to the north and south of the AONB is presented in Volume 5.7, Chapter 7 of the ES that accompanies the DCO application.

Concerned about visibility of the T-pylons from Brent Knoll

National Grid acknowledges that the proposed pylons would be visible from some points on Brent Knoll. In developing its proposals careful consideration was given to the effects on landscape and views. In this area National Grid is proposing to utilise the T-pylon which is lower in height than the traditional steel lattice pylons and is less visible at distance.

No

The T-pylon is outdated The T-pylon is a new design of electricity pylon and was the winner of the 2011 Pylon Design Competition run by the Royal Institute of British Architects, DECC and National Grid. Since this date, National Grid has worked with its designers to develop the design further for use on the transmission system.

N/A

Socio-economics

The proposals would cause disruption to the daily life of the village of Mark during construction

As part of the development of its proposals, National Grid consulted with the local highways authorities and the Highways Agency to ensure that the proposed routes for construction traffic are appropriately sited and minimise disruption as far as possible. The amount of construction activities being carried out on smaller highway routes will be limited to reduce the impact to local residents and businesses. Mark Causeway itself would not be used for construction, however there would be a crossing point on the Causeway at which point priority would be given to highway traffic. Further detail on the traffic management measures proposed during construction to minimise impacts are set out in the CTMP which accompanies the DCO application.

No

The proposals would impact on property values

In accordance with the Holford Rules the Proposed Development has been designed to avoid residential areas and individual properties as far as

No


753


possible. Whilst socio-economic factors have been taken into account in the development and refinement of the proposals, the effect on the value of private individual properties has not been a factor in the decision making process. The effect on house prices of an overhead transmission line is not a matter that requires assessment under the EIA Regulations. PINS have not required such effects to be assessed in the scoping opinion adopted for this project or adopted in relation to other nationally significant infrastructure projects. The effect on house prices as a result of this development, as with all types of development, is not material to the planning merits of the proposal.

Compensation arrangements are set out in legislation. The relevant legislation provides that those whose property will have National Grid equipment sited on or across it (e.g. if the conductors/wires oversail a landholding) are entitled to compensation under property law. National Grid works closely with any landowners on whose land our equipment is sited to negotiate compensation terms if this is appropriate. Any party who feels that they may have a claim for compensation, is recommended to seek professional advice and /or contact National Grid who will be happy to discuss their individual situation.

Parts of the proposed Hinkley Point C Power station profits should be used for socially beneficial projects such as funding energy efficiency grants to households

Any questions regarding the allocation of the profits from the proposed Hinkley Point C Power Station should be directed to EDF Energy in the first instance.

N/A

Section C: Mendip Hills

14.4.16 The main issues raised by wider consultees in relation to Section C – Mendip Hills are set out in Table 14.11 below together with National Grid’s response to these issues and whether the representation resulted in a change to the proposals.

Table 14.11 Issues Relating to Section C


Environment

The proposed underground cable passes through a Strategic Nature Area,

National Grid noted this representation. The Ecological Management Plan sets out a number of measures to be implemented during construction

No


754


could affect the Lox Yeo River, and the Wildlife Reserve at Max Bog, which is hydrologically linked to the river.

to minimise effects on designated sites and ecological species and habitats.

Concerned about the potential impacts to field ditches and the long term impacts to local hydrological processes.

Whilst undergrounding would have environmental effects these would only be temporary as they would last for the duration of construction activities only. Prior to construction commencing, a full survey of existing drains would be undertaken and a pre-construction and post construction drainage mitigation plan would be developed and agreed with the relevant stakeholders.

No

Concerned about the potential heating effects of underground cables on the soil structure and biodiversity in the AONB

The effects of the underground cables are assessed in the respective chapters of the ES that accompanies the DCO application.

No

Routeing and Design

Concerns about the impacts of undergrounding in the AONB.

As part of the identification of the most appropriate technology for the connection through the Mendip Hills AONB, consideration was given to the potential for impacts on features of the biodiversity interest and the historic environment. Whilst the assessment identified the potential for effects on ecological receptors and unknown buried archaeology in this area during construction these effects were not considered so significant so as to outweigh the benefits of undergrounding on the purposes of the AONB designation.

No

The overhead lines visible from the AONB should be carefully considered including from viewpoints such as Crook Peak.

The Mendip Hills AONB is the only nationally designated landscape along the length of the connection and therefore was an important consideration in routeing from the outset of the project. The prominence of Crook Peak within the AONB and the importance of views from it were highlighted in numerous public and statutory representations submitted during the various stages of pre-application consultation. As a result of the statutory protection afforded to this landscape and the representations received, National Grid proposes to underground the connection within this designated area. In order to minimise effects on the setting of the AONB National Grid is also proposing to extend the undergrounding approximately 1km south and north of the AONB boundary. Whilst an overhead line would be present in some views the use of the T-pylon would help to minimise the visual impact as it is lower than the traditional steel lattice pylon and is less visible with distance.

No


755


Further information on the effects of the proposals on public and private views to and from the AONB are presented in Volume 5.7, Chapter 7 of the ES that accompanies the DCO application.

The route of the underground cables should be restored as soon as possible with appropriate landscaping

National Grid can confirm that upon completion of the installation of the underground cables the land would be reinstated. The only visible signs that would indicate the presence of underground cables would be the above ground link pillars that would be spaced at intervals along the cables route.

N/A


14.4.17 The main issues raised by wider consultees in relation to Section D – Somerset Levels and Moors North are set out in Table 14.12 below together with National Grid’s response to these issues and whether the representation resulted in a change to the proposals.

Table 14.12 Issues Relating to Section D


Alternatives

National Grid should consider in greater detail underground cable options to help minimise construction impacts

The COR which was published as part of the Stage 3 Draft Route consultation assessed overhead line and underground cable options within Section D against a range of various factors and policy provided in the National Policy Statement for Electricity Networks (EN-5). The presence of numerous sites designated under the Wildlife and Countryside Act as SSSIs (including the Tickenham, Nailsea and Kenn Moors SSSI) was an important consideration in this Section. The COR concluded that the benefits from the use of underground cables as an alternative to an overhead line would not clearly outweigh any extra economic, social and environmental impacts. As a result undergrounding would not be justified and therefore National Grid was unable to accommodate this suggestion within its proposals.

No

National Grid should utilise GIL for the connection in Section D.

The ability to use underground cables and GIL to facilitate the delivery of power from Hinkley Point C was considered within the further Strategic Options Report produced in August 2011 in support of the Stage 3 consultation.

The report explains that underground cables and GIL were not preferred for this scheme as their higher capital and lifetime costs, compared to the

No


756


alternatives, could not be justified. In the section of the route which will be undergrounded XLPE cable is preferred to GIL due to its lower cost.

Consultation

Local biodiversity data collected by National Grid should be published

As part of its statutory consultation National Grid published its PEIR which contained all of the baseline data collated by National Grid during the development of the project. Further baseline data is also presented in Volume 5.8, Chapter 8 of the ES that accompanies the DCO application.

N/A

National Grid have paid insufficient attention to local opinion regarding alternative methods of transmission

National Grid appreciates that the proposed Hinkley Point Connection is of interest to many communities along its route. As a Nationally Significant Infrastructure Project, National Grid followed the requirements for pre-application consultation set out in the Planning Act 2008, and sought the views and participation of local communities and others with an interest in the proposals at each stage in the decision making process.

Since 2009, National Grid consulted with the public and stakeholders at key stages including consideration of the connection options, route corridor options, proposals for reconnecting the local electricity network in North Somerset and the draft route. National Grid believes that local communities should have a strong voice in the decision making process relating to infrastructure they host, and worked with local authorities, parish councils, elected representatives and the local media to help explain what can be influenced, encourage participation and feedback, and explain where local opinion has influenced decisions. Early consultation showed a preference for a route corridor which required the removal of an existing 132kV overhead line, reducing the overall scale of change in the landscape (albeit with a general preference for a completely underground or subsea route which could not be accommodated for reasons that National Grid was a pains to explain clearly). Concern about the visual effects of traditional 400kV steel lattice pylons were recognised, and the award winning T-pylon was developed and brought forward for consultation, whilst the draft route included over 8km of underground cable through the Mendip Hills AONB. Further undergrounding and removal of existing 132kV, and the alignment of the proposed new connection further from property in the Nailsea again recognises specific issues raised by the public, adding to the list of examples where National Grid is pleased to have been able to

N/A


757


respond to the concerns and ideas provided by the community.

The consultation documents are confusing as information on the T-pylon and the height of pylons is inaccurate

Project News and the Public Consultation Overview Report are part of the series of regular public information updates published by National Grid during consultation on the proposals since 2009. In the September 2013 edition of the Project News and the Overview Report an illustration was provided to indicate the difference in height between the traditional 400kV steel lattice pylons (approximately 46.5m high) and the T-pylon (approximately 34.5m high). The Pylon Design Options Report which was also published to accompany the statutory Stage 4 Consultation included detailed information on each of the pylon types and a plan illustrating the differences in size and height between the 400kV steel lattice pylon, the 400kV low height steel lattice pylon, the T-pylon and the existing 132kV steel lattice pylons. This plan was also available in the Q&A section of the project website. National Grid also developed a 3D computer model which was available to view at the public Information Hubs at Avonmouth, Nailsea and Bridgwater and at well-advertised public events along the proposed route.

No

Cost

The cost of an underground connection would be substantially lower than originally stated

National Grid supported the production by the IET of an independent transmission cost study. National Grid’s cost estimates compare favourably with this report as shown below:

The IET Report, which was based on 2011 prices, sets out that for a 75km medium rated overhead line is £1.6m per km and for a 15km medium rated direct buried cable is £17.53m per km. These cost estimates are broadly similar to those used by National Grid.

No

Costs borne by the community have not been taken into account

Cost benefit analysis (CBA) is defined on page 4 of HM Treasury’s Green Book as "analysis which quantifies in monetary terms as many of the costs and benefits of a proposal as feasible, including items for which the market does not provide a satisfactory measure of economic value."

National Grid does not consider that effects on the environment from its proposals can be properly given a monetary value. Decisions on the balance to be struck between National Grid's statutory and licence duties are matters of judgement for itself and ultimately the Secretary of State in determining whether development consent should be granted for any proposal that is brought forward. This is

No


758


consistent with other planning judgements that are made in determining applications for planning permission or consents under other legislation.

Detailed cost information has been made available and presented within a number of project documents. The SOR includes detailed costs of overhead lines, underground cables, GIL and HVDC technology. The COR also include cost information for overhead lines and underground cables. Similarly the Pylon Design Options Report included cost information for lattice and T-pylons.

Environment

Concerned about the effects on wildlife (particularly otters)

The effects on ecological habitats and species were an important consideration in the development and refinement of National Grid’s proposals. Wherever possible the Proposed Development avoids sites valued for their ecological importance. Where this was not possible mitigation measures will be implemented during construction to ensure effects on habitats and species are minimised. A full assessment of the impacts of the Proposed Development on Ecology is presented in Volume 5.8, Chapter 8 of the ES that accompanies National Grid’s DCO application.

N/A

Concerned about the effects on the environment in the area of Yatton and Congresbury due to construction works to install the new line and remove the old line.

When planning the proposed construction associated with both the installation of the new overhead line and the removal of the existing WPD 132kV overhead line, National Grid gave careful consideration to the potential for adverse effects on the environment. Where required National Grid will employ wildlife friendly working practices and will seek to minimise effects on the environment through careful phasing of its construction activities. As part of the development of the proposals National Grid has liaised closely with a range of organisations responsible for the protection of the environment and has wherever possible incorporated their advice into the Construction Environmental Management Plan.

No

Concerned about the impact of undergrounding through SSSIs in North Somerset

The only section of undergrounding proposed in North Somerset in the vicinity of the numerous SSSIs is the undergrounding of the 132kV W Route in the vicinity of Nailsea. The route of these underground cables was carefully selected to ensure that the amount of SSSI crossed by the connection was minimised as far as possible, to ensure that effects on the integrity of the SSSI could be avoided. Due to the presence of residential development on the edge of Nailsea it was not possible to completely avoid the SSSI and

No


759


as a result a short section crosses the designation on route to Tickenham Ridge. To ensure effects on this area of designation are minimised as far as possible National Grid and WPD are proposing to use HDD techniques to avoid the open cutting of the SSSI. Further information on the effects of the underground cables are presented in Volume 5.8, Chapter 8 of the ES that accompanies the DCO application.

Concerns about the visibility of the new powerlines from Cadbury Camp and the Tickenham Ridge as the assessment does not currently seem to place much weight on views from Cadbury Camp. It is requested that the route is moved closer to the existing pylon route.

The route across Tickenham Ridge was designed to cross the ridge obliquely to minimise the amount of pylons visible against the sky on the top of the ridge and avoid residential properties and areas of woodland and ancient woodland as far as possible. In response to the representation received, National Grid back checked and reviewed its previous decisions in this area but concluded that the route identified offers the optimal solution in this area as it avoids effects on a government pipeline, minimises the amount of woodland loss, maximises the distance to residential properties and avoids effects on a site of archaeological importance and Noah’s Ark Zoo farm.

No

National Grid should utilise markers/bird diverters etc to help birds avoid the overhead line near the wildlife reserve at Moorend Spout

Whilst National Grid is proposing to utilise bird diverters at several locations along the length of the connection there are no proposals to fit bird diverters in the vicinity of Moorend Spout.

No

The T-pylon design may have negative landscape effects in comparison with traditional pylon designs

As part of the development of the proposed application, National Grid undertook an appraisal to consider the use of a new pylon design, the T-pylon, as an alternative to the traditional steel lattice design for the overhead line sections of the connection. This appraisal was documented in the ‘Pylon Design Options Report’ and demonstrates how statutory duties, policy considerations and environmental issues were considered and makes recommendations for a pylon design that National Grid should take forward to consultation for the Hinkley Point C Connection Project. This appraisal concluded in Section D that whilst wider than the traditional steel lattice design, due to its lower height the T-pylon offers advantages over the steel lattice pylons in this area.

No

Concerned about the potential impacts of the undergrounding of the 132kV line around Nailsea on the peat soils in the area.

During construction National Grid will employ a range of working practices and implement appropriate mitigation to ensure that soils and land drainage are not adversely impacted. Further information on the construction methods and mitigation proposed is presented in the CEMP which forms Volume 5.26 of the ES which

No


760


accompanies the DCO application.

Concerns about the effects of the 400kV overhead line on Kenn, Tickenham and Nailsea Moors Sites of Special Scientific Interest (SSSI)

The presence and reasons for designation of the Tickenham, Nailsea and Kenn Moors SSSI were recognised at the outset of the project and routes were selected which sought to minimise the effects on this site as far as possible. The selection of an overhead line and the careful siting of the pylons to avoid the ditches which comprise the designation helped to further reduce effects on this site. Where accesses, culverts or bridges are required within or in close proximity to the SSSI these have been designed to minimise effects and have been discussed and agreed with a range of organisations including North Somerset Council and Natural England.

