Councils have not sought in this document to assess impacts offshore given these do not ... shingle beaches are largely
Examination of Proposals for Galloper
Windfarm
Reference Number EN010003
Local Impact Report Prepared by Suffolk
County Council Ref No. removed and Suffolk
Ref No. removed Coastal District Council
July 2012
GALLOPER OFFSHORE WIND FARM PROJECT:
LOCAL IMPACT REPORT BY SUFFOLK COASTAL DISTRICT COUNCIL
AND SUFFOLK COUNTY COUNCIL
1. INTRODUCTION
i. This report has been compiled by Suffolk Coastal District Council and
Suffolk County Council. It seeks to summarise local impacts arising from
the proposed Galloper Wind Farm (GWF) development onshore. The two
Councils have not sought in this document to assess impacts offshore
given these do not fall within its administrative area.
ii. Both Councils have agreed a Statement of Common Ground (SOCG) with
the applicant and, as such, have tried to avoid repeating information
contained in the SOCG.
2. PROPOSED DEVELOPMENT
The Galloper Wind Farm (GWF) onshore works will consist of:
i. Two compounds: one 132kV GWF compound (170m by 130m (0.2ha) and
one 132/400kV transmission compound approximately 70m by 130m
(0.9ha). Both compounds are located together next to the Greater
Gabbard Offshore Wind Farm (GGOWF) substation. The heights of
buildings will vary, the tallest being approximately 14m high.
ii. Transmission bays located in arable land south of Sizewell Gap.
iii. Sealing end compounds with associated overhead wires next to the
transmission towers adjoining Sizewell Wents.
iv. Onshore cable route 23m to 33m wide depending on installation technique
with 38m maximum working width. Open trenching for most of the route
with three possible locations for directional drilling across Sizewell Beach,
across Sizewell Hall access and across Sizewell Gap Road.
v. Landscaped bund around substation site.
3. CHARACTERISTICS OF SITE AND SURROUNDINGS
i. The site is close to the Sizewell Nuclear site which is set within the Suffolk
Coast and Heaths Area of Outstanding Natural Beauty(AONB) and
adjacent to the Heritage Coast.
ii. The wider landscape around the site consists of a series of locally
characteristic landscape types, as identified in the Suffolk Landscape
Character Assessment, (LCA). www.suffolklandscape.co.uk . The mosaic
of farmland forest and heathlands is regularly dissected by a series of
estuaries and their associated coastal grazing marshes. Furthermore, the
shingle beaches are largely open and unsettled (there are only a few
intensive tourist centres). The coast is often backed by grazing marshes
rising to the farmed and forested landscape to the west.
iii. It is the combination of these distinctive landscape types and their close
relationship to each other that is the most important distinguishing quality
of the Suffolk Coast and Heaths AONB.
iv. The site itself consists largely of arable land and woodland, although some
of the site and associated works will impinge onto the beach. Therefore, in
terms of landscape, the site is principally of the Estate Sandlands
landscape type.
v. The site is visually accessible from adjacent public viewpoints especially
those to the west of the site.
vi. The size and location of the proposal, outside the nuclear power site,
means that it has of the potential to have a detrimental impact on the
character of this part of the AONB.
vii. The site also forms part of a matrix of habitats which together are of
significant value and it is adjacent to nationally and internationally
important wildlife sites.
viii. The site is within the area designated as an Area of Outstanding Natural
Beauty in March 1970. The boundaries of the AONB are based on a
revision of the Hobhouse conservation areas identified in 1947. It was the
plans for the construction of a nuclear power station at Sizewell in 1958
which brought forward the area for designation as an AONB. A draft
boundary was established by the National Parks Commission and East
Suffolk County Council by July 1958. The guiding principle of the final
boundary was that it should encompass the coastal sands crags and
gravels which give this part of the Suffolk coast its particular character. As
the National Parks Commissioner noted at the time “neither forests nor
aerodromes are everlasting”.
viii. The Suffolk Heritage Coast was defined in 1973 by agreement between
the local authorities and Natural England’s predecessor, the Countryside
Commission. The principal purposes of the Heritage Coast are twofold, to
conserve, protect and enhance the natural beauty of the coast, its marine
flora and fauna and heritage features, and to facilitate and enhance the
enjoyment and appreciation by the public.
4. RELEVANT PLANNING HISTORY
The most relevant planning permission relates to the Greater Gabbard
Offshore Wind Farm (GGOWF) which adjoins the site of the proposed
onshore substation. Planning permission C06/2191 was granted for the
onshore works by the District Council on 23 February 2007. The experience of
the construction of this project and its physical manifestation on the ground
has informed both Local Authorities’ approach to the GWF development. In
particular lessons learned from the constructional phase have underpinned
discussions with the GWF Project Team in respect of the proposed landscape
mitigation and aftercare, conditions attached to the draft DCO and the content
of the draft Construction Code of Practice.
