Lionlink - Walberswick Parish Council official response to the Environmental Impact Assessment Scoping Report
Walberswick Parish Council (WPC) has been invited as a Statutory Consultee to respond to the Environmental Impact Assessment Scoping Report (SR) for the proposed Lionlink (LL) project. Walberswick, a pristine, historic village renowned as one of the top destinations for nature-based tourism on the Suffolk Coast, has been identified by NGV as one of its preferred landing sites and cabling routes for LL.
The WPC, with wide support from our village community, has focused its response on the sections of the SR specific to the landing site and the cabling route proposed for Walberswick. This in no way suggests that WPC is supportive of any elements of the scheme nor the soundness of the SR, but rather that we are focusing our submission on the area we know best so as to assist in holding NGV fully to account.
Most critically, we draw the attention of the PIanning Inspectorate to the fact that LL G2 site is in the very heart of Walberswick village. Despite being made aware of this during the pre-consultation stage, the Developer has chosen to submit a SR that misrepresents and downplays the location of G2 – known locally as Manor Field. It is a gross oversight of LL not to state this positioning clearly. As a result, LL has prepared a SR that is inadequate in terms of its approach to the potential impacts that need to be considered and resolved in relation to the Walberswick site.
LL incorrectly states that the site is “south” of Walberswick Village. In another section (6.3.45) it states that homes are located 5m “to the north” of the G2 landfall sites. These are misrepresentations of reality. Manor Field is within the village and, as such, directly abuts and is surrounded by homes not only on the north, but on the north, east and west -- including those within the village Conservation Area. It is adjacent to a seasonal caravan park and camping ground at one corner. G2 is also ringed on four sides by heavily used Public Rights of Way (PRoWs) that lead to the popular Walberswick swimming beach and that are part of nationally recognised walking trails that connect Dunwich, Walberswick and Southwold. It is adjacent to, and will have to cross, highly protected SFA, SAC and RAMSAR sites. There is no road access to the G2 site not because Manor Field is remote, but because it is a beauty spot that is an integral part of Walberswick village, accessed by PRoWs and by back garden gates of the houses on which it abuts.
Because of this unique situation, we request that the inadequacies of the SR be challenged robustly in relation to the Walberswick G2 option. LL states in 10.5.3 that “where it is not possible to avoid sensitive receptors, a number of measures will be embedded into the design to limit any effects.” Specifically, LL says that “where possible, the proposed Onshore Scheme would be designed to avoid residential properties, community facilities and amenities as well as visitor attractions.” We cannot understand why LL would have made such an inappropriate choice as G2 given that it directly contradicts its own stated design imperatives. However, as LL has chosen to persist, then it must be compelled to Scope-In more impacts and, where impacts are Scoped In, should not be permitted to use “desk studies” for baseline data or to understand likely impacts. Instead, LL must base its analysis on appropriate bespoke surveys, interviews and case studies. The analysis should properly be done to cover a period of a year to take into account the differing seasonal impacts on the residential properties, amenities and attractions, particularly given that the basis of the Village’s economy is on year-round nature-based tourism.
Within this context, the remainder of our submission highlights by Chapter the specific areas of concern and where amendments are required.
Chapter 3. Assessment of Alternatives
The first step should be in relation to Chapter 3 of the SR that deals with the assessment of alternatives. Given that LL has identified a preferred site in Walberswick that is within a residential area, with community amenities and visitor attractions, it needs to make much more transparent why they are dismissing more reasonable alternatives including an Integrated Offshore Grid, landfall at brownfield sites, or co-location with other interconnector and offshore projects. There are sentences in the SR (such as 6.3.45) where LL admits that G2 is within 5m of residences. Without much greater detail and transparency with respect to alternatives, it is impossible to determine whether there truly are no better alternatives to putting the landing site into the heart of a rural community surrounded by human and ecological receptors and within 5m of village homes.