Further information on the effects on the SSSI are presented in Volume 5.8, Chapter 8 of the ES that accompanies the DCO application.

No

The Environment Agency should be consulted about how the rivers should be traversed. Land Yeo, Middle Yeo and Tickenham Boundary Rhyne all carry considerable water alongside the larger drains and all are intersected by the 132kV undergrounding

This comment was noted and National Grid will continue to work closely with the EA during the construction and operational phases of the development

N/A

Mitigation

Permanent harm to habitats should be offset by habitat creation or improvement /enhancement of habitat elsewhere

The Ecological Mitigation Strategy was discussed with a number of consultees as part of the development of the application and suggests a range of measures to compensate for any permanent loss of habitat resulting from the Proposed Development.

N/A

The substation at Sandford would offer opportunities for habitat improvement /enhancement

This representation was noted. National Grid can confirm that a range of native species will planted as part of the landscaping scheme around the proposed Sandford Substation. These will be managed by National Grid as part of a programme of long term maintenance.

Yes

Further opportunities for path improvement/enhancement of footpaths should be considered such as a new bridge within the Biddle Street SSSI.

Whilst National Grid is not proposing to construct a bridge within the Biddle Street SSSI, a PRoW Management Strategy has been produced and is presented at Volume 5.26, Appendix 5.

No


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An environmental fund should be created for community organisations.

National Grid welcomes the suggestion for wider consideration of environmental enhancement. We are committed to consider such works as part of our Stakeholder, Community and Amenity Policy. As such a fund is not necessary to secure the grant of consent, National Grid would welcome discussions with relevant organisations and individuals to explore these opportunities further following the grant of consent.

No

The pylons should be painted in muted colours to minimise effects

Within its DCO application National Grid has specified appropriate colour finishes which could be used for the proposed pylons.

No

Routeing and Design

Consideration should be given to using the T-pylons more extensively

As part of the development of the proposed application, National Grid undertook an appraisal to consider the use of a new pylon design, the T-pylon, as an alternative to the traditional steel lattice design for the overhead line sections of the connection. This appraisal is documented in the ‘Pylon Design Options Report’ and demonstrates how statutory duties, policy considerations and environmental issues have been considered and makes recommendations for a pylon design that National Grid should take forward to consultation for the Hinkley Point C Connection Project. This appraisal concluded whilst the T-pylon is lower in height and offered advantages in certain sections of the route over the steel lattice pylons, it was more prominent when viewed at close proximity due to its solid central column and cross beam. In response to representations received during the consultation National Grid back checked and reviewed its proposals and due to the marginality of its original preference and the strong support for the T-pylon expressed National Grid is proposing to utilise the T-pylon in Section A. The only other section where steel lattice pylons were proposed was in Avonmouth where National Grid is satisfied that its original selection remains valid and is therefore not proposing to utilise T-pylons in this section.

Yes

The size and solid central column of the T-pylon make this design an inappropriate choice as a form of landscape mitigation

As part of the development of the proposed application, National Grid undertook an appraisal to consider the use of a new pylon design, the T-pylon, as an alternative to the traditional steel lattice design for the overhead line sections of the connection. This appraisal was documented in the ‘Pylon Design Options Report’ and demonstrates how statutory duties, policy considerations and environmental issues were considered and makes recommendations for a pylon design that National

No


762


Grid should take forward to consultation for the Hinkley Point C Connection Project. This appraisal concluded in Section D that whilst wider than the traditional steel lattice design, due to its lower height the T-pylon offers advantages over the steel lattice pylons in this area.

The proposals to remove and underground the two existing 132kV overhead lines in Section D which currently run in close proximity to a number of residential areas are welcomed.

National Grid noted this comment. N/A

Socio-economics

Concerned about the effects on property prices in Section D

In accordance with the Holford Rules the Proposed Development has been designed to avoid residential areas and individual properties as far as possible. Whilst socio-economic factors have been taken into account in the development and refinement of the proposals, the effect on the value of private individual properties has not been a factor in the decision making process. The effect on house prices of an overhead transmission line is not a matter that requires assessment under the EIA Regulations. PINS have not required such effects to be assessed in the scoping opinion adopted for this project or adopted in relation to other nationally significant infrastructure projects. The effect on house prices as a result of this development, as with all types of development, is not material to the planning merits of the proposal.

Compensation arrangements are set out in legislation. The relevant legislation provides that those whose property will have National Grid equipment sited on or across it (e.g. if the conductors/wires oversail a landholding) are entitled to compensation under property law. National Grid works closely with any landowners on whose land our equipment is sited to negotiate compensation terms if this is appropriate. Any party who feels that they may have a claim for compensation, is recommended to seek professional advice and /or contact National Grid who will be happy to discuss their individual situation

N/A

Concerned about the effects on tourism in Section D

As part of the development of the scheme, modifications to the route and design were considered which reduced socio-economic and land use effects on certain receptors. This resulted in a design which inherently reduces likely socio-

No


763


economic and land use effects. In addition to design modifications, a number of mitigation measures will be considered during construction to reduce impacts on socio-economic receptors. These include:

Seeking to minimise effects to businesses and land uses through the provision of alternative accesses and facilities (e.g. parking) if required;

Seeking to programme construction activities that have the greatest effect on amenity in order to minimise effects on traffic peaks and local communities.

Look for opportunities to maximise the procurement of materials and employees from within the South West and encourage employment of a local workforce;

Seeking to minimise the extent to which usage of PRoW/recreational routes are disrupted; and

Implementing a plan for improving the condition of certain footpaths.


14.4.18 The main issues raised by wider consultees in relation to Section E – Tickenham Ridge are set out in Table 14.13 below together with National Grid’s response to these issues and whether the representation resulted in a change to the proposals.

Table 14.13 Issues Relating to Section E


Consultation

The information presented contained a lack of detail as well as inaccurate information and omissions in relation to Section E.

Under the Planning Act 2008, promoters of NSIPs have a duty to consult on their proposed application. In doing so they must bring forward preliminary environmental information of sufficient detail to allow consultees to understand the likely significant impacts and do so at a stage where the proposals can be influenced. Comments and concerns raised during the statutory Stage 4 Consultation were taken into account in the finalisation of the detailed design. However, National Grid did not limit dialogue on these issues to the statutory consultation and has liaised extensively with local authorities and key

N/A


764


stakeholders since 2011. Any gaps or inaccuracies in the information presented in the consultation materials were addressed and remedied in the respective chapters of the ES that accompanies the DCO application.

Environment

Off-site planting is required in the Forest of Avon Community Forest between the Mendip Hills AONB boundary and Seabank.

Details of National Grid’s offside planting proposals are presented within the OSPES (Volume 5.25) which accompanies the DCO application. The OSPES sets out volumes of offsite planting considered appropriate by National Grid and to be implemented by the local authorities but does not prescribe geographical locations for this planting.

Yes

Routeing and Design

Underground cables should be implemented across Tickenham Ridge

The COR which was published as part of the Stage 3 Draft Route consultation assessed overhead line and underground cable options within Study Area E (Tickenham Ridge) against a range of various factors and policy provided in the National Policy Statement for Electricity Networks (EN-5). In this area the COR concluded that the benefits from the use of underground cables as an alternative to an overhead line would not clearly outweigh any extra economic, social and environmental impacts. As a result undergrounding would not be justified within Study Area E and therefore National Grid was unable to accommodate this suggestion within its proposals. However it should be noted that both existing 132kV overhead lines that cross Tickenham Ridge will be removed as part of the proposals. This will have the effect of replacing two existing overhead lines with one 400kV connection.

No

The route should be moved closer to the existing pylon route on Tickenham Ridge

The route across Tickenham Ridge was designed to cross the ridge obliquely to minimise the amount of pylons visible against the sky on the top of the ridge and avoid residential properties and areas of woodland and ancient woodland as far as possible. In response to the representation received, National Grid back checked and reviewed its previous decisions in this area but concluded that the route identified offers the optimal solution in this area as it avoids effects on a government pipeline, minimises the amount of woodland loss, maximises the distance to residential properties and avoids effects on a site of archaeological importance and Noah’s Ark Zoo farm.

No


765

Section F: Portishead

14.4.19 The main issues raised by wider consultees in relation to Section F – Portishead are set out in Table 14.14 below together with National Grid’s response to these issues and whether the representation resulted in a change to the proposals.

Table 14.14 Issues Relating to Section F


Environment

National Grid’s findings appear to be inaccurate regarding Portbury Wharf.

At the time of the publication of the PEIR some protected species information in relation to Portbury Wharf was incomplete. These surveys were subsequently completed and are addressed in Volume 5.8, Chapter 8 of the ES that accompanies the DCO application.

N/A

Concerned about the effects on five Sites of Nature Conservation Interest (SNCIs) along the M5 which may result in loss of habitat and potentially affect bird species and water voles that use the sites

None of the SNCIs along the M5 crossed by Option A are specifically noted for bird species and only one of the sites has water vole recorded within it. The methods outlined in the Biodiversity Mitigation Strategy detail the approaches during the construction phase that will be taken to minimise effects on protected and priority species including water vole and breeding birds. National Grid will also seek to reinstate any habitats lost during the construction phase. Where this is not possible (for example due to the permanent footprint of the pylon or the need to clear trees to maintain electrical safety clearances) National Grid will offset these permanent habitat losses through habitat creation elsewhere.

No

Option B will cause a potential new obstruction for birds using the Estuary and Reserve and then flying down to the Gordano Valley.

This representation is noted and the potential collision risk of the overhead line is considered in Volume 5.8, Chapter 8 of the ES that accompanies the DCO application.

N/A

Concerned with the potential impacts of the 132kV undergrounding on the Reserve. 132kV overhead cables rather than undergrounding technology should be used through this area. If National Grid is minded to go ahead with undergrounding through Portbury Wharf, why different routes have not been explored outside the Reserve boundary (e.g.

National Grid recognises that the installation of underground cables can result in temporary effects on habitats and wildlife. As a result, National Grid proposing to utilise HDD techniques through the Portbury Wharf Nature Reserve to minimise effects and avoid the required for open cut trench techniques. It is also proposing to schedule its works to avoid the most sensitive wintering bird season.

In response to this representation National Grid back checked and reviewed its previous decisions. Having back-checked and reviewed it previous decisions National Grid is satisfied that undergrounding in this area is the correct option

No


766


Port Fields).

and is therefore not able to accommodate this change in the DCO.

As part of the identification of technically feasible routes for the 132kV W Route underground cables, National Grid sought to identify routes which avoided the Portbury Wharf Nature Reserve. However, potential routes in this area were constrained by the presence of a strategic flood defence bund and other utilities within the roads of the Portbury Ashland’s residential development. As a result any underground connection had to travel through a short section of the reserve to achieve a connection into Portishead Substation.

Concerned about the effects of drainage improvement works associated with the 132kV underground cables on the wetland habitat that exists in the fields affected at Portbury Wharf

Whilst undergrounding would have environmental effects these would only be temporary as they would last for the duration of construction activities only. Prior to construction commencing, a full survey of existing drains would be undertaken and a pre-construction and post construction drainage mitigation plan would be developed and agreed with the relevant stakeholders.

No

Concerns regarding the impacts of Option A in the Portbury area and the setting of the Listed church

As part of the identification and assessment of options in Section F, National Grid considered the potential for adverse effects to arise on a rage of designated and undesignated historic environment assets (including the Grade I Listed Portbury Church). The effects on this receptor were considered to be moderate adverse if steel lattice pylons were used however through the adoption of the T-pylon these effects have been reduced to minor adverse. Further information is presented in Volume 5.11, Chapter 11 of the ES that accompanies the DCO.

As part of the development of the proposals National Grid also undertook a range of surveys to develop an understanding of the use of the study area for bat roosting and foraging. The findings of these surveys were taken into consideration in the identification and assessment of potential routes and in this area did not materially affect our choice of option.

No

Mitigation

An Ecological Clerk of Works should be used during the construction phase, particularly at sensitive sites such as Portbury Wharf Nature Reserve

National Grid can confirm that an ecological clerk of works will be employed during construction.

N/A


767


14.4.20 No responses received from wider consultees commented specifically on Section G – Avonmouth during this period of consultation.

Section H: Hinkley Line Entries

14.4.21 No responses received from wider consultees commented specifically on Section H – Hinkley Line Entries during this period of consultation.

14.5 Conclusion and Summary of Influence on the Project

14.5.1 National Grid’s statutory Stage 4 consultation with wider consultees was

undertaken in accordance with National Grid’s statutory SoCC and Consultation Strategy which were developed in accordance with DCLG Guidance and the requirements of the Planning Act 2008 (as amended by the Localism Act 2011). As a result of the multi-staged consultation undertaken on the project, wider consultees had multiple opportunities to provide feedback and inform the development of the scheme. As the design of the Proposed Development evolved, opportunities for significant changes to the proposals inevitably reduced.

14.5.2 The representations raised during the statutory Stage 4 consultation were considered in detail by the project team in the refinement of the proposals and the formulation of the application. This section summarises the changes that were made to the Proposed Development as a result of representations received from wider consultees during the consultation.


14.5.3 Suggestions were received which asked National Grid to consider using the T-pylon instead of traditional steel lattice pylons in Section A. Due to the marginality of National Grid’s original preference for lattice pylons in this area and the strong support for the T-pylon expressed in the representations from both members of the community and statutory consultees National Grid is proposing to include this change within its DCO.

Section B: Somerset Levels and Moors South

14.5.4 A representation was received that indicated that several elderly residents in the settlement of Biddisham did not have access to the internet or consultation events. In response to this representation National Grid undertook an additional date on the consultation vehicle programme at Tanyard Farm Nurseries, Turnpike Rd, Axbridge, BS26 2JG on Saturday 12 October 2013. National Grid was pleased to provide this additional opportunity for the local community to engage in the consultation.

Section C: Mendip Hills AONB

14.5.5 No changes were made to the Proposed Development in Section C as a result of representations from wider consultees.


768


14.5.6 No changes were made to the Proposed Development in Section D as a result of representations from wider consultees.


14.5.7 A suggestion was received which suggested that off-site planting should be implemented across the Forest of Avon Community Forest area. In response to this representation and representations from the local authorities National Grid developed an OSPES (see Volume 5.25). The OSPES sets out volumes of offsite planting considered appropriate by National Grid and to be implemented by the local authorities but does not prescribe geographical locations for this planting.

Section F: Portishead

14.5.8 Comments were received which suggested that National Grid should seek to minimise effects on the Portbury Wharf Nature Reserve from the installation of the 132kV underground cables. To ensure effects on the Nature Reserve are minimised, National Grid is proposing to only undertake works in the Nature Reserve between the months of April and September and it is also proposing to use horizontal directional drilling techniques to install the cables to avoid the requirement to open cut trenches through the Nature Reserve.