5. RELEVANT DEVELOPMENT PLAN POLICIES
i. The statutory Development Plan that covers the application site consists of
the East of England Plan and the Suffolk Coastal Local Plan incorporating
the first and second alterations. Whilst several policies are relevant to the
consideration of the details of the development, those of most significance
to the principle of development are policy AP12 which relates to
development in the Suffolk Coast and Heaths AONB and policy AP98
relating to Renewable Energy. The local authorities are required under the
Countryside and Rights of Way Act 2000 to prepare and revise every 5
years a management plan for the AONB. The current AONB Management
Plan has a role in supporting the Suffolk Coastal Local Plan.
www.suffolkcoastandheaths.org/downloads.asp?PageId=161
ii. The local authorities are satisfied that due regard has been paid to the
policies in the East of England Plan particularly ENV2 Landscape
Conservation and to policies in the Local Plan as set out in the applicant’s
Planning Statement in Document 8.1. Whilst the site for the substation
runs contrary to the principles in policy AP12 in as much as it will have a
significant adverse impact on the AONB landscape it is considered by the
local authorities to be the best available site given the alternatives
considered and discarded as part of the pre-application consultations. In
effect the local authorities have accepted that there is a proven national
need for this development to meet national energy and low carbon targets
and as such every effort should be made to accommodate it.
iii. Having accepted that the substation site is the best option available given
the local circumstances, it is necessary to minimise its impact on the
AONB landscape and to have regard to the need to minimise other
impacts to comply with policy AP98. These issues are looked at in more
detail below. (section 7)
6. RELEVANT DEVELOPMENT PROPOSALS UNDER CONSIDERATION
OR CONSENTED
i. As described in the submitted documents two consented developments
would, potentially, overlap in terms of construction periods with the
onshore GWF construction, namely Sizewell A decommissioning and the
Sizewell B Dry Fuel Store. The Dry Fuel Store was approved by the
Secretary of State for Energy and Climate Change under the Electricity
Act (ref 12.04.09.04/37c). The potential cumulative impacts of these
overlapping construction projects largely relate to traffic on Lovers Lane
and Sizewell Gap Road as outlined in Chapter 25 of the Environmental
Statement (section 25.10).
ii. The consent for the Dry Fuel Store granted by the Secretary of State was
subject to a number of planning conditions that are now the subject of a
submission to the District Council (ref C12/1325/DIS). Details of the
application, which includes additional traffic movements to and from site
and a longer construction period, are available on the District Council’s
web site at:
www.suffolkcoastal.gov.uk/yourdistrict/planning/devcontrol/applications/siz
ewell/default.htm
iii. The application for the Dry Fuel Store is currently subject to public
consultation and has yet to be reported to any decision making committee
of the District Council. The submitted further environmental information
indicates that the construction programme is to be lengthened with an
increase in the overall number of HGV movements to the site.
iv. The main building foundation placement remains the most intensive period
of activity as referred to in the GWF ES (25.10.11). The current
submission reduces the daily maximum 234 HGV movements of the
original application to 106 movements but now over a 16 week rather than
2 week period. The impact is therefore now less intensive than before
although it will be spread over a longer period. The mitigation is still one of
suitable traffic management.
7. LOCAL LANDSCAPE CHARACTERISTICS AND SENSITIVITIES
i. The site of the proposed development is in an open countryside location
close to, but not immediately adjoining, the Sizewell nuclear site. The
proposal will significantly extend the built footprint in the area which has
already been enlarged in recent years by the construction of the Greater
Gabbard sub-station.
ii. Views of the proposed development are available from public locations
and these have been identified and assessed in detail by the applicant in
the EIA. The site is close to the town of Leiston, so Sizewell beach is
particularly important for local users of the coast.
iii. The outline landscaping proposals prepared by the applicant are
acceptable and commensurate with the scale of the proposed
development and sensitivity of the landscape. Lessons learnt from the
Greater Gabbard development highlight the need to ensure the
implementation of the landscaping scheme, and provide a comprehensive
programme of aftercare, to the highest standards. This is essential to
ensure that the planting can become established to provide effective
mitigation.
iv. The applicant has proposed two differing options with regard to the extent
and design of the outer face of the bunding on the southern side of the
site. The option proposed in DWG 2.9a is for a slope on the southern side
of the site with a gradient of 1:10, indentified in Schedule1 of the
Development Consent Order as Work No7. The option proposed in DWG
2.9b is for a slope on the southern side of the site with a slope with a
gradient of 1:16, identified in the Development Consent Order as Work
No8.
v. It is the Local Authorities’ contention that this second option of Work No8,
a 1:16 slope, offers a significant landscape benefit. This is because the
proposal will integrate the bunding fully into the natural contours of the
adjacent land to the south of the site and so minimise the disruption to the
landform of this area. This is a proportionate approach, given that the
proposal is within a nationally designated landscape, in a location where
there are a significant number of visual receptors. Therefore, the additional
land required for this option can be justified.
