SPS’s written representation has been submitted to the Planning Inspectorate
SPS has set out its concerns regarding the impact of the offshore and onshore substation infrastructure on the landscape and heritage of Suffolk.
The Suffolk Preservation Society (the SPS)acknowledges the important contribution that renewable energy will make towards securing the Nation’s future energy needs and fully accept that this forms part of the Government’s low carbon energy strategy. However, the SPS’s charitable objects charge us with protecting and promoting the special landscape and heritage of Suffolk. We aim to achieve this by ensuring that the heritage, landscape and visual impacts of these proposals are fully identified, critically assessed and where possible mitigated.
Onshore impacts at Friston
The SPS has significant concerns regarding the impact of the selected onshore substation site at Friston on the historic landscape character and the setting of heritage assets. The SPS considers that the Applicant underestimates the contribution made by setting to the significance of heritage assets, relying upon a visual assessment, contrary to Historic England Guidance, which advocates a broader set of criteria including; noise, dust, vibration, light pollution and impact upon the historic relationship between assets. The SPS is also concerned by the inadequate assessment of impacts upon heritage assets during the construction and decommissioning phases, including the impact of increased traffic on the setting of heritage assets along the access routes. We also have concerns about the visualisations which are often highly selective and, in some cases, misleading, resulting in an under representation of impacts.
The SPS is concerned that the potential cumulative impacts of the seven identified connection points (EA1(N), EA2, NG, Galloper, Greater Gabbard extensions, SCD1 and SCD2), singly or in combination, have not been assessed. Friston has been identified as a strategic connection point and the SPS considers that the cumulative impacts of all current and proposed energy projects should be fully assessed as part of this Examination.
The SPS also considers that the scale and character of the proposals is incapable of mitigation and that the historic landscape character of the site has not been fully understood. Moreover, the proposed landscape mitigation at 15 years is over optimistic in view of the dry conditions in this part of East Anglia.
Offshore impacts on the special qualities of the Suffolk Coast and Heaths Area of Outstanding Natural Beauty
The SPS considers that the proposed development within the setting of the AONB will cause significant harm to its special qualities. The proposals would introduce significant industrial development offshore that would be of an unprecedented scale as well as being animated and illuminated. The intrusion into views of the seascape from within the AONB and the negative impact on long views along the coastline will be of such a magnitude that it will run counter to the purposes of the nationally designated AONB. Significant negative impacts will result, most notably on seascape quality, scenic quality, relative wildness, relative tranquillity and cultural heritage qualities.
The SPS considers the proposed mitigation to achieve a degree of separation between the two developments is inadequate and only a reduction in height of the turbines could materially reduce the visual impacts upon the setting of the AONB.