14.5.9 No changes were made to the Proposed Development in Section G as a result of representations from wider consultees.

Section H: Hinkley Point Line Entries Study Area

14.5.10 No changes were made to the Proposed Development in Section H as a result of representations from wider consultees.

Aspects of the Proposals which remained unchanged

14.5.11 As a result of the representations received from wider consultees during the Stage 4 consultation, a number of changes were made to the proposals; however certain key aspects of the proposals remained unaltered.

In representations received during the consultation there was significant support for the adoption of a route using either sub-sea cables, underground cables or GIL. National Grid back checked and reviewed its proposals in response to these representations but concluded that no new information had come to light that would change the assessments presented in the SOR.

In addition to total undergrounding of the connection, there was also support for localised undergrounding of the connection or the greater use of underground cables. In response to these representations, National Grid back checked and reviewed its proposals in the context of the NPS EN-5 but concluded that no new information had come to light that would change the assessments presented in the COR.


769

There was also support for minor alterations to the route or the locations of temporary construction facilitates. In response to the representations received, National Grid reviewed its proposals but concluded that the alternatives suggested would either not be technically feasible or would result in greater effects than the proposed and as a result these changes were not included in the DCO.


770


771

15 LOCALISED CONSULTATION ON CHANGES TO THE ROUTE AT SOUTHWICK

15.1 Introduction to this Stage of Consultation

15.1.1 As part of the statutory Stage 4 consultation, National Grid received numerous representations which proposed changes to the Proposed Development. Each of the changes suggested was considered and appraised against technical, planning and environmental criteria to determine whether they would result in localised benefits and a change in scheme design. The vast majority of the changes put forward were minor and within the order limits indicated during the statutory Stage 4 consultation. However, in the Southwick area of Somerset a number of

representations were received which suggested a larger change to the route of the overhead line that would take it to the east of the settlement. National Grid assessed the suggested change and concluded that the revised route would result in localised benefits and would therefore be preferred over the route consulted on during the statutory Stage 4 consultation.

15.1.2 In line with paragraph 9.1.4 of its published statutory SoCC, National Grid deemed that the change in preferred route at Southwick was sufficient to require further geographically targeted consultation undertaken in accordance with the principles and methods set out in the statutory SoCC. This consultation on the change to the route (the Revised Route Consultation) would form an extension to National Grid’s statutory Stage 4 consultation undertaken pursuant to sections 42, 47 and 48 of the Planning Act 2008. A copy of the SoCC commitments and the actions required for the Revised Route Consultation can be found at Appendix 9.

15.1.3 The Revised Route Consultation took place from Monday 10 February to Monday 10 March 2014, a period of 28 days. This was in line with the minimum period for consultation outlined by Section 45 of the Planning Act 2008. Prior to the start of consultation, National Grid notified the Secretary of State of the proposed application under Section 46 of the Planning Act 2008 by letter dated 7 February 2014 to the Planning Inspectorate. This can be found at Appendix 51.

15.1.4 The consultation invited the views on a change to the route of the overhead line from pylon C-LD10 in the south (located to the north of the River Brue) to pylon C-LD20 to the north (located to the north of Northwick Road). The revised route would be further east than the route proposed as part of the statutory Stage 4 consultation and involved changing the proposed location of nine pylons.

15.1.5 This section summarises the consultation methods used, the representations received during this period of consultation and National Grid’s responses to these representations.

15.2 Consultation Zones

15.2.1 To ensure consistency with the Consultation Zones used in previous stages of pre-application consultation, the Revised Route Consultation Zone encompassed all addresses within 1km of the redline boundary. The points where the revised route and the previously consulted route diverge were used to identify the northerly and southerly extents to the Zone. A map showing the Revised Route Consultation Zone can be found at Appendix 52.


772

15.3 Summary of Consultation Activities Undertaken

15.3.1 As part of the consultation, National Grid made consultation material and technical documents available to the public and statutory consultees. These documents explained what National Grid proposed to build and where, and the decisions that had been made in developing the revised route. The documentation made available was as follows:

Consultation leaflet - plain English leaflet produced to explain the proposals;

Feedback form (online and paper copy);

Southwick Revised Route Consultation Preliminary Environmental Information Report (PEIR);

Southwick Revised Route Consultation Plans;

Southwick Revised Route Consultation Options Appraisal Report; and

A DVD containing all the revised route consultation documents.

15.3.2 National Grid met with representatives of Sedgemoor District Council on Tuesday 14 January to advise them of the intention to undertake additional local consultation, and outline the proposed consultation activities. At the meeting the principle for the timetable for the consultation (28 days) and extent of the Revised Route Consultation Zone were agreed.

15.3.3 Further liaison with Sedgemoor District Council officers and Somerset County Council officers took place on 24 January 2014 and additional correspondence advising of the detailed timetable for consultation activities on was sent to officers on Monday 27 January. Copies of this correspondence can be found at Appendix 53.

Prescribed Consultees

15.3.4 In line with the statutory SoCC, National Grid consulted from all parties recognised within Sections 42, 43 and 44 of the Planning Act as part of the Revised Route Consultation. For consistency and to ensure compliance with the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009 the list of prescribed consultees consulted was the same as that used for the statutory Stage 4 consultation in September and October 2014 (see Appendix 18). This list includes key prescribed consultees, such as the Environment Agency, Natural England and English Heritage, as well as all affected and adjacent local authorities and parish councils. The directly affected local authorities are listed below and a map of the affected and adjacent parish councils can be found at Appendix 54:

Sedgemoor District Council; and

Somerset County Council.


773

Parish Councils

15.3.5 In order to ensure affected and adjacent parish council members were aware of the Revised Route Consultation, and the proposed consultation activities, National Grid set up a parish cluster meeting on Tuesday 4 February 2014. Representatives from the affected and adjacent parish councils were invited to attend the meeting, along with relevant local authority members. Copies of the invitations sent can be found at Appendix 55. In addition, posters advertising the consultation events were sent to the parish clerks of directly affected and adjacent to the Revised Route Consultation Zone (see Appendix 72).

15.3.6 A copy of the presentation for the meeting can also be found at Appendix 56,

along with the registration sheet. Meeting details are provided in Table 15.1 below:

Table 15.1 Parish Cluster Meetings

Date Time Location

Tuesday 4 February 2014

19:00 to 21:00

East Huntspill Church Hall, Church Lane, East Huntspill, Highbridge, Somerset, TA9 3PQ

Local Authorities

15.3.7 National Grid engaged with officers at the directly affected authorities (Sedgemoor District Council and Somerset County Council) in order to ensure their members were made aware, and suitably briefed, on the Revised Route Consultation. A briefing note was agreed with officers at Sedgemoor District Council, and this was issued by officers to the relevant members. In addition, members were also invited to attend the parish cluster meeting held on the 4 February. The briefing note and list of members invited to the parish cluster meeting can be found at Appendix 55.

PILs

15.3.8 National Grid and its land agents, directly engaged with PILs during the consultation period via correspondence and face-to-face meetings, in order to make them aware of the Revised Route Consultation and ensure that they understood their rights and role in the ongoing process.

15.3.9 Letters and consultee packs containing the following documentation were sent to PILs affected by the revised route on the 7 February 2014. A list of PILs sent letters and packs, along with the different letters that were sent can be found at Appendix 57.

Consultation leaflet.

Feedback Form.

Freepost envelope.

Document CD (containing the project consultation documents including the Southwick Revised Route Consultation PEIR, Southwick Revised Route


774

Consultation Options Appraisal Report and Southwick Consultation Plans)

Notice of the consultation which was published in local newspapers.

Consultation with the Local Community

Members of the Public and Local Businesses

15.3.10 In line with the SoCC and section 47 of the Planning Act 2008, National Grid consulted people living or working in the vicinity of the revised route. Given the geographical scale of the revised route it was important to ensure that any communication with local communities was both targeted and effective. Therefore, to ensure proportionality in terms of scale, National Grid developed a Revised

Route Consultation Zone.

15.3.11 To ensure consistency with previous consultation zones, including the review undertaken ahead of the consultation in September and October 2013, the extent of the Revised Route Consultation Zone encompassed all addresses within 1km of the redline boundary. The points where the revised route and the previously consulted route diverge were used to identify the northerly and southerly extents to the Zone. A map showing the Revised Route Consultation Zone can be found at Appendix 52.

Wider Consultees

15.3.12 National Grid also consulted a number of non-prescribed consultees as part of the Revised Route Consultation. These consultees had either been previously engaged by National Grid on the project, responded to previous pre-statutory consultations, or had requested to be included as a consultee during the course of the project. The list of consultees was the same as that used as for the statutory Stage 4 consultation, and can be found at Appendix 18.

15.3.13 To raise awareness of the consultation, emails were sent to wider consultees at the beginning of the consultation period providing an overview of the revised route. Examples of the correspondence can be found at Appendix 58.

15.3.14 A letter and pack of consultation documents including the consultation leaflet, DVD, Feedback Form and Freepost envelope were delivered to the Planning Inspectorate on Friday 7 February 2014. A copy of the letter and a delivery receipt can be found at Appendix 51.

MP briefings

15.3.15 National Grid contacted, and met with Tessa Munt MP on Wednesday 5 February to brief her on the Revised Route Consultation. An email advising of the consultation was also issued to Ms Munt at the start of the consultation, and she attended the drop-in session at Mark Village Hall on 15 February 2014.


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Methods of Consultation

Consultation leaflet mailing

15.3.16 Awareness of the consultation was raised through a consultation leaflet which informed people about the project and provided:

Details of why National Grid was undertaking additional, local consultation on the revised route;

A map showing the revised route in comparison to the route previously consulted on during the statutory Stage 4 consultation;

Information on how further information could be accessed;

Information on a consultation drop in session; and

Details of how people could provide feedback.

15.3.17 A copy of the Consultation leaflet can be found at Appendix 59.

15.3.18 The Consultation leaflet was posted first class to 682 addresses within the Consultation Zone on Friday 7 February 2014. The residential and business addresses were taken from the most up-to-date version of the Post Office’s address database.

Media

15.3.19 National Grid prepared a press statement, which was issued to local media on request. A copy of the statement was also posted on the project website. The statement can be found at Appendix 60, along with a sample of press coverage that was generated for the Revised Route Consultation.

Project website and social media

15.3.20 Information about the consultation was promoted through the project website –

www.hinkleyconnection.co.uk. The website was updated for the consultation and went live at 09.30 on Monday 10 February 2014. The website included:

A full set of consultation documents (where necessary, files were reduced in size to enable those with slow internet connections to download documents more easily);

An interactive Google map focused on the revised route, including the ability to zoom to specific postcodes;

An online version of the feedback form to enable people to submit their feedback electronically.

15.3.21 Screenshots of the updated project website can be found at Appendix 61. Website statistics are set out in Table 15.2.

http://www.hinkleyconnection.co.uk/


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Table 15.2 Website Statistics

.

15.3.22 Prior to the start of the consultation people had the opportunity to register on the project website to receive email updates. This database included 1,151 people. An email about the revised route consultation was sent to these people on 10

February 2014. A sample email can be found at Appendix 62.

15.3.23 Information about the Revised Route Consultation was also promoted through the project Twitter account (@NG_Hinkley) and Facebook page (Hinkley Point C Connection Project) at the start and end of the consultation period. Copies of the tweets and Facebook posts can be found at Appendix 63. Statistics for social media can be found in Table 15.3.

Table 15.3 Social media statistics

Social media statistics – Source – Twitter and Facebook

Number of Tweets during consultation (including retweets)

2

Number of followers pre-consultation period 328

Number of additional followers gained during consultation

10

Number of Facebook posts during consultation 2

Consultee packs

15.3.24 A pack of consultation material was sent to the prescribed consultees, PILs and non-prescribed consultees on Friday 7 February 2014 by First Class post. The pack included the following documents:

Consultation leaflet (see Appendix 59);

Document DVD including the consultation documents and plans detailed at paragraph 15.3.1;

Feedback Form (See Appendix 64);

FREEPOST Envelope; and

Notice publicising further consultation on the proposed project.

15.3.25 A photo of the documents pack can be found at Appendix 65, along with the relevant statutory consultee letters which accompanied the packs.

Website statistics - Source: Google Analytics

Total visits during consultation period 1,081

Total unique visitors during consultation period 774

Average duration of stay per visitor 4:26


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Statutory notices

15.3.26 In accordance with Section 48 of the Planning Act and the statutory SoCC, an advert providing details of the consultation was placed in local newspapers in the week prior to the start of the consultation. To ensure the adverts were relevant to the revised route consultation, the notices only appeared in newspapers which covered the geographical area of Southwick:

Bridgwater Mercury;

Mid Somerset Series (All Editions): Wells Journal, Shepton Mallet Journal, Cheddar Valley Gazette, Central Somerset Gazette;

Western Daily Press; and

Somerset County Gazette.

15.3.27 A copy of the notice can be found at Appendix 66.

Drop in session

15.3.28 National Grid held a drop in session during the consultation period where the communities in the Southwick area were able to find out more about the Revised Route Consultation, and talk to National Grid project team representatives. The drop in session was held on Saturday 15 February 2014 at Mark Village Hall, Vole Road, Mark, Somerset, TA9 4NY, from 10:00 to 16:00. The registration sheets indicate that 31 people attended the drop in session. Display material and registration sheets for the drop in session can be found at Appendix 67.

15.3.29 A full set of the technical documents and plans were made available for inspection at the drop in session. This included all plans at A1 size. The feedback form (including Freepost envelopes) and consultation leaflet were also made available for the public to take away.

15.3.30 An interactive computer model of the proposals was available for the public to view at the drop in session. Consultees were invited to provide information on the viewpoints or locations they would like to view in the model and members of the National Grid project team operated the model. A video of the model in the Southwick area was also available.

15.3.31 National Grid project team representatives from the disciplines of engineering, environment, planning and consents, EMFs and communications were available at the drop in session to answer queries from the public and help people to provide feedback:

15.3.32 Details of the drop in session were included in the consultation leaflet and on posters sent out to the directly affected and adjacent parish clerks at the beginning of the consultation.


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Question and answer sessions

15.3.33 No public Q&A’s were held during the consultation as anyone who had questions could attend the drop in session to speak to members of the project team, or contact the Community Relations Team to find out more about the consultation.

Information point

15.3.34 One unmanned information point was set up at Mark Village Hall on Monday 10 February 2014 to provide people with information on the revised route consultation. This comprised two display banners outlining the background to the Revised Route Consultation and a stand holding project literature.

15.3.35 The feedback form (including Freepost envelopes) and consultation leaflet were available to take away, and an inspection box containing all the technical documents and plans was available for people to view.

15.3.36 The information point was accessible when Mark Village Hall was open. The opening times were clearly advertised on the project website, and a poster at the Hall directed people to the project website, public drop in session, and local libraries to ensure people knew when and where information could be accessed when the venue was closed. Copies of the posters can be found at Appendix 68.