8. LOCAL ECOLOGICAL CHARACTERISTICS AND SENSITIVITIES
i. The onshore site forms part of a matrix of habitats which together are of
significant value and is adjacent to local national and European designated
wildlife sites. The offshore works are both within and adjacent to the
Special Protection Area (SPA) designated for Red Throated Diver. The
offshore site is also in an area that is key feeding ground for the colony of
Lesser Black-Backed Gulls within the Alde-Ore Estuary Site of Special
Scientific Interest (SSSI). Lesser Black-Backed Gulls are one of the
features for which this SSSI is designated. Protected species are also
present on the site of the onshore development particularly reptiles. The
area in which the onshore site is located is also known to support
extensive populations of bats, although the value of the site itself for bats
requires further clarification. If bats are found to be present on the site, an
appropriate and effective bat mitigation strategy will be required.
ii. We note that the offshore ecological impacts and issues of the proposal
remain unquantified or unresolved, these are; bird strike impacts of Lesser
Black-Backed gulls, the impact of the offshore development on Sabellaria
Reef. However these are not matters on which the Local Authorities have
the capacity to make detailed comments.
iii. The mitigation principles for those reptiles displaced by the on-shore
development have been established and are set out in the Draft Code of
Construction Practice 9.2.18 – 9.2.23. These are considered to be
appropriate.
iv. However a detailed reptile mitigation strategy is still required. We
understand that this is currently being prepared, and that it is the intention
of the applicant that this will be finalised and agreed before the end of the
examination period.
v. It is noted that the draft Code of Construction Practice (9.2.4) states that
there may be a need for 24 hour lighting when the site is operational. The
design and operation of any onsite lighting needs to be such that any
deliberate disturbance of bats is avoided.
9. LOCAL ARCHAEOLOGICAL AND HISTORIC LANDSCAPE
CHARACTRISTICS
i. The onshore site of the proposal is largely within the Estate Farmlands
Landscape Type and is typical of it, in that the pattern of enclosure and the
historic landscape character is of “modern”, rather than “ancient”,
th
th
countryside is, consistent with 18 -19 century enclosure of heath and
th
other open land, and the creation of plantation woodland in the late 19
th
and early 20 centuries.
ii. The on-shore of development is located in an area of high potential for
encountering important heritage assets of archaeological interest, certainly
of local and regional interest. The landscape setting, on a ridge
overlooking Sizewell Belts, is topographically favourable for early
occupation of all periods. Various sites and finds spots are recorded in the
near vicinity and archaeological investigations undertaken in advance of
the on-shore works associated with the adjacent Greater Gabbard
Windfarm in 2007 defined important, and previously unknown, medieval
occupation remains relating to the medieval settlement at Sizewell.
iii. A trenched archaeological evaluation undertaken across the area of the
proposed Greater Gabbard substation has proved the existence of
scattered below-ground archaeological features. The pottery recovered
from the site, although mainly confined in any quantity to one ditch is of
Romano-British date. Finds were conspicuously absent from the
remainder of the features across the site although a sherd of Late Saxon
Thetford ware pottery was recovered from topsoil. Some struck flint of
prehistoric date was also recovered as was a moderate quantity of burnt
flint from a pit, consistent with prehistoric activity. This evaluation defined
archaeological features that will need further investigation, in the form of
full excavation, in advance of development. Full provision for this work is
made in the EIA.
iv. In terms of the overall approach, the Archaeological Service of the County
Council is satisfied with the proposals relating to Archaeology and the
Historic Environment, including the Schedule for Archaeology (25) in draft
DCO.
v. The archaeological consultants for the project have liaised closely with the
Archaeological Service of the County Council during the pre-submission
phase. A common understanding about the potential for, and significance
of, the archaeological remains that will be affected by the development
has been established.
vi. A similar approach was successfully used in the adjacent Greater
Gabbard Wind Farm project (SCDC application C/06/2191/FUL) and SCC
Archaeological Service is confident that the current project can also be
delivered successfully.
10. LOCAL AIR, NOISE AND ENVIRONMENTAL ISSUES
i. There are unlikely to be any significant adverse impacts on air quality in
the local environment. Any impacts from construction activity, largely dust
from earth moving and excavation, can be dealt with by way the
implementation of an agreed Construction Code of Practice to include dust
suppression techniques.
ii.