Chapter 4. Legislation and Policy Overview
Table 4.1 references several local planning documents. However, it leaves out the Conservation Area Appraisal and Management Plan for Walberswick and the Walberswick Parish Plan. Walberswick Parish Council is also engaged in the process of a Neighbourhood Development Plan. All these relevant documents must be used to better inform the EIA. Walberswick documents can be provided to LL by the Parish Council.
Chapter 5. EIA Method and Approach
Population size is a key element in impact analysis particularly on human receptors. It is obvious from the SR that LL’s approach will not accurately reflect this impact in Walberswick if it relies solely on ONS census and other public source data. For the G2 site, it is essential that data and analysis is complete given that the site is within a residential area. In addition to homes and ProWs which are within 5m, the tourist beach is only some 65m from the site. Walberswick’s only main road, its village shopping, and many historically significant homes in the Conservation Area are within 100m of the landing site and because of its compact design, the majority of the village including playgrounds, village hall and all amenities are within 500m of G2.
Walberswick has circa 350 homes. About half are occupied by full time residents with others used by part-time residents most of whom stay in the village throughout the year but who are not likely to show up in ONS data. Another portion of the residences are used as holiday lets many of which are large and therefore accommodate in excess of 10 guests. There is also hotel accommodation at two pubs and camping and caravan grounds. In addition to those who stay in the village, data available from the Parish Council in its pre-consultation submissions provides evidence that Walberswick has up to 200,000 day visitors annually coming by car and bicycle and on foot. This means that the actual number of people staying in the village, and exposed to the impacts of LL construction, is many multiples higher than the census data and the preliminary population figures provided in the SR would suggest. Given that LL is breaking its own design requirements by suggesting a landing site within a residential area and within close proximity to major recreation and tourism sites, it must be required to collect correct data on human receptors beyond ONS data sources in order to get an accurate and more granular baseline. This is particularly essential for ensuring proper baseline data in areas that study impacts on human receptors including Chapters 6, 10, 14, 15 and 16. The Parish Council can assist LL in providing some of the relevant data necessary to make a more accurate assessment and analysis.
Chapter 6. Air Quality
We note that the SR scopes in most impacts, but the choice of language appears to downplay the potential risks. This is notable in section 6.6.9 that states: the risks from the impact of construction dust on ecological and human receptors has been scoped into the EIA on the basis that there is potential for significant effects due to proximity of both ecological and human receptors to the proposed Onshore Scheme. However, the impacts will unlikely be significant with the implementation of suitable mitigation measures. We believe that “lack of significance” does not reflect the reality in Walberswick given that G2 selection is contrary to LL’s statement in 6.5.3 that “The design of proposed Onshore Scheme will seek to avoid sensitive features such as larger residential areas and ecological designations.” As the nearest residences are a mere 5m from the landing site, and the most protected of ecological sites similarly border the landfall construction site, then LL fails in implementing its design measures making its Control Measures listed in 6.5.4 likewise insufficient. Therefore, in all its Air Quality assessments that are Scoped-In, it should be assumed that the impacts at G2 could be significant and therefore techniques for assessment must always take a precautionary approach and be at the highest possible standards and sensitivity. For example, meteorological impacts must be assessed for the actual conditions present seasonally and in relation to the impact, for example, of the common occurrence of storms and very high winds that impact the G2 site whilst not necessarily present inland.