Information hub/mobile information point (also known as National Grid’s consultation vehicle)

15.3.37 As the information point at Mark Village Hall was located within the consultation zone, was well known in the local community and provided full disabled access, information hubs and mobile information points were not considered to provide any added value to this consultation.

Inspection boxes

15.3.38 National Grid provided inspection boxes to three local libraries (Bridgwater Library, Burnham-on-Sea Library and Highbridge Library) and the two directly affected

local authorities, so information could be made available to the public on request. The libraries were selected as being the most likely to be visited by people living or working in the Revised Route Consultation Zone.

15.3.39 The inspection boxes contained paper copies of the documents and A3 plans made available for the consultation. Each inspection box also contained feedback forms and Freepost envelopes so people could take them away and provide feedback. A letter accompanied the box to advise the venue about the contents, as well as a poster to advise how the public could access the box. A breakdown of recipients and contents of each box can be found at Appendix 69.

Community Forum

15.3.40 The statutory SoCC provided details of the Community Forum which had been set up as part of the Hinkley Point C Connection project. Given that the consultation needed to be targeted and effective, and that the Community Forum had evolved to deal with issues affecting the whole route, it was not considered appropriate to hold a Community Forum as part of the Revised Route Consultation.


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15.3.41 National Grid advised members of the Joint Relationship Group (see the statutory SoCC for details) of the Revised Route Consultation by email. A copy of the email can be found at Appendix 70.

Community relations team

15.3.42 Throughout the consultation National Grid’s community relations team were available to assist people in finding information about the project and the consultation. The Freephone number, 0800 377 7347 was open between 09:00 and 17:00 weekdays and all emails received through the project email address [email protected] and letters received through the Freepost address, FREEPOST H Point Connection, were responded to.

Approach to Hard to Reach Groups

15.3.43 The consultation included specific measures to ensure National Grid communicated effectively with hard to reach groups and provided an opportunity for them to have their say. These are outlined below:

Correspondence

15.3.44 Hard to reach group contacts were sent emails, letters, or contacted by phone to advise them of the Revised Route Consultation. The extent of these activities is detailed in the schedule at Appendix 71.

Plain English language

15.3.45 The consultation leaflet was written in clear and concise language to ensure people could understand what was being proposed and why consultation was taking place.

Access

15.3.46 A public drop in session took place at Mark Village Hall which was a publicly accessible venue and is Disability Discrimination Act compliant. The drop in session took place on a Saturday from 10:00 to 16:00 to ensure all people had an

opportunity to visit at times convenient to them.

Posters

15.3.47 Posters advertising the consultation, where to find further information and the drop in sessions were sent to the parish clerks of both directly affected and adjacent parish councils. A copy of the posters can be found at Appendix 71.

Media coverage

15.3.48 Articles about the Revised Route Consultation appeared in the local media before and during the consultation period. A sample of the press coverage can be found at Appendix 73.

Notices

15.3.49 Statutory notices were placed in local newspapers in the week prior to the consultation beginning. These advised people about the timescales for the



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consultation, where further information could be found, and provided details of the public drop in session.

Freephone number and Freepost address

15.3.50 A Freepost address and Freephone number were publicised and operated throughout the consultation period. The phone line was available between 09:00 and 17:00 during weekdays. The address and number were published in the consultation leaflet, on the feedback form, and on the project website.

Consultation leaflet mailing

15.3.51 The consultation leaflet was sent directly to people’s homes in the Revised Route Consultation Zone.

Social media

15.3.52 A small number of Tweets and Facebook posts were used at the start of the consultation to raise awareness of the consultation period. A copy of the tweets and Facebook posts can be found at Appendix 63.

Document availability

15.3.53 Paper copies of documents and information was available at local libraries, council offices and Mark Village Hall. A list of the documents available at each location can be found at Appendix 74.

Alternative languages and versions

15.3.54 No requests for the consultation leaflet in an alternative language were received during the consultation period. Braille versions were produced and available on request.

Language Line

15.3.55 The Language Line telephone service was available during the consultation period. This service connected a project team member with an interpreter immediately to allow them to communicate with a member of the public. Details of Language Line were provided in the contact us section of the project website. During the consultation the service wasn’t used.

Other meetings

15.3.56 National Grid attended the Sedgemoor Disability Forum on 27 February 2014. A member of the project team was available to answer questions and handed out the consultation leaflet and feedback forms. Approximately 40 people attended the event.

Consultation materials

15.3.57 Hard to reach contacts were sent an email at the start of the consultation, as well as a link to the project website to download all of the consultation materials. Copies of the email can be found at Appendix 71.


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15.4 Feedback Mechanisms

Feedback Form

15.4.1 A paper feedback form was made available to enable people to provide their feedback on the Revised Route Consultation. Specific questions guided people to the particular issues on which National Grid were seeking feedback. A copy of the hard copy feedback form can be found at Appendix 64.

15.4.2 An online version of the feedback form was also available on the project website for people to submit their feedback electronically. Screenshots of the online feedback form can be found at Appendix 75.

15.4.3 The number of feedback forms received as part of the consultation is set out in Table 15.4.

Table 15.4 Feedback Forms

Feedback Forms

Hardcopy feedback forms received 28

Electronic feedback forms received 16

Total 44

15.4.4 In addition to online and hard copy feedback forms consultees were able to provide feedback on the proposals by:

a) writing to the freepost address at Freepost H POINT CONNECTION;

b) sending an email to [email protected];

c) calling the freephone number 0800 377 7347; and

d) speaking to National Grid’s land agents.

15.4.5 A total of 55 emails, phone calls and letters were received as part of the consultation and 26 responses were received via National Grid’s land agents.

15.5 Responses received

15.5.1 In accordance with the DCLG Guidance on pre-application consultation, this section of the report provides a summary of the relevant representations received from all parties (including prescribed bodies) during the Revised Route Consultation. A summary of National Grid’s response to these and a description of how the proposals were influenced by these responses is presented in Section 15.8 of this document.

Prescribed Consultee Responses Received

15.5.2 A total of 84 responses were received from all parties recognised within Sections 42, 43 and 44 of the Planning Act during the Revised Route Consultation. Twenty eight of these were from organisations identified under Section 42(a) as



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prescribed consultees, four were received from one organisation identified under Section 42(b) of the Planning Act as a local authority and 51 responses were received from organisations and individuals identified under Section 42(d) of the Planning Act as PILs.

Town and Parish Councils

Badgworth Parish Council

15.5.3 Badgworth Parish Council expressed their preference for a sub-sea connection and noted that they have consistently stated this preference in previous submissions.

15.5.4 The Parish Council were critical of the consultation on the revised route, specifically with reference to the section that crosses Mark Causeway, arguing that the decision to move the line here contradicts views expressed in the previous stage of consultation. The Parish Council indicated support for a slight alteration to the revised route in order to minimise the visual impact of the line at Mark Causeway by Mark Parish Council. The suggestion involved moving Pylon LD18 closer to Court Farm.

15.5.5 The Parish Council expressed concerns about the visual impact of the line on the Somerset Levels and Moors and indicated that this in their view cannot be mitigated.

15.5.6 The Parish Council expressed their opposition to another specific part of the Draft Route, where it crosses the Somerset Levels and Moors. In addition to the visual impact of the line here, the Council also objected to the fact that it passes near a number of dwellings.

15.5.7 Badgworth Parish Council expressed opposition to the use of pylons more generally, questioning the reliability of this form of connection. They also urged again that further consideration be given to alternative transmission technologies including undergrounding.

15.5.8 Badgworth Parish Council reiterated their concern about the proximity of the line to properties. They expressed specific concern about the line being moved closer to Wainbridge Farm, a listed building, where it crosses Mark Causeway, as well as on the Somerset Levels and Moors.

Mark Parish Council

15.5.9 Mark Parish Council expressed their preference for a sub-sea connection and stated that this view is widely held within the parish, however they did acknowledge that the decision to revise the route has minimised impacts on the majority of Southwick.

15.5.10 The Parish Council was broadly supportive of the decision to consult on the revised route, acknowledging that the decision to propose an alternative route at Southwick is to the benefit of many residents.


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15.5.11 The Parish Council expressed mixed views on the proposal and noted that while many residents within the parish preferred the revised alignment in this area, there were a small number of previously unaffected landowners who objected to it.

15.5.12 The Parish Council requested a slight alteration to the revised route in order to minimise the visual impact of the line at Mark Causeway. The suggestion put forward involved moving Pylon LD18 nearer to Court Farm to make use of existing farm buildings for screening.

15.5.13 The Parish Council expressed opposition to the use of pylons more generally, questioning the reliability of this form of connection. They also urged again that further consideration be given to alternative transmission technologies including

undergrounding. In stating their opposition to an overhead connection, Mark Parish Council questioned the reliability of this form of electricity transmission, drawing attention to its potential vulnerability to extreme weather. Mark Parish Council mentioned severe storms with gale force winds in the area, noting this could become more common as a result of climate change. More generally, the Parish Council argued the proposals should be reconsidered in light of the need to maintain a secure, long-term electricity supply.

15.5.14 The Parish Council highlighted the proximity of the revised route to resident’s properties noting the objection of three previously unaffected landowners within the parish who will be impacted by pylons being placed on their land.

Other Prescribed Bodies

EDF Energy

15.5.15 Within their response EDF Energy reiterated the need for upgrading the transmission network in the South-West and providing connection for new generation projects like Hinkley Point C.

15.5.16 In relation to how the Proposed Development will interact with other infrastructure, EDF Energy underlined their commitment to working closely with National Grid in order to coordinate the planning and development of the proposed Hinkley Point C

Power Station alongside the proposed connection.

English Heritage

15.5.17 English Heritage commented that in relation to landscape they could not identify any significant impacts on designated historic assets associated with the revised route and as such had no further comment.

Environment Agency

15.5.18 The Environment Agency did not comment specifically on the revised route but submitted detailed comments on the Draft Horsey Levels Flood Risk Assessment, suggesting that the latest version was a marked improvement but added a number of specific comments relating to the wording and structure of the document.

15.5.19 The Environment Agency provided comments on the design of the proposed cable sealing end compound (CSE). They argued that detail of the proposed layout of the CSE compound was needed to consider flood risk mitigation. They also


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queried the 40 year design life envisaged for the CSE compound, given that generation at the proposed Hinkley Point C Power Station is predicted to continue for longer than this. It was suggested that provision be made for future changes in flood risk, including those resulting from climate change.

15.5.20 The Environment Agency commented on flood risk and drainage issues suggesting that greater detail should be provided on fluvial flood risk in the FRA. The Environment Agency also commented on surface water, noting that detail of drainage provision appears to have been omitted from the FRA.

15.5.21 The Environment Agency asked for clarity on a specific map provided in relation to flood risk assessment.

15.5.22 The Environment Agency made a number of comments on flood risk mitigation in the Horsey Levels, generally requesting clarification or further detail on what is proposed. For example a lack of provision for emergency access in case of flooding was identified, as well as details of ground levels and adaptive measures to cope with future change in flood risk. They also made some specific suggestions for improving this mitigation in relation to the design of the compound and a proposed perimeter bund.

Equality and Human Rights Commission

15.5.23 The Equality and Human Rights Commission reminded National Grid of their Public Sector Equality Duty under the Equality Act (2010) to identify and mitigate adverse impacts on any protected groups.

Natural England

15.5.24 Natural England noted the potential for protected species to be impacted. They requested that if protected species licences are required, all relevant information should be provided in relation to the revised route.

15.5.25 Natural England commented on ecological mitigation, expressing broad satisfaction with the measures proposed although noting that they may need more time for detailed consideration. They also discussed the need for newt and amphibian gully crossings and temporary bat fly-ways.

Natural Resources Wales

15.5.26 Natural Resources Wales requested to be kept informed about the project although they had no comments to make.

The Somerset Internal Drainage Board

15.5.27 The Somerset Internal Drainage Board Consortium underlined their interest in maintaining the watercourse network, noting that this involves ensuring access and controlling surface water.

Wessex Water

15.5.28 Commenting on the Draft DCO and protective provisions relating to water and sewerage undertakers, Wessex Water highlighted a number of relevant sections


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of the Water Industry Acts to be considered and referenced, suggesting changes to the wording and the addition of specific clauses.

15.5.29 In relation to compensation, Wessex Water set out the statutory provisions for compensation in the case of damage to facilities and interruption to service as well as the process for resolving disputes.

Local Authority Responses Received

15.5.30 Four representations were received during the consultation period from one local authority, Sedgemoor District Council.

15.5.31 Sedgemoor District Council welcomed the decision to consult on the revised route near Southwick, stating that this was consistent with their previous recommendation for focused, localised consultation at key ‘pinch-points’ along the route.

15.5.32 The Council commented positively on the consultation material, stating that it was clearly presented and that the technical information was adequate to enable comment. They commented more specifically on some of the photomontages used in the documentation in relation to the visual impact. It was argued that the photomontage showing the visual impact from a PRoW outside of Mark was not representative of the views from the village itself and suggested that photomontages for each option should be provided from the Causeway Road.

15.5.33 Sedgemoor District Council raised a number of points relating to the visual impact of the proposals, in particular reiterating their concern about the visual impact of the proposals near Mark Causeway. The Council felt that this negative effect had been underplayed from particular receptors because of ‘averaging out’ of impacts along the route. They suggested that best practice would be to detail the worst impacts along with appropriate mitigation.

15.5.34 Possible impacts on the historic environment were also highlighted in this response, although it was judged that while the revised route would be further away from a deserted farm site, it was not yet clear which route has the greatest

potential to impact on buried archaeology.

15.5.35 The Council commented in detail on landscape mitigation in one of their responses. This mostly related to the visual impact from Mark Causeway where they indicated that there was insufficient detail on the mitigation proposed. The Council put forward some detailed suggestions for mitigation, for example in relation to tree planting.

15.5.36 Two specific suggestions were made in relation to a property south of Mark Causeway which National Grid is to purchase. Sedgemoor District Council suggested that this would allow mitigation to be delivered more effectively in particular the planting which they felt was necessary here. They also suggested that while not listed, the building does contribute to the character of Mark Causeway and as such should be preserved in some form.

15.5.37 At a more strategic level the Council argued that for visual impacts which the Council judge to be ‘major’, additional and targeted mitigation should be detailed


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so as part of the DCO. They also emphasised that these measures should be deliverable, in particular that they should not depend on landowner agreement.

15.5.38 The Council were supportive of what they identify as the first section of the revised route, south of pylon LD17, recognising that the revised route will be further away from farms and properties in Southwick. However they expressed concerns relating to the second section of the route, in particular the potential impact on views from Mark Causeway. They suggested a small alteration to the route in order to avoid impacting a mature tree on Mark Causeway.

15.5.39 In two further responses the Council asked whether all consultation material was available on the National Grid website and suggested organisations National Grid

could contact in relation to outreach activities.

