Formal complaint to the consultation process for NGET Sea Link
Subject: Formal complaint to the consultation process for NGET Sea Link
Dear complaints department
Saxmundham Against Needless Destruction (SAND) is a community group (with over 200 members) established in NOV 2023, focusing on providing information and raising awareness of the devastating impacts caused by the energy infrastructure projects to the affected communities in Saxmundham, Sternfield and Benhall, Kelsale cum Carlton. The group also promotes offshore solutions and landfall at existing brownfield sites close to demand. SAND is affiliated with Suffolk Energy Action Solutions (SEAS).
We would like to raise a formal complaint regarding the consultation process for Sea Link.
Under consultation law, a consultation may only be considered legitimate if the four rules of the Gunning Principles are met, and NGET’s consultations for Sea Link have not demonstrated this.
We would therefore like to lodge a formal complaint that NGET have not followed the Gunning Principle for the consultations, based on the following:
1. As requested by your numerous consultees and stakeholders, you have not provided any thorough evidence of the offshore grid solution being properly assessed.
2. You have not provided adequate timing to your consultees for their considerations, by scheduling the latest July 2024 consultation during the summer holiday time, when people will be away on vacation and only providing 4 weeks. Your statutory consultation in Oct 2023, was timed in the run up to the Christmas period when communities were busy and could not focus on digesting all the information. Your public information exhibition in Saxmundham was on the 24 Nov 2023, which then only provided 3 weeks for the communities to submit their responses before the deadline.
3. The insufficient timing for consideration for the July 2024 consultation is exacerbated by NGV / Ofgem Nautilus Project Consultation which is a mere 4 days after the Sea Link deadline.
SAND Response to Sea Link July 24 Consultation
CONTENTS
Below headings have been based on the Additional PEI – Executive Summary but not limited to.
1. Introduction
2. Refinement to the construction compound on land south of North Warren Royal Society for the Protection of Birds (RSPB) Reserve and Sandlings SPA & & Alteration to the cable route north of Aldeburgh.
3. Landscape and Visual - modified western access route inclusive of bridge design.
4. Additional land included within the draft Order Limits along the banks of the River Fromus.
5. Temporary overhead line diversion, including temporary pylons or Masts at Friston Substation.
6. Plans to allow construction to take place 7 days a week – including Sundays and Bank Holidays.
7. Changing of Draft Order Limits
8. Conclusion
9. Appendices
1. Introduction
Saxmundham Against Needless Destruction (SAND) is a community group (with over 200 members) established in NOV 2023, focusing on providing information and raising awareness of the devastating impacts caused by the energy infrastructure projects to the affected communities in Saxmundham, Sternfield and Benhall, Kelsale cum Carlton. The group also promotes offshore solutions and landfall at existing brownfield sites close to demand. SAND is affiliated with Suffolk Energy Action Solutions (SEAS).
We fully support the response compiled by Suffolk Energy Action Solutions (SEAS)
SAND strongly objects to the current Sealink project proposals because these are the WRONG PLANS and in the WRONG LOCATIONS.
The proposed converter station(s), Western access road and bridge are totally inappropriate for the rural setting and in the wrong location.
By altering your original Draft Order Limits, NGET have removed the need to account for the cumulative impacts of all 3 proposed energy infrastructure projects (Sea Link, Lion Link and Nautilus) which is underhand and disingenuous.
Furthermore, it is questionable if the Sea Link project is at all needed since it appears to be only diverting energy to Kent.
It would seem NGET are determined in destroying our Suffolk countryside and heritage coastline when there is a better alternative option for electricity transmission in the form of developing an offshore grid, pooling energy to brownfield sites closer to demand.
Similar solutions are being implemented by other North Sea European countries and they have been proven to be successful.
With regards to changes in the latest consultation below are our comments and responses:
2. Refinement to the construction compound on land south of North Warren Royal Society for the Protection of Birds (RSPB) Reserve and Sandlings SPA & Alteration to the cable route north of Aldeburgh
The Suffolk coastal area is unusually rich in biodiversity and is one of the last habitats for numerous red-listed species. The SSSIs of coastal Suffolk are linked, and are protected to some degree by the AONB rules (NSP-EN-1 applies) and ad hoc diversity corridors linking designated areas despite industrial agriculture. Multiple projects will compromise all of this.
North Warren was acquired by the RSPB in 1939 so has been a safe home for wildlife for 84 years. The Haven, lying between North Warren and the sea is a Site of Special Scientific Interest.
In this latest consultation, there is no publications of the findings of the latest ecological surveys which were conducted between April and June 2024. In the PEI, it is only noted that surveys are ongoing and reports of completed surveys are being completed. There is therefore inadequate evidence that the rare and special ecology and biodiversity will not be impacted.