Chapter 8. Ecology and Biodiversity
Given the sensitivity of the G2 landing site and parts of the cabling route, we feel that the SR is deficient in its approach to ecology and biodiversity. We set out below our chief concerns in relation to this section of the SR:
Within Chapter 8, the issue of undertaking a Habitats Regulations Assessment (HRA) is assigned two small paragraphs (8.2.2 & 8.7.20); yet crossing the Walberswick-Minsmere SPA, SAC and Ramsar sites (International Sites to which HRAs relate) is unavoidable at the G2 landing site and terrestrial cabling route. Paragraph 8.7.20 acknowledges that Stage 2 of an HRA (Appropriate Assessment: AA) will be required. The AA could well demonstrate a likely significant effect on the International Sites that would require a derogation from the Habitats Regulations (2017) (as amended). Test 1 of the Derogation states the following:
Test 1: Consider alternative solutions
To allow a derogation you must decide that there’s no alternative solution that would be less damaging to the site. You should work with the proposer and consider whether any alternative solutions are available. This might include considering whether the proposal could:
· happen at a different location
· use different routes across a site
· change its scale, size, design, method or timing
As pointed out in our comments to Chapter 3, currently only two alternative solutions are put forward -- the Walberswick and the Southwold landfall sites and associated cabling routes. There are clearly other viable alternatives, such as an offshore grid, brownfield landfall, co-location of cables, etc and more information is required to be able to comparatively assess the ecological impacts of each viable alternative. To date, this evaluation has simply been presented in a cursory manner. As this will need to be properly and fully evaluated within the HRA, the absence in the SR of geographical scope and methods by which this will be done should be corrected and the methodology included.
- We note that the evidence requirements for the AA stage still needs to be agreed with Natural England under the Discretionary Advice Service (DAS) agreement to produce an Evidence Plan. Yet the SR gives no details of what this Evidence Plan may include, or when, where and how the Evidence Plan will be made available for consultation. This omission makes the scoping of the HRA within Chapter 8 woefully inadequate and this needs to be included in the SR. Specifically, it should set out how and where the Evidence Plan information will be disseminated.
- An overarching issue in this Chapter is the lack of detail on survey methods to be employed. We understand that the survey scope and design will be refined as the project advances in consultation and agreement with Natural England (per 8.2.3, 8.3.58 & 8.7.5). However, we would expect that other statutory consultees, including the parish councils, be kept informed of any decisions as they arise. The SR is inadequate in this regard and specifically how and where this information will be disseminated should be added.
- The geographical scope of LL’s ecological assessment (Section 8.3) is inadequate to allow a full and satisfactory HRA/AA to be carried out. We suggest that there be a re-evaluation of the Ecological impact Assessment (EcIA) and HRA scope and that this be strengthened in the SR.
- The SR is inadequate in terms of the details on the methods and locations of surveys to allow full and proper assessment. In particular, more details need to be added to the SR for target bird species surveys (8.37, section 8.3.47), otter surveys and invertebrate surveys. If this information is not currently available, then details of specifically how and where this information will be disseminated should be added to the SR.
- The SR is incomplete in presenting the qualifying species for the SPA and Ramsar nor is this topic consistently presented throughout the SR. Species such as little tern, avocet and nightjar have been omitted in parts (Table 8-2; paragraphs 8.3.44 & 8.3.45). This omission needs to be corrected. The suite of qualifying Annex 1 species (Table 8-2) now includes woodlark as detailed in the following SPA factsheet: https://assets.publishing.service.gov.uk/media/5dc1504be5274a4aa00642a2/Minsmere-Walberswick_SPA_factsheet.pdf This update, however, is not reflected in the SR and needs to be updated throughout with survey scope and methods adapted accordingly.
- No specific mention is made to several key rare and notable invertebrate species occurring within the Walberswick cabling route boundary (see Paras 8.3.88-8.3.92). This includes wainscot moth species group, spotted-wing antlion Euroleon nostras, and starlet sea anemone Nematostella vectensis. These species need to be scoped in as they may be affected by impacts on the water quality and levels, by trenching and tunnelling impacts, and by exacerbated coastal erosion.
- We note that artificial lighting at night (ALAN) impacts have been scoped out as LL claims that only emergency lighting will be implemented (8.54). However, given the highly sensitive nature of the G2 site and the possibility that ALAN is not properly documented in the Construction Management Plan, these impacts should be scoped-in as a precaution.
- Chapter 8 does not identify contamination or coastal erosion as being within the scope of the terrestrial ecology and biodiversity assessment. Yet trenching of the landfall section between the landfall site G