PILs Responses Received

15.5.40 A total of 51 responses were received from PILs during the Revised Route Consultation. Within this section of the report the issues raised by PILs have been grouped under the same topics as used in the statutory Stage 4 consultation in order to provide a coherent structure to the responses received. The same topics have also been used in subsequent sections of the report in relation to the responses received from members of the community. No specific comments relating to Cost and Safety and Security were made.

Alternatives

15.5.41 There were two comments which expressed support for the use of sub-sea cables, or in one case, installing the entire connection underground.

Consultation

15.5.42 There were 24 comments from PILs which referred to various aspects of the consultation process. The majority of those were requests for further meetings with the project team, general enquiries about the status of the project or more specific questions about the impact it would have on individual properties, as well as instructions to National Grid how to obtain land access.

15.5.43 Criticisms of the consultation process were made in three responses and focussed on the respondent’s belief that the revised route at Southwick was only suggested at a very late stage in the consultation process. One response commented on the transparency of the decision-making process, and whether it is influenced by public/PIL views.

15.5.44 Conversely, one respondent expressed their gratitude to the project team for taking people’s comments on board and revising the route accordingly.

15.5.45 Another PIL, also in favour of the revised route, protested at the decision of a Mark Parish Councillor to support the original route without first consulting the local residents. One response also questioned the accuracy of maps which did not appear to show their property.


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15.5.46 Maintaining access and traffic management during construction were mentioned in nine responses. For example a concern was voiced by one PIL with regards to further pressure on Northwick Road access points. The permanent access road was mentioned in several responses – by PILs either seeking clarifications or expressing concern over the effect the road would have on their property, for example on a dwelling they are planning to build.

15.5.47 Other responses mentioning traffic were mainly requests for further information and focussed on the location of the haul road. One respondent challenged the haul road’s position, suggesting it should follow the WPD overhead line because

this would reduce land take. Others were concerned that even after reinstatement; the land would be severely damaged.

15.5.48 Conversely, two PILs referring to Manor Farm and Chestnut House did not express concerns about the haul road passing through their land during the two year construction period but did request any accommodation works and the activities associated with it should be agreed in advance. Another respondent stated their belief that the revised construction works will impact on fewer properties.

15.5.49 Fencing and gating was another issue discussed by a small number of respondents, ranging from concerns to suggestions about which areas should be fenced. One PIL requested that health and hygiene are observed by workers and contractors.

15.5.50 Two respondents commented on the effect the construction may have on existing infrastructure on their property, one of which requested that their sewage treatment tank be protected during works.

Environment

15.5.51 Two PILs commented on wildlife; including one who described a badger sett on their land and another who requested that National Grid minimise any loss of trees

during construction. One respondent mentioned a designated area which they felt would be more significantly affected by the revised route than it would have been by the previous proposed route.

15.5.52 In four separate responses to the consultation referring to Blagdon Farm and a new development there, respondents reiterated their opposition to the revised route and highlighted its adverse visual impact, both to the Moor area in general and their land in particular.

15.5.53 One response commented on the visual impact of the proposals on their land near Court farm.

15.5.54 There were eight comments on the potential impacts of the proposed route on agriculture, most of which were concerned that the positioning of pylons on their land would impede farming operations. However, there were two PILs who felt the revised route would affect their land less than the previous proposal. Other land uses mentioned by one respondent included dog walking and horse riding.


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Health

15.5.55 Five health-related comments expressed support for the revised route because they felt it posed a decreased risk to adults’ and children’s health.

15.5.56 However there was one respondent who expressed concerns about the impact the new route may have on local residents. Two further responses asked for information on the electric and magnetic fields.

15.5.57 Apart from the future health impact of the line itself, one respondent highlighted the anxiety they are suffering because of uncertainty surrounding the project.

Mitigation

15.5.58 One respondent asked for further mitigation and impact assessment to be carried out by National Grid and a second requested that trees be retained on their land.

Policy

15.5.59 Two respondents stated that they approve the revised route because they believed it conforms more closely to the Holford rules. A further respondent commented that they believe National Grid should reroute the connection around Mark to meet their own ‘mission statement’ of caring for people and environment.

Routeing and design

15.5.60 The PILs who explicitly opposed (11) as well as those who explicitly supported (19) the revised route did so for environmental, health and socio-economic reasons. Others were unhappy that their land would be affected or highlighted particular aspects, such as sewage treatment systems or garages, which needed to be protected.

15.5.61 Two responses expressed more mixed views on the proposals, for example acknowledging that the line ‘has to go somewhere’ while maintaining concerns about impacts on their land.

15.5.62 Five respondents stated they had no preference as the new proposal had no or little effect on their properties. One, however, expressed their disappointment that they were not notified by National Grid that a particular pylon would be relocated, although they acknowledged this would not have a major impact on their land.

15.5.63 In one case, the respondent expressed support for the revised route while maintaining that they would prefer the connection to be undergrounded.

15.5.64 Four responses suggested alternative routes including re-routeing further to the East of Southwick, an alignment equidistant between Wainbridge and Court Farm and two who suggested the route should bypass Mark altogether.

15.5.65 There were five comments from PILs which mentioned pylon design; four confirmed that they had no particular views on the choice of lattice or T-pylon whilst one suggested that overhead lines are outdated. There were a further four responses which expressed a preference for the T-pylon.


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15.5.66 Three comments from PILs indicated support for a greater amount of undergrounding.

Socio-economic

15.5.67 Proximity to residential properties and associated visual impact, noise and reduction of value were the most mentioned socio-economic concern.

15.5.68 Ten responses expressed the view that the new route would affect fewer properties, including their own properties and thus it was seen favourably. However, nine responses argued that the proposed route was too close to their property. Some felt that this would affect the saleability of their properties or impact on their enjoyment of them.

15.5.69 The issue of compensation was frequently mentioned with 12 responses commenting. Of these, one asked that their case be treated with special consideration because of their advanced age and poor health. Legal/representative fees were mentioned in three responses with all three seeking clarification on National Grid’s reimbursement policy. Two PILs explored the possibility of National Grid purchasing their land with one of them stating they would be happy to receive such an offer, while the other noted they would consider it.

15.5.70 Impact on farming and tourism was an area discussed by five PILs. Concerns were also raised over the effect the revised route would have on agricultural activities in five responses. One PIL highlighted that the new route would pass through Reed Drove which was perceived as a better option.

15.5.71 Two PILs, who co-own a piece of land the revised route would cross, expressed their concerns over the effect the development would have on land they are planning to build an agricultural workers’ dwelling on. They also indicated that the construction of a third pylon as well as the haul road which would be situated on their land, would adversely affect their farming business.

15.5.72 Concerns about a tourism business were expressed by one PIL who felt that their

business would become obsolete with the line in such proximity; they commented on compensation arrangements, noting that they would consider compulsory purchase if necessary. Conversely, one PIL supported the new route because of its reduced impact on their tourism business.

15.5.73 One respondent claimed that the changes were influenced by a single PIL and did not reflect the opinions of others in the area. Other equity concerns were that Mark had not been afforded the same consideration as Southwick and two responses which felt that positioning the line equidistant between two properties is the only ‘fair’ approach.

15.5.74 Amenity was mentioned in two responses. One expressed concern with loss of amenity the other felt the revised route reduces this impact. A third response felt that the proposals have adversely affected their quality of life.


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15.6 Members of the Community Responses Received

15.6.1 There were 41 responses from members of the local community during the consultation period. No specific comments were made relating to Mitigation. These responses are summarised below with National Grid’s response to these representations presented in Section 15.8.

Alternatives

15.6.2 The majority of comments on alternative transmission technologies related to sub-sea cabling, with six responses expressing support for this form of connection. Reasons cited included the visual impact of overhead lines and their impact on communities, as well as the perceived vulnerability of overhead lines to adverse

weather. Three respondents disputed the comparative costs provided for the sub-sea connection, arguing that these have not been considered properly. They felt cost had been used as justification for not pursuing a sub-sea option.

15.6.3 Three respondents argued more generally that alternatives (including undergrounding) had been dismissed without proper consideration or justification.

Consultation

15.6.4 Four members of the public challenged the consultation process as a whole or its influence on National Grid’s decision making. One saw the consultation as an attempt to divide affected residents and questioned the influence of respondents’ feedback on this basis. Another argued that the process was inequitable, favouring those residents affected by the original route.

15.6.5 One member of the local community commented critically on a video intended to show the visual impact of the overhead line, arguing it was misleading as it did not show the true impact on properties along Yarrow Road.

Cost

15.6.6 A number of respondents referred to the comparative costs of overhead lines in

relation to alternative forms of connection. Two respondents raised the issue of willingness to pay. One indicated that they personally would be happy to contribute towards the cost of undergrounding the cables, while the other felt the possibility that residents may be happy to do so, has yet to be explored. Another response suggested that while an overhead connection appears less expensive in the short term, the long term costs of the connection should be considered.

15.6.7 There were two comments relating to the cost of the consultation on the revised route, in both cases questioning the necessity of the process. Three responses which were supportive of the revised route suggested that as fewer properties would be affected, it would be a more cost-effective option.


15.6.8 One member of the local community commented on the perceived difficulty of construction access.


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15.6.9 There were also two comments relating to pylon design, one argued that all pylons represent an outdated form of technology which should be replaced by undergrounding. The other expressed concern about visual impact resulting from the size of the proposed 400kV pylons.

Environment

15.6.10 Eleven of the fourteen comments on the environment related to the perceived adverse visual impact the revised route would have on the open and flat Somerset Levels landscape. Its importance as a habitat and home to wetland birds was also noted by one respondent.

15.6.11 A number of people stated that changes in the route, coupled with the use of

larger pylons, would make the line more visible for a greater number of locals and holidaymakers, with one respondent also mentioning footpaths and cycleways. Concerns were often accompanied with calls for the use of underground cables, with respondents emphasising that the native vegetation is not tall enough to provide sufficient screening.

15.6.12 Although most respondents who commented felt that the revised route was damaging to the area as a whole, two respondents highlighted specific sections of concern – one was the proximity of the new overhead line to Wainbridge Farm which is a listed building and the other was the visually prominent Polden Hills.

15.6.13 Conversely, five respondents felt that the revised route was less detrimental to the landscape around Southwick.

Health

15.6.14 Of the seven health-related comments from the local community, four praised the revised route for taking the pylons further away from Southwick Road. One response specified that this would expose fewer people to radiation. Another respondent, however, raised concerns over EMFs emitted by the newly located pylons and potential impacts on their young child.

Policy

15.6.15 Of the three comments on policy, one called for National Grid to lobby the government and secure an increase in subsidies which would enable them to consider undergrounding; another questioned the integrity of National Grid’s policy since its own staff denounces living near pylons. The third suggested National Grid has a ‘duty of care’ to by-pass the hamlet of Cote.

Routeing and design

15.6.16 Nine responses expressed support for the revised route, largely on the basis that it would minimise the impact on residents as less properties would be affected. Other benefits identified within responses, associated with the revised route were that it minimises the health and safety concerns of nearby residents, as well as potential impacts on property value and a listed building.

15.6.17 Two members of the public supported the route with a particular reservation or caveat. This included a preference for the line to be placed underground, concern


792

that the process seems costly and unnecessary and that the same regard should be given to the impact on Mark as on Southwick. A further three had mixed views on the route, acknowledging that although the line would be further from some properties, others would be more adversely affected.

15.6.18 In contrast, six respondents opposed the draft route generally on the grounds that it would bring the overhead line closer to their property or to communities in Mark or Yarrow. Three opposed specific areas of the route for example concern was expressed about Knowle View Farm and Southwick Farm, as well as properties on Butt Lake Road and Yarrow Road. A small number of respondents questioned the apparently greater proximity of the line to the Mark Harvest Primary and Preschool, the impact on views across the Quantock Hills and more generally on

tourism in the area.

15.6.19 Six respondents expressed opposition to an overhead line connection, or pylons in general. Two highlighted the vulnerability of overhead lines to adverse weather, while others expressed a preference for an underground or sub-sea connection. There were 15 comments on undergrounding, including respondents which argued for the entire line to be undergrounded, some which supported undergrounding more generally and one which advocated a route which follows existing lines and is underground in the AONB. Among reasons cited for this was the visual impact on the landscape of an overhead line as well as the vulnerability of such a connection to adverse weather.

15.6.20 A small number of respondents opposed the use of pylons more particularly within the area of Southwick and Mark covered by the revised route, with three consultees arguing that any connection through this area should be undergrounded.

15.6.21 Three members of the community proposed an alteration to the route. One response argued that the line should avoid the Polden Hills and the village of Puriton because of the visual impact it would have here, while another mentioned routeing further to the east to avoid the hamlet of Cote.

Safety and Security

15.6.22 Five responses called for the overhead line to be undergrounded quoting the recent flooding and strong winds which they believe would pose risk to the pylons.

15.6.23 Another respondent indicated concern over increased traffic accidents on the already dangerous B3139 road in the vicinity of First School in Mark.

Socio-economic

15.6.24 Proximity to property and reduction in value was the most commonly voiced socio-economic concern from the local community responses. Respondents indicated concerns that the proposals would bring the prices of their houses down or that they would not be able to market their properties until the project was completed. As a result of this one respondent expressed a desire to sell their house to National Grid. Conversely, one respondent believed that the revised route would affect the value of fewer residential properties than the original one.


793

15.6.25 Impact on tourism was discussed in two responses with both indicating that holidaymakers would be put off from visiting an area that would be scarred with pylons. Another respondent also noted that the environment should be preserved for the future generations. Three responses made more general comments expressing concern about the perceived detrimental impact of overhead lines on their village or community.

15.6.26 Mark First School was mentioned in two responses which expressed concerns over the well-being of children. One of the respondents indicated concerns over the proximity of the overhead line and called for undergrounding or the re-location of the second closest pylon. The other response focussed on managing traffic risks during construction.

15.6.27 It was also indicated that the school has partnered with Mark Cricket Club, which as owner of a nearby field has agreed to let the school use part of the land as a pick-up and drop-off point. The cost of developing the land has been divided between the School and Mark Cricket Club and both appealed to National Grid to assist them financially.

15.7 Wider Consultation Responses Received

15.7.1 Two responses were received for wider consultation organisations. These responses are summarised below with National Grid’s response to these representations presented in Section 15.8.

Banwell Caves Heritage Group

15.7.2 Banwell Caves Heritage Group expressed support for the revised route on the grounds that it would minimise the impact of the overhead line on properties and the environment.

Somerset Tourism Association

15.7.3 The Somerset Tourism Association requested information about arrangements for community investment or benefit. As the official tourism organisation for the county, they offered to work proactively with National Grid for the good of the region and asked for contact details in order to arrange this.