The local area is rural in nature with low background noise levels. There
will be an increase in noise levels locally arising from construction works,
traffic movements and the operation of the substation. Noise from
construction activities is likely to be limited in its impact provided the
working hours proposed in the DCO are adhered to. The exceptions to the
working hours in paragraph 28 of Schedule 1 Part 3 of the DCO will
inevitably give rise to potentially significant adverse impacts on local
residents and visitors but this will be short lived.
iii. During operations, noise from the substation will have limited impact upon
its immediate surroundings, most notably the public right of way to the
north of the site. There will be negligible impact on the nearest residential
properties provided the noise limits set under Schedule 1, Part 3
paragraph 29 are adhered to.
11. LOCAL TRANSPORT ISSUES INCLUDING RIGHTS OF WAY
i The local road network is essentially rural in character and is limited with
only a single access route (B1125 and C228) to the site and the adjacent
licensed nuclear site, along the C228. This is typical of much of the
coastal strip of Suffolk. This route was brought up to suitable standard as
an access road in preparation for construction of Sizewell B twenty years
ago However the use of this road by heavy vehicles accessing the
Sizewell Power Stations has resulted in some deterioration in the
intervening period. The route bisects the village of Theberton. At this
location the road is subject to a 30mph speed limit. However residents of
Theberton will experience increased lorry movements as a result of this
development, the decommissioning of Sizewell A and the proposed
construction of a Dry Fuel store at Sizewell Power Station and possible
future construction of a new Nuclear Power Station at Sizewell –
Sizewell C.
ii The nearby town of Leiston has narrow streets and is not suitable for use
as an access route to this development. The Developer should take
steps to ensure works traffic and staff commuting to the site should not
use routes through Leiston to access the site
There is an extensive network of rights of way adjacent to the
iii development site and although access to these will not be physically
affected by the proposed development in some instances the visual
amenity enjoyed by users of some routes will be significantly adversely
affected.
iv Specific issues on the access to the transition pits from the junction of
Sizewell Gap Road and Sizewell Hall Road are dealt with under the
County Council’s response to Examining Authority Question 3.10. This
indicates that the detail of the access arrangements at this point in the
draft Construction Code of Practice still remain to be resolved. We
anticipate that this will be finalised before the hearing part of the
Examination.
12. SOCIO-ECONOMIC MATTERS
i. The specialist nature of the wind turbine industry and the location of ports
suitable to accommodate the servicing of the operational phase some
distance from the terrestrial site allied to the limited number of operational
workers mean that the positive impacts on the local economy would not be
significant..
ii. There will a limited impact upon local tourism during the construction
phase arising from disruption to the beach area and the access road to
Sizewell Beach. Controls to working hours will ensure that such impacts
are limited at peak usage periods, on Sundays and Bank Holidays
although the tidally dependant beach works will still be disruptive during
these periods.
iii. During the construction of the Greater Gabbard Wind Farm, concerns
were raised at the way that the company was using the beach, relating to
the period of construction, the area used and the poor restoration. We are
content that, in the context of the Galloper Wind Farm, these issues are
adequately addressed in the draft Code of Construction Practice.
iv. The Local Authorities reserve the right to respond to any answer from the
applicant to Question 15.3 relating to port use for the offshore construction
phase. Depending on the choice of port this may be socio-economic and
transport impacts, as yet unidentified in the submission.
13. FLOOD ISSUES
The landform and free draining soil on the site is such that there does not
appear to be any significant risk from surface water flooding. Although there is
a risk of surface water flooding in the wider area this is largely associated with
the river valleys to the north of the proposed development site.
14. COASTAL PROCESSES
i. Whilst the applicant’s submission (paragraphs 9.4.65 to 9.4.68 of the ES)
suggests that there will be no adverse impacts on coastal processes
arising from the excavation of a cable route across the Sizewell Banks, the
local authorities’’ have concerns that open trenching across the crag may
have an adverse impact on the transfer of sediment along the coast. The
crag is a critical part of the local control mechanism on coastal process at
this point. The applicant should be required to undertake horizontal
directional drilling to avoid any potential adverse impacts on coastal
processes.
ii. There are also concerns that the width of the Order Limit (as shown on
drawing 2.4 Rev 9) adjoining the coastline may prejudice the installation of
cooling water intakes/outfalls from a potential Sizewell C power station
which has been identified as a potential site in National Policy Statement
EN-6. The Local Authorities’ have no wish to prejudge either development
but would like to be reassured by Galloper Wind Farm and EDF
Energy that the two potential uses of this section of inshore coast can
accommodate both development requirements without adversely affecting
coastal processes