3. Landscape and Visual - modified western access route inclusive of bridge design
None of the access routes initially identified by National Grid were viable because it is the site selection itself that is fundamentally flawed. It is not possible to access such a major construction hub at Wood Farm without encountering insurmountable environmental and visual damages.
The dual lane haul road, large bell mouth entrance and an enormous concrete bridge (6M tall x 150M plus long) are inappropriate and incongruous structures for a rural landscape adjacent to a nationally important Grade II listed asset and its setting.
The proposals will cause significant harm to the protected views of Hurts Hall across to the Grade II* Listed St John the Baptist Church and landscape character of the Fromus Valley. The proposed road and bridge will cut through mature woodland and will require the felling of old beech & oak trees and a horse chestnut tree which has been described by the East Suffolk Council Principal Landscape and Arboriculture Officer as having “exceptional qualities”. It is apparent that NGET had not surveyed the site properly.
In your Additional PEI Report, in your team’s own admission the road and bridge will cause “significant adverse effects”.
In addition, SAND & SEAS have commissioned Michelle Bolger to conduct a Landscape and Visual Review of the latest changes documented within in the latest consultation.
Refer to Appendix 1:
Michelle Bolger’s Landscape Briefing Note 1278 BN01 – Landscape Review
NGET should therefore find a more suitable converter station site and new access route that are less harmful to their surroundings.
4. Additional land included within the draft Order Limits along the banks of the River Fromus
The additional land has already been substantially planted by the landowner and therefore should not be counted towards the 10% biodiversity net gain (BNG) requirement.
5. Temporary overhead line diversion, including temporary pylons or Masts at Friston Substation
Initial planning consent for the substation at Friston was originally intended to support the Scottish Power EA1N and EA2 wind farms and was not intended for Sea Link, Nautilus and Lion Link, with their associated converter stations at Saxmundham.
The additional temporary pylons will further exacerbate the impacts to Friston.
6. Plans to allow construction to take place 7 days a week – including Sundays and Bank Holidays
The proposed introduction of core working hours to include Sundays and bank holidays shows NGET’s total lack of consideration and respect for impacted communities, which is shameful. It is completely unacceptable.
Under the Town and Country Planning Act and the Control of Pollution Act, working hours for any construction within close proximity to residential areas are restricted to;
· Monday to Friday: 8am to 6pm
· Saturdays: 8am to 1pm
· Sundays and bank holidays: No work permitted and noisy work prohibited
Why does NGET considers it appropriate to circumvent this basic consideration to the affected communities?
7. Changing of Draft Order Limits
In the Project Update Document, it is noted that one of the reasons for the Saxmundham site selection was because of its capacity to accommodate further converter stations.
As noted previously by altering your original Draft Order Limits, NGET have removed the need to account for the cumulative impacts of all 3 proposed energy infrastructure projects (Sea Link, Lion Link and Nautilus) which is underhand and disingenuous.
Colocation of these massive energy infrastructures is only appropriate in a brownfield location and not on a “good” arable farmland close to a small rural market town. It is evident that the proposed site is in a wrong location which is demonstrated by the numerous “significant adverse effects” that has been reported within the PEI. The projects are being forced into unsuitable and inappropriate sites.
The cumulative impacts must be considered on all the current energy projects (Sea Link, Lion Link and Nautilus) and the PEI Reports and consultations should reflect this.
8. Conclusion
NGET claims that "Sea Link is due to carry electricity from where it is generated to where it is needed", however if this is the underlying purpose, the wind farm energy should be transported from where it is generated in the North Sea directly to where it is needed in South East England using HVDC cables, without the unnecessary diversion via East Suffolk, saving on unnecessary onshore infrastructure.
Electrical Infrastructure on this scale is completely inappropriate for a greenfield site on the borders of a residential market town and rural villages. The excessive adverse impacts on East Suffolk of pursuing the development of Sea Link, Lion Link and Nautilus should be avoided by developing a strategic offshore grid with conversion at coastal brownfield sites close to demand.
Nature based tourism is vital to the local economy and economic growth in East Suffolk and this is at risk of irreparable damage if NGET’s energy infrastructure proposals for the region proceed.
The environment must be protected and siting major electrical infrastructure in East Suffolk that is threatening the Heritage Coast with irreversible industrialisation, will inevitably damage permanently the richly biodiverse ecosystems that flourish in this rural countryside setting.
It makes no sense to cause such needless destruction in East Suffolk when there is a perfectly viable alternative solution in the form of an offshore grid with conversion at brownfield sites.
The new Labour government and NGET should look at a more holistic approach to energy transmission and conversion and deliver a long-term legacy for the country.
9. Appendices
Appendix 1 - Michelle Bolger’s Landscape Briefing Note 1278 BN01 – Landscape Review