15.8.1 This section reports on National Grid’s response to the issues raised by prescribed consultees, members of the community and wider consultees during the Revised Route Consultation and the changes to the project that were made in response to the representations. The main issues raised are grouped by consultee type and are responded to under each of the themes used above with further responses in the Tables at Appendix 80. An additional column has been added to the tables to indicate whether the response was new or previously raised during the statutory Stage 4 consultation. Where the response was previously raised a cross reference to the applicable response is provided within this table to avoid duplication. The Consultation Summary Report presented at Appendix 27 provides further information on how the responses were coded and analysed.


794

Prescribed Consultees

15.8.2 The main issues raised by prescribed consultees are set out in Table 15.5 below together with National Grid’s response to these issues and whether the representation resulted in a change to the proposals.

Table 15.5 Issues raised by Prescribed Consultees

Representation New Issue

National Grid’s Response Change (Yes/ No)

Alternatives

The connection should be sub-sea

X Please see Table 12.5 No

Further consideration should be given to alternative transmission technologies including undergrounding


A greater amount of undergrounding should be proposed


Overhead lines are an outdated technology


Consultation

The decision to move the line on Mark Causeway contradicts views expressed in the previous stage of consultation

National Grid has consulted extensively on its proposals for the Hinkley Point C Connection project since 2009, and feedback from statutory consultees and local communities has been taken into account and has informed the technical development and environmental assessment of the proposals as they have evolved. During the statutory Stage 4 consultation representations were received requesting that the alignment be routed equidistant between Court Farm and Wainbridge Farm. In response to these representations and as a result of the purchase of a residential property to the south of the Causeway which will be demolished as part of the Proposed Development a revised alignment was proposed as part of the Southwick Consultation which maximised distance to properties on the Causeway as far as possible.

No

The consultation material was clearly presented and the technical information was adequate to enable

This representation was noted by National Grid.

N/A


795



comment

The revised route at Southwick was only suggested at a very late stage in the consultation process.

During the statutory Stage 4 consultation a number of representations were received from members of the community and PILs asking for a change to the route in the Southwick area. In response to these representations, National Grid developed a technically feasible route to the east of Southwick and undertook an assessment to compare the effects of the revised route against the original route consulted on during the Stage 4 Consultation. This assessment identified that the revised route would result in a reduction in the effects on views from a number of receptors in the Southwick area including PRoW AX23/3, Chesnut Farm and Knoll View Farm.

Recognising that the change to the route in this area was substantially different to that consulted on during the Stage 4 consultation, National Grid held a the Southwick consultation between 10 February and 10 March 2014 to provide consultees with an opportunity to submit feedback on the change.

No

Is the decision-making process influenced by public/PIL views.

National Grid greatly appreciates the participation of all consultees in the various stages of public consultation since 2009. National Grid has listened carefully to the views expressed in writing, at meetings and at public meetings, and have balanced these against the technical, environmental and cost considerations which we are obliged to consider. In response to feedback received from members of the community and PILs during the statutory Stage 4 consultation which asked for the proposed route to be moved to the east of Southwick, National Grid developed a technically feasible route and consulted on this to provide consultees with a further opportunity to provide feedback and express their views. All representations received during this consultation were considered by National Grid in the selection of its preferred route in this area prior to the submission of its DCO application.

N/A

Concerned about the accuracy of maps used in the consultation

The Ordnance Survey (OS) base mapping used by National Grid was the most up to date available from the OS. However, as different scales of mapping produced by the

No


796



OS display different degrees of detail and are updated at different times not every individual property may have been illustrated. National Grid was aware of the limitations of such mapping and as a result supplemented the desk-based mapping with extensive site visits to ensure all potential properties and constraints were taken into account in the development of its proposals.


Concerned about the reliability of this form of electricity transmission and its potential vulnerability to extreme weather

X Please see Table 13.27 – Safety and Security

No

Concerns about the effects of construction on Northwick Road

As part of the development of its proposals, National Grid consulted with local highway authorities and the highways agency to ensure the proposed haulage routes and access points were appropriately sited to minimise disruption to the local road network as far as possible. National Grid also liaised with these organisations over the production of a CTMP, which is submitted as part of the DCO application.

The effects of construction traffic are assessed in Volume 5.12, Chapter 12 of the ES that accompanies the DCO application.

No

The haul road should follow the WPD overhead line because this would reduce land take.

National Grid’s proposed haul road is required to provide access to the proposed overhead line and pylon positions for construction. In this area as the existing 132kV overhead line and the proposed 400kV overhead line follow different routes it would not be possible for the haul road to follow the existing overhead line.

No

Concerned that even after reinstatement the land would be severely damaged.

Upon completion of works National Grid will reinstate all land affected during the underground cable construction in accordance with the DEFRA Code of Practice for the Sustainable Use of Soils on Construction Sites.

No

Health and hygiene should be observed by workers and contractors

National Grid will ensure that all construction works are undertaken in accordance with an approved Code of Construction Practice.

No

The sewage treatment X Please see Table 12.17 – Engineering and No


797



tank should be protected during works

Construction

A consultee set out the statutory provisions for compensation in the case of damage to facilities and interruption to service as well as the process for resolving disputes

National Grid has designed its proposals to avoid all Third Party services wherever possible. Where Third Party services cannot be avoided, National Grid has worked closely with the organisations responsible for their operation or maintenance to minimise effects on operations and future development aspirations.

No

Environment

Concerns about the visual impact of the line on the Somerset Levels and Moors

X Please see Table 13.27 - Environment No

Concerned about the visual impact of the proposals on land near Court farm

Effects on views from public and private receptors in Section B were considered as part of the identification of routes and the development of the detailed design. In this area the overhead line was routed to utilise a larger gap between properties along Mark Causeway than the existing 132kV overhead line. The use of the low height T-pylon design will also help to minimise visual effects as the pylons would be approximately 11m shorter than the steel lattice pylons originally proposed.

Further information on the landscape and visual impacts of the Proposed Development is presented in Volumes 5.6 and 5.7, Chapters 6 and 7 of the ES that accompanies the DCO supplication.

No

If protected species licences are required, all relevant information should be provided in relation to the revised route

This representation was noted. All information required in support of any necessary protected species licenses will be provided to Natural England.

No

Wessex Water highlighted a number of relevant sections of the Water Industry Acts to be considered and referenced, suggesting changes to the wording and the addition of specific clauses

This representation was noted by National Grid and the suggested changes to the wording of the DCO were incorporated as appropriate.

Yes

Photomontages for each In response to this representation, National Yes


798



option should be provided from Causeway Road

Grid liaised with Sedgemoor District Council to agree the location of an additional photomontage from Mark Causeway. This photomontage has been included in Volume 5.18, Chapter 18 of the ES that accompanies the DCO application

Concern about the visual impact of the proposals near Mark Causeway


It is not clear which route has the greatest potential to impact on buried archaeology

The potential effects of the original and revised routes were appraised in the Southwick Options Appraisal Report. Paragraph 3.10.4 of this report indicated that:

“For both alignments there may be adverse effects on as yet unknown buried archaeological remains as a result of truncation during construction of pile pads, access roads, crane bases and perturbation as a result of piling. These effects are likely to be able to be mitigated and of low residual significance.”

Further assessment of effects on buried archaeology and the historic environment is presented in Volume 5.11, Chapter 11 of the ES that accompanies the DCO application.

No

National Grid should minimise any loss of trees during construction

In accordance with the Holford Rules, National Grid sought to avoid tree losses wherever possible when planning the route of the Proposed Development. Where the removal of trees cannot be avoided, National Grid has a policy of replacing one tree with four new trees. National Grid will aim to plant the new trees on the same land but where this cannot be achieved, National Grid will enter into negotiations with landowners to agree suitable alternative locations for planting.

No

Health

Concerns about the impact of the new route on the health of local residents.

Electric and magnetic fields (EMFs) are produced wherever electricity is used, and there have been suggestions that exposure to these fields might be a cause of ill health. The NPS EN-5 highlights at paragraph 2.10.6 that ‘the balance of scientific evidence over several decades has not proved a causal link between EMFs and

No


799



cancer or any other disease’.


Health considerations are given a high priority in the process by which we arrive at any proposals for new electricity circuits. Assessment of compliance with national guidance and policies is key to our approach. The UK has a carefully thought-out set of policies for managing EMFs, which includes both numerical exposure guidelines to protect against established, acute effects of EMFs, and precautionary policies to provide appropriate protection against the possibility of chronic effects of EMFs at lower levels, including, specifically, the possibility of a risk for childhood leukaemia. These policies are incorporated into the decision-making process for Development Consent in National Policy Statement EN-5.

Our approach is to ensure that all of our assets comply with those policies, which are set by Government on the advice of their independent advisors PHE. This ensures that health concerns are properly and adequately addressed. The evidence concerning compliance with these policies as specified in EN-5, including the numerical guidelines are fully and publically documented in Volume 5.16, Chapter 16 of the ES. Additionally, in developing a route for the connection National Grid sought to maximise the distance from settlements and residential properties as far as possible on the grounds of general amenity. National Grid operates an EMF information website and telephone helpline to answer any questions and concerns from members of the public. People requiring further information can look at the EMFs information website at www.emfs.info, or



800



alternatively contact the EMF Helpline on 0845 702 3270 or via email – [email protected].

Mitigation

There was insufficient detail on the mitigation proposed on Mark Causeway

Site specific mitigation details are provided in Volume 5.7, Chapter 7 of the ES and details of the offsite measures proposed are presented in the OSPES, Volume 5.25.

No

For visual impacts which are ‘major’, additional and targeted mitigation should be detailed as part of the DCO

No

The building to be demolished to the south of Mark Causeway contributes to the character of Mark Causeway and as such should be preserved in some form

In response to this representation National Grid reconsidered its proposals for the demolition of the building to the south of Mark Causeway but concluded that its original proposals remained valid to ensure that the proposed route maximises distance from residential properties as far as possible.

No

Policy

National Grid has a Public Sector Equality Duty under the Equality Act (2010) to identify and mitigate adverse impacts on any protected groups.

This representation was noted by National Grid and details of the mitigation proposed are set out at Volumes 5.6 to 5.17, Chapters 6 to 17 of the ES.

No

Routeing and Design

Pylon LD18 should be moved closer to Court Farm

This request would move the pylon closer to the original alignment included within the statutory Stage 4 consultation which was modified following requests received during the consultation from the Joint Councils and other consultees who requested that an alignment more central between Court Farm and Wainbridge Farm should be adopted.

Whilst repositioning pylon C-LD18 would move it slightly further away from Wainbridge Farm it would take it closer to the house at Court Farm and would also require pylon C-LD19 to be moved west closer to a drain. This change in alignment was not considered to offer any benefits over the route proposed and as a result National Grid is not proposing to include this change within its DCO application.

No

There should be a small alteration to the route in order to avoid impacting a mature tree on Mark Causeway

No



801



The alignment should be equidistant between Wainbridge and Court Farm

During the statutory Stage 4 consultation representations were received requesting that the alignment be routed equidistant between Court Farm and Wainbridge Farm. In response to these representations and as a result of the purchase of a residential property to the south of the Causeway which will be demolished as part of the Proposed Development a revised alignment was proposed as part of the Southwick Consultation which maximised distance to properties on the Causeway as far as possible.

No

Concern about the line being moved closer to Wainbridge Farm, a listed building

Effects on the listed building of Wainbridge Farm were assessed as part of the PEIR that was published to accompany the Southwick consultation. The assessment concluded that whilst there would be minor adverse effects on this receptor the scale of effect would not differ as a result of the change in alignment.

No

The decision to revise the route has minimised impacts on the majority of Southwick

This representation was noted by National Grid.

No

National Grid should reroute the connection around Mark

X Please see Table 13.27 – Routeing and design

No

The route should be re-routed further to the East of Southwick

X

Socio-Economics

Concerned that the positioning of pylons on their land would impede farming operations

Where the Proposed Development crosses land used by a business and that business’ operation is affected by the construction or operation of the Proposed Development National Grid will pay compensation for any losses in accordance with statute.

No

Concerned about the effects on property values

X Please see Table 13.27 – Socio-economics No

Concerned about the effects of the revised route on tourism

The effects of the revised route on tourism receptors was presented in the PEIR that accompanied the consultation with further information presented within Volume 5.15, Chapter 15 of the ES that accompanies the DCO application.

No

Concerns over the effect As part of the development of its proposals No


802



the development would have on land on which an agricultural workers’ dwelling is planned. The construction of a third pylon as well as the haul road would adversely affect the farming business

National Grid gathered data relating to all consented developments from the local planning authorities. Wherever possible National Grid sought to avoid or minimise effects on land on which development was proposed. Where it was not possible to avoid or minimise effects National Grid will pay compensation for losses directly attributable to the Proposed Development in accordance with current statute.

Members of the Community

15.8.3 The main issues raised by members of the community are set out in Table 15.6 below together with National Grid’s response to these issues and whether the representation resulted in a change to the proposals.

Table 15.6 Issues raised by Members of the Community



Alternatives

The connection should be sub-sea


Other alternatives (including undergrounding) have been dismissed without proper consideration or justification


Consultation

The consultation is an attempt to divide affected residents

During the statutory Stage 4 consultation a number of representations were received from members of the community and PILs asking for a change to the route in the Southwick area. In response to these representations, National Grid developed a technically feasible route to the east of Southwick and undertook an assessment to compare the effects of the revised route against the original route consulted on during the Stage 4 Consultation. Recognising that the change to the route in this area was substantially different to that consulted on during the Stage 4 consultation, National Grid held the Southwick consultation between 10

No

The consultation process was inequitable as it favoured those residents affected by the original route.

No


803



February and 10 March 2014 to provide consultees with an opportunity to submit feedback on the change. All comments received during the consultation were considered by National Grid in finalising its proposed DCO application

The video intended to show the visual impact of the overhead line was misleading as it did not show the true impact on properties along Yarrow Road

The video produced to illustrate the Proposed Development was taken from a 3D computer model which allowed an “interactive” fly-through perspective of the Proposed Development. This model was designed to provide a realistic impression of the proposals and, amongst other options, a comparison of existing infrastructure, the T-pylon and the equivalent 400,000 volt steel lattice pylons. The model was based on technically accurate mapping and detailed photographic surveys and was used widely during the consultation.

No

Cost

Undergrounding is not as expensive as is being quoted


National Grid should properly cost the sub-sea and underground options


Would be happy to contribute towards the cost of undergrounding the cables


National Grid has not explored residents willingness to pay for alternative methods of transmission.


The long term costs should be considered



Concerned that there will be problems bringing construction vehicles down narrow winding country lanes at Southwick.

As part of the identification and development of appropriate access routes for construction National Grid considered a range of factors to ensure that the accesses identified were the most appropriate and would minimise the disruption impacts on the local road network as far as possible. All accesses were discussed with the local authorities and the Highways Agency who

No


804



confirmed their in principle agreement to the accesses proposed. The use of a haul road in this area helps to minimize effects on the local road network as it minimises the number of access points required off the highway network and removes HGVs from using unsuitable roads in this area.

Pylons represent an outdated form of technology


Concerned about the reliability of this form of electricity transmission and its potential vulnerability to extreme weather

X Please see Table 13.27 – Safety and Security

No

Environment

Concerned about the adverse visual impact the revised route would have on the open and flat Somerset Levels landscape


Changes in the route, coupled with the use of larger pylons, would make the line more visible

Whilst the revised route would have a slightly greater scale of change in the landscape due to its distance from the existing 132kV overhead line it would result in a reduction in the effects on views from a number of receptors in the Southwick area including PRoW AX23/3, Chesnut Farm and Knoll View Farm and as result was considered preferable to the route consulted on during the statutory Stage 4 consultation.

No

Native vegetation is not tall enough to provide sufficient screening.

In response to representations received during the statutory Stage 4 consultation, National Grid developed an OSPES. The OSPES at ES Volume 5.25 includes landscape works to further reduce the adverse residual effects on landscape character and views of the Proposed Development.

No

Concerns about proximity of the new overhead line to Wainbridge Farm a listed building

Effects on the listed building of Wainbridge Farm were assessed as part of the PEIR that was published to accompany the Southwick consultation. The assessment concluded that whilst there would be minor adverse effects on this receptor the scale of effect would not differ as a result of the

No


805



change in alignment.

Concerns about effects on views from the Polden Hills

National Grid acknowledges that the proposed pylons would be visible from some receptors on higher ground including the Polden Hills. In developing its proposals careful consideration was given to the effects on landscape and views and a full assessment is presented in Volume 5.7, Chapter 7 of the ES that accompanies the DCO application.

No

Health

Concerns over EMFs emitted by the newly located pylons and potential impacts on young children

X Please see Table 13.27 – Health No

Policy

National Grid should lobby the government and secure an increase in subsidies which would enable them to consider undergrounding


Routeing and Design

National Grid should route further to the east to bypass the hamlet of Cote

X Please see Table 13.27 – Routeing and Design

The pylon closest to Mark First School should be moved further away.

This request would move the pylon closer to the original alignment included within the statutory Stage 4 consultation which was modified following requests received during the consultation from the Joint Councils and other consultees who requested that an alignment more central between Court Farm and Wainbridge Farm should be adopted.

Whilst repositioning pylon C-LD18 would move it slightly further away from Mark First School it would take it closer to the house at Court Farm and would also require pylon C-LD19 to be moved west closer to a drain. This change in alignment was not considered to offer any benefits over the route proposed and as a result National Grid is not proposing to include this change within its DCO application.

No

National Grid should have given the same regard to

X Please see Table 13.27 – Routeing and No


806



the impact on Mark as on Southwick and avoided the village

Design

National Grid should reconsider a route to the east of Mark

X No

Why is the route closer to Mark First School

The proposed route has moved slightly closer to Mark First School as a result of requests received during the consultation from the Joint Councils and other consultees who requested that an alignment more central between Court Farm and Wainbridge Farm should be adopted. Following the purchase of a residential property to the south of the Mark Causeway and a change in the route to the south of Mark at Southwick a modification to the alignment that met these requests was identified and was considered to offer benefits over the route originally proposed.

N/A

The route should follow the existing 132kV overhead line

X Please see Table 12.17 – Routeing and Design

No

The connection through Mark and Southwick should be undergrounded

The COR which was published as part of the Stage 3 Draft Route Consultation, assessed overhead line and underground cable options within Section B (Somerset Levels and Moors South) against a range of various factors and policy provided in the National Policy Statement for Electricity Networks (EN-5). It concluded that the benefits from the use of underground cables as an alternative to an overhead line in the Somerset Levels would not clearly outweigh any extra economic, social and environmental impacts.

Localised undergrounding of the connection in areas such as Mark, Southwick or Cote would require the introduction of CSE compounds and large terminal pylons wherever the overhead line transitions to an underground cable. The use of underground cables would also further increase the overall cost of the scheme. As a result the benefits from the use of underground cables as an alternative to an overhead line in these localised sections of the route would not clearly outweigh any extra economic, social and environmental impacts and as a result could not be justified.

No

The connection should be underground through Cote

No


807



The revised route is preferable as it would position the overhead line and pylons further away from properties.

National Grid noted this comment. No

The revised Southwick route goes through much more open countryside where there are far reaching views over flat land across to the Quantock Hills.

During the statutory Stage 4 consultation a number of representations were received from members of the community and PILs asking for a change to the route in the Southwick area. In response to these representations, National Grid developed a technically feasible route to the east of Southwick and undertook an assessment to compare the effects of the revised route against the original route consulted on during the Stage 4 Consultation. This assessment identified that whilst the revised route would have a slightly greater scale of change in the landscape due to its distance from the existing 132kV overhead line it would result in a reduction in the effects on views from a number of receptors in the Southwick area including PRoW AX23/3, Chesnut Farm and Knoll View Farm.

No

The route should be moved further south and east away from Southwick Farm

In response to this representation National Grid considered options for a route alignment further south and east of Southwick Farm. Further movement of the proposed route east increase the length of the route, would make it less direct and would require additional larger angle pylons to be included in the route. As a result an alteration to the route in this area was not considered to offer any benefits over the revised route proposed as part of the Southwick consultation.

No

Safety and Security

Recent flooding and strong winds would pose risk to the pylons

Overhead lines are required to be designed, constructed and operated to meet the requirements set out in the Electricity Safety, Quality and Continuity Regulations 2002 (as amended) as well the Electricity Supply Industries own standards.

Extreme weather conditions that can affect National Grid’s overhead lines include high winds and ice or, worst of all, a combination of the two. Ice forming on a conductor can cause the insulators supporting the line to break under the additional weight and the additional tension that the additional weight

No


808



will cause. Furthermore high winds can place much greater forces on an iced up conductor placing yet more strain on the supporting insulators. Nevertheless, overhead lines are designed to withstand all but the most extreme weather conditions and, as a result, have an excellent reliability record.

National Grid has investigated whether future climate change might require new designs of overhead lines, but found there is more likely to be a reduction in the risk of a simultaneous occurrence of ice on the wires and intense wind gusts.

Concern over increased traffic accidents on the already dangerous B3139 road in the vicinity of First School in Mark

As part of the development of its proposals, National Grid consulted with the local highways authorities and the Highways Agency to ensure that the proposed routes for construction traffic are appropriately sited and minimise disruption as far as possible. The amount of construction activities being carried out on smaller highway routes will be limited to reduce the impact to local residents and businesses. Mark Causeway itself would not be used for construction, however there would be a crossing point on the Causeway at which point priority would be given to highway traffic. Further detail on the traffic management measures proposed during construction to minimise impacts are set out in the CTMP which accompanies the DCO application.

No

Socio-Economics

Concern that the proposals would bring the house prices down

X Please see Table 13.27 – Socio-economics No

Holidaymakers would be put off from visiting an area that would be scarred with pylons

As part of the development of the proposed application, National Grid undertook a socio-economic appraisal, which considered the effects on tourism, including the effects on accommodation facilities and visitor attractions in Section A. A number of mitigation measures will be considered during construction to reduce impacts on socio economic receptors. These include:

Seeking to programme construction activities which have the greatest effect on amenity to minimise effects on traffic peaks and local

No


809



communities.

Explore ways to allow the accommodation and transport requirements to avoid coinciding peak employee demand for accommodation with peak seasons and to maximise the ability to have a geographic spread of employee accommodation to account for potential cumulative impacts with other projects

Seeking to minimise the extent to which use of PRoW/recreational routes is disrupted and implement a plan for improving the condition of certain footpaths.

The environment should be preserved for the future generations

The proposed Hinkley Point C Connection project is a NSIP which is helping to facilitate the transition to low carbon and renewable sources of electricity generation including the proposed Hinkley Point C Power Station. In developing its proposals National Grid had regard to a range of factors including potential effects on the landscape in Section A and balanced these against other environmental effects, technical considerations and its statutory duties and legislation in identifying the most appropriate route and form of the connection.

N/A

National Grid should contribute to the cost of developing land as a pick up and drop off point for Mark First School

Until National Grid has obtained permission to build the new electricity connection, we are unable to consider specific applications for community investment. National Grid would however be pleased to hear from this consultee again when proposals for the Hinkley Point C Connection have been approved.

No


15.9.1 The Revised Route Consultation undertaken between 10 February and 10 March 2014 was undertaken in accordance with National Grid’s statutory SoCC and Consultation Strategy which were developed in accordance with DCLG Guidance and the requirements of the Planning Act 2008 (as amended by the Localism Act 2011).


810

15.9.2 Many of the issues raised during the consultation, particularly those regarding alternatives and costs had previously been raised during the statutory Stage 4 consultation. However, all of the representations raised by prescribed consultees, members of the community and wider consultees were considered in detail by the project team in the refinement of the proposals and the formulation of the DCO application. As a result of representations received, National Grid concluded that its revised route offered the optimal solution in the Southwick area and should be confirmed as the preferred solution and included within the DCO application.

15.9.3 A small number of changes were made to the proposals due to representations received. In response to a representation from Sedgemoor District Council National Grid produced an additional photomontage from Mark Causeway and

included this within its DCO application. Modifications to the wording of the DCO were also made in response to a representation received from Wessex Water.


811

16 PILS IDENTIFIED FOLLOWING THE STATUTORY STAGE 4 CONSULTATION

16.1 Introduction

16.1.1 As a result of amendments made to the route, and discussions with PILs during the consultation process, a number of new PILs were identified. In order to ensure that these additional PILs were consulted in accordance with section 42 of the Planning Act, a rolling programme of consultation with PILs took place between 10 February and 3 May 2014.

16.2 Summary of Consultation Activities Undertaken

16.2.1 All newly identified PILs were sent letters and consultee packs at the start of the consultation containing the following information and were given a period of 28 days in which to respond.

Project News.

Project Overview Report.

Consultation Feedback Form.

Document Navigation Booklet (a guide to the project documents on the enclosed DVD).

Document DVD (containing all of the project consultation documents published during the statutory Stage 4 consultation including the PEIR); and

Copy of the S48 notice.

16.2.2 National Grid and its land agents also directly engaged with PILs during the consultation period via correspondence and face-to-face meetings, in order to make them aware of the consultation and ensure that they understood their rights and role in the ongoing process.

16.2.3 A list of PILs sent letters and packs, along with the different letters that were sent can be found at Appendix 57.

Feedback Mechanisms

Feedback Form

16.2.4 A paper feedback form was made available to PILs to provide their feedback on the consultation (see Appendix 76).

16.2.5 In addition to hard copy feedback forms consultees were able to provide feedback on the proposals by:

a) Writing to the freepost address at Freepost H POINT CONNECTION;

b) Sending an email to [email protected];

c) Calling the freephone number 0800 377 7347; and



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d) Speaking to National Grid’s land agents.

16.2.6 A total of four emails, phone calls and letters were received as part of the consultation and seven responses were received via National Grid’s land agents.

16.3 Responses Received

16.3.1 A total of 13 representations from organisations and individuals identified under Section 42(d) of the Planning Act as PILs were received. These responses are summarised below with National Grid’s response to these representations presented in Section 16.5.

16.3.2 The issues raised by PILs have not been split into project wide and location specific issues but have been grouped under the same topics as used in the statutory Stage 4 consultation in order to provide a consistent structure to the responses received. No specific comments relating to Alternatives, Cost, Policy and Safety and Security were received during the consultation.

Consultation

16.3.3 Of nine comments received on consultation, six were requests for more information or further meetings with the project team and one challenged the accuracy of the map provided by National Grid and their property’s recorded details.

16.3.4 One PIL in the Tickenham area felt that their previous discussion with National Grid had been ignored as the route proposed had greater impacts on their property than in previous iterations. The same PIL felt that National Grid had not responded to them promptly during the consultation period and objected to the use of standard letters to communicate on issues of serious consequence to them.


16.3.5 One response commented on construction traffic and access. Submitted by a business owner operating a distribution centre it called for any road works to be

carried out outside office hours to minimise disruption.

16.3.6 Another response argued that noise pollution from the proposed route may affect the development potential of their property.

Environment

16.3.7 One comment on Environment was made in relation to the effect of the proposal on a parcel of development land.

Health

16.3.8 One PIL expressed concern about the anxiety caused by the proposals and their potential impact on the PILs property.

Mitigation

16.3.9 Notwithstanding their desire to sell the land to National Grid, Triflex Properties Limited made a number of suggestions about how they felt the adverse impact of


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the line could be mitigated. These included the use of T-pylons instead of the proposed lattice pylons and relocating the pylon that is opposite the Harbour Centre further south.

Routeing and design

16.3.10 One PIL response expressed opposition to the proposals adjacent to development land they own near Avonmouth and indicated that the Proposed Development would be contradictory to a number of local planning policies in the Bristol Local Plan, the Core Strategy and the NPPF. In addition there were three responses from a PIL in the Tickenham area who objected to the proposed route, which will require the purchase of part of their land.

Socio-economic

16.3.11 Adverse impact on development land was a concern raised in three responses relating to two sites: a planned recycling facility at Avonmouth and planned residential development in the vicinity of the Harbour Centre, in Section G.

16.3.12 Triflex Properties Limited commented extensively on its proposed residential development within Section G, quoting the adverse effect the proposed route would have on its land including noise and visual impact. It argued that a compulsory purchase of a portion of the land by National Grid would render them unable to comply with planning requirements and subsequently the development could not proceed. As such they requested that National Grid should purchase the totality of the land.

16.3.13 Impact on existing businesses was another area of concern with one respondent stating that 30 of their properties could be affected and requested further meetings with the project team.

16.3.14 There were three responses from a PIL in the Tickenham area setting out their concerns that the proximity of the route to their property will render it un-saleable and effectively deprive them of the equity invested in the property.

16.4 Other PILs

16.4.1 During the same period four responses were received from PILs whose were not newly identified PILs and who had been contacted previously during the statutory Stage 4 consultation.

16.4.2 Of the four responses three were requests for information about the project timetable, payments for land access and documentation. There was also one comment from a business owner in Avonmouth who objected to the cables passing over their depot due to their use of large cranes.


16.5.1 This section reports on National Grid’s response to the issues raised by the newly identified PILs during the consultation and the changes to the project that were made in response to the representations. The main issues raised are responded to under the themes detailed above in Table 16.2 with further responses in the Tables at Appendix 81. An additional column has been added to the tables to


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indicate whether the response was new or previously raised during the statutory Stage 4 consultation. Where the response was previously raised a cross reference to the applicable response is provided within this table to avoid duplication. The Consultation Summary Report presented at Appendix 27 provides further information on how the responses were coded and analysed.

Table 16.2 Issues raised by Newly Identified PILs


National Grid’s Response Change (Yes/No)

Consultation

The map provided by National Grid was inaccurate and the property’s recorded details were incorrect

The inaccuracies in the map and property details were caused as a result of an error by National Grid’s land agents. However, National Grid did not consider that the inaccuracies prevented the PIL from providing an effective response.

N/A

Previous discussions with National Grid have been ignored

National Grid greatly appreciates the participation of both of all consultees in the various stages of public consultation since 2009. National Grid has listened carefully to all views expressed in writing and at meetings and have balanced these against the technical, environmental and cost considerations which we are obliged to consider. On Tickenham Ridge the change in the proposed route of the 132kV underground cables is as a result of utilising a horizontal directional drill to minimise effects on this area.

No


Any road works should be carried out outside office hours to minimise disruption.

Construction activities will take place between the hours of 0700 to 1900 Monday to Saturday and 0700 to 1700 Sundays. However, certain activities such as the jointing of the underground cables will require 24 hour working.

No

Noise pollution from the construction and operation of the proposed route may affect the development potential of their property

National Grid does not consider that the noise generated during construction and operation of the Proposed Development would affect the development potential of the site in question. The effects of the Proposed Development on noise sensitive receptors in the Avonmouth area (and across the route as a whole) are assessed in Volume 5.14, Chapter 14 of the ES that accompanies the DCO application.

No

Environment

Concerned about the noise and visual impact of

The effects of the Proposed Development are assessed in the ES that accompanies the DCO application. The visual impacts

No


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the proposed route of the proposals are addressed in Volume 5.7, Chapter 7 and the noise effects in Volume 5.14, Chapter 14.

Mitigation

T-pylons should be used instead of the proposed lattice pylons in Section G

X Please see Table 13.3 - Routeing and Design

No

The pylon that is opposite the Harbour Centre should be relocated further south

The proposed alignment does not oversail

the Proposed Development at the Harbour

Centre and the order limits do not

encroach on the Proposed Development

site. Due to the presence of existing and

proposed built development in this area

options for change are extremely limited

and would have knock on implications for

other pylons in this section of the route.

As there would be no demonstrable

benefits in moving the pylon further south

this change was not included within the

DCO.

No

Routeing and Design

Opposition to the route of the proposed development as it would be contradictory to a number of local planning policies in the Bristol Local Plan (adopted 1997), the Core Strategy (adopted 2011) and the NPPF..

These representations were noted and considered by National Grid as part of the finalisation of the DCO application. As assessment of the Proposed Development in the context of the National Policy Statements, the NPPF and local policy is provided within the Planning Statement that accompanies the DCO application.

No

Socio-Economics

Concerned about impact of the route on planned development at the Harbour Centre, Avonmouth. Planning permission has been granted, but proposed dwellings have not yet been built

The proposed route avoids the site of the Proposed Development at the Harbour Centre, Avonmouth and would not prevent this site being brought forward for development.

No

It is not clear how the proposed development will affect a site which has planning consent for a 350,000 tonne Energy from Waste plant, a

The Proposed Development has been designed to avoid the site of the proposed energy from waste plant and material recycling facility and as a result adverse effects on the developability of this land are not anticipated.

No


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100,000 tonne Material Recycling Facility and a Bottom Ash recycling facility.

Concerned about the effects of the proposals on property value due to proximity.

In accordance with the Holford Rules the Proposed Development has been designed to avoid residential areas and individual properties as far as possible. Whilst socio-economic factors have been taken into account in the development and refinement of the proposals, the effect on the value of private individual properties has not been a factor in the decision making process. The effect on house prices of an overhead transmission line is not a matter that requires assessment under the EIA Regulations. PINS have not required such effects to be assessed in the scoping opinion adopted for this project or adopted in relation to other nationally significant infrastructure projects. The effect on house prices as a result of this development, as with all types of development, is not material to the planning merits of the proposal.

Compensation arrangements are set out in legislation. The relevant legislation provides that those whose property will have National Grid equipment sited on or across it (e.g. if the conductors/wires oversail a landholding) are entitled to compensation under property law. National Grid works closely with any landowners on whose land our equipment is sited to negotiate compensation terms if this is appropriate. Any party who feels that they may have a claim for compensation, is recommended to seek professional advice and /or contact National Grid who will be happy to discuss their individual situation.

No


16.6.1 The rolling programme of consultation undertaken with newly identified PILs between February and May 2014 was undertaken in accordance with National Grid’s statutory SoCC and Consultation Strategy which were developed in accordance with DCLG Guidance and the requirements of the Planning Act 2008 (as amended by the Localism Act 2011).


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16.6.2 The representations raised by the newly identified PILs were considered in detail by the project team in the refinement of the proposals and the formulation of the application. However, no changes were made to the Proposed Development as a result of these representations.


818


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17 EIA CONSULTATION

17.1 Introduction

17.1.1 This section provides an overview of the consultation and engagement relating to the EIA process, including screening, scoping and the preliminary environmental information report (PEIR). National Grid’s consultation and engagement on the EIA process is set out in more detail in Volume 5.5, Chapter 5 of ES.

17.2 Screening Opinion and Consultation

17.2.1 No ‘screening opinion’ was requested from decision makers. Given the scale and complexity of the project and the sensitivity of the local environment within which it would be constructed and operated, the Proposed Development was considered likely to have the potential to give rise to significant effects on the environment. As such, an EIA has been undertaken and a statutory ES prepared.

17.2.2 On 16 April 2013, National Grid notified PINS in writing that it would provide an ES in respect of the project. On 2 September 2013, National Grid wrote to PINS to provide formal notice of its intention to submit a DCO application and accompanying ES in respect of the project, in accordance with Section 46 of the Planning Act 2008. Prior to the Revised Route Consultation a Section 46 notification was also issued. These letters advised PINS that National Grid intended to commence statutory pre-application consultation on 3 September 2013 and 10 February 2014 respectively. A copy of the letters sent to PINS is provided in Appendices 14 and 53.

17.3 Scoping Consultation

17.3.1 Scoping is the non-mandatory process of seeking an opinion as to the appropriate content and extent of matters to be covered by the EIA. The scope of the EIA was determined through voluntary early and on-going engagement with consultees and more formally through the publication of an EIA Scoping Report on 16 April 2013 and request for a scoping opinion.

Scoping Report Consultation

17.3.2 In accordance with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 (as amended), National Grid engaged with the relevant local planning authorities, national agencies and others on the proposed scope of the EIA between October 2012 and March 2013. Three Thematic Groups were established (landscape and views; biodiversity; and the historic environment) comprising technical officers from local authorities, statutory consultees and specialist local non-statutory consultees, such as the Wildlife Trust. In addition, a number of ad hoc meetings covering other environmental assessment topics were held with statutory consultees and representatives of the local authorities. These groups provided advice on baseline conditions and the scope of the assessments.

17.3.3 In parallel to this, the Stage 3 Draft Route consultation took place. The information upon which this stage of consultation was based included extensive


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environmental information and responses to this consultation helped inform route selection, site selection and design and mitigation.

17.3.4 Prior to submission of the Scoping Report to the Planning Inspectorate, National Grid provided attendees of the Thematic Groups and other statutory and non-statutory organisations with a copy of the applicable Draft EIA Scoping Report Chapters for review and comment. Comments received were addressed within the Scoping Report and a table was included within each of respective chapters which set out the comments received and how they had been taken in to account in the finalisation of the report.

17.4 Feedback on the Scoping Report

17.4.1 The Scoping Opinion from PINS was received on 31 May 2013. National Grid has undertaken a review of the views expressed by the Secretary of State and the representations from statutory consultees included in the Scoping Opinion. Volume 5.5, Appendix 5B provides a summary of each representation and how they have been addressed through the EIA process. If no further action was considered necessary, appropriate justification is provided.

17.4.2 The majority of the representations received were either specific to each environmental topic chapter or site-specific and generally included the following statements:

in agreement with a proposed approach;

in broad agreement with a proposed approach but requesting consideration of other issues which may lead to partial refinement;

disagreement with a proposed approach; and

suggestions not put forward in the Scoping Report that should be considered further.

17.4.3 The remaining representations were more generic and including the following:

requests to ensure appropriate consultation was undertaken with relevant consultees to agree the timing and relevance of survey works;

requests to ensure the physical scope of study areas was identified in accordance with recognised guidance where possible and is sufficiently robust;

requests to demonstrate compliance with National Policy Statements;

requests to ensure the ES includes a description of the proposed construction programme and methods;

comments on the structure and overall assessment approach of the ES; and

comments on matters proposed to be scoped out.

Outcome of the Consultation and Engagement

17.4.4 The outcome of the scoping was to confirm the scope and approach to topic assessments, appropriate modelling, data collection and facilitate better communication of the project to consultees.


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17.5 PIER Consultation

17.5.1 Regulation 10 of the 2009 EIA Regulations requires that where a development is EIA development the applicant confirms in their SoCC how they intend to publicise and consult on the preliminary environmental information. The PEIR produced satisfied this requirement and was consulted on in accordance with the SoCC.

17.5.2 The PEIR formed part of a suite of documents which were available to view as part of the statutory Stage 4 consultation. The PEIR built on the Scoping Report, taking account of representations at Scoping Stage, and provided high level information on the potential effects of the Proposed Development. The consultation was undertaken for a period of eight weeks between 3 September

and 29 October 2013. As outlined in Chapter 5 of this Report, National Grid produced a SoCC in accordance with Section 47 of the Planning Act 2008 detailing how it intended to consult upon the preliminary environmental information.

17.5.3 During the statutory Stage 4 Consultation, 1,635 individual representations were received, many of which were directly related to the EIA process (PEIR and ES). The process of holding meetings with stakeholders to discuss key environmental issues was maintained by National Grid before, during and after statutory Stage 4 Consultation. This enabled further influence of the EIA process through to the production of the ES.

17.6 The Revised Route PEIR

17.6.1 As a result of the feedback received during the statutory Stage 4 consultation, some changes were introduced to the proposals with regard to Section B: Somerset Levels and Moors South, in the Southwick area, which were subject to localised and targeted consultation. The Revised Route Consultation took place from 10 February to 10 March 2014, a period of 28 days. This was in line with the minimum period for consultation outlined by Section 45 of the Planning Act 2008. Prior to the start of consultation, National Grid notified the Secretary of State of the proposed application under Section 46 of the Planning Act 2008 by letter dated 7 February 2014 to the Planning Inspectorate. This can be found at Appendix 51.

17.6.2 As part of the material for targeted consultation, a supplementary PEIR relating to the proposed change in the route was produced. The purpose of this PEIR was to describe the potential changes at sites and to identify whether these would have the potential to give rise to likely significant environmental effects not identified in the assessment presented at the statutory Stage 4 Consultation or which would be materially different.

17.7 Ongoing Engagement

17.7.1 Engagement has been an important theme throughout the EIA process. Outside of the non-statutory and statutory consultation stages described above, a variety of methods were used to engage with consultees. Following the publication of the PEIR stakeholder engagement included further Thematic Group meetings, topic specific meetings and one to one meetings with stakeholders and statutory consultees, to inform more detailed assessment and subsequent mitigation strategies. Short periods of written engagement have also taken place to determine the method and projects covered in the cumulative effects assessment


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and to inform the assessments and mitigation measures in the post Design Freeze Draft ES.

17.7.2 The Draft ES and a large number of the ES supporting documents were provided to a number of statutory and non-statutory bodies over a period of two weeks between 3 and 17 February 2014. This process of engagement (over and above that required by the statutory consultation process) was undertaken to provide an opportunity for these bodies to influence the assessment documents prior to their finalisation to accompany the DCO application.

17.7.3 A summary of the Draft ES comments received (relevant to EIA) and National Grid’s responses are summarised at Volume 5.5, Appendix 5C of the ES.

17.7.4 Further detail on the on-going engagement undertaken with relevance to the ES including who National Grid engaged with, frequency of events and the period over which engagement was undertaken and the type of engagement undertaken are provided in Volume 5.5, Chapter 5 and Appendices 5B and 5C of the ES. In addition, each ES topic chapter (Volumes 5.6 to 5.16) include key issues arising from the consultations.


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18 CONCLUSIONS

18.1.1 National Grid has adopted a multi-phased approach to its non-statutory and statutory stages of pre-application consultation for the Hinkley Point C Connection project. The non-statutory consultations were undertaken in accordance with the non-statutory SoCC and published consultation strategies and the statutory consultation was undertaken in accordance with the statutory SoCC and all relevant statutory requirements.

18.1.2 All representations received during the non-statutory and statutory pre-application consultation stages were considered by National Grid and taken into account in the development and refinement of the project. National Grid took great care to analyse and give detailed consideration to all feedback received and to publish feedback reports following each stage of the non-statutory pre-application consultation process. Those reports, and this overarching Consultation Report, show how the feedback received has influenced and improved National Grid’s thinking on the design of, and way to deliver, this major infrastructure project.

18.1.3 Whilst a large number of changes were made to National Grid’s proposals as a result of feedback received during the non-statutory and statutory consultations a number of aspects of the Proposed Development remained unchanged. A reoccurring theme during each stage of consultation was the desire of consultees to see the connection completely undergrounded, constructed in the sea using sub-sea cables or constructed with an alternative technology that did not require overhead transmission infrastructure. In response to these representations, National Grid employed a continual process of back-check and review which involved re-evaluating these technologies in light of new information and changes in the generation background. Where changes were not made National Grid clearly articulated to consultees the reasons why and published information which fully explained these reasons.

18.1.4 Having considered the representations received during each round of consultation, National Grid remains confident that appropriate information was

provided at each stage of the consultation process to enable consultees to respond and that the information provided was in accordance with the published SoCC and consultation strategies, and the requirements of the 2008 Act, the Infrastructure Planning (Environmental Impact Assessment) Regulations (as amended) and best practice.


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i National Grid: Need Case for the South West and the South Wales and Gloucestershire Regions: 2014

ii National Grid : Hinkley Point C Connection, Strategic Optioneering Report: 2009

iii TEP: Route Corridor Study For Public Consultation: 2009

iv National Grid: Hinkley Point C Connection Project, Selection of Preferred Connection Report : August 2011

v National Grid: Hinkley Point C Connection Project, Stage 1 Consultation Feedback Report : August 2011

vi National Grid: Hinkley Point C Connection Project, Bridgwater to Seabank Connection Options Report:

October 2012.

vii National Grid: Hinkley Point C Connection Project, Distribution System Options Report : May 2012

viii National Grid: Churchill/Sandford Grid Supply Point, Substation Siting Study for Public Consultation : May

2012

ix TEP : Western Power Distribution 132kV Route Corridor Study for Public Consultation : May 2012

x National Grid: National Grid Undergrounding Policy: 2009

xi National Grid: Hinkley Point C Connection Project – Stage 3 Consultation Strategy: October 2012 (Update)

xii

National Grid: Hinkley Point C Connection Project – Stage 3 Consultation on Draft Route and Associated

Development: Feedback Report (April 2013)

Documents

6.1 - Planning Inspectorate · 14.1.6 A letter and pack of consultation documents including the Project News, Overview Report, Document Navigation Booklet, DVD, Feedback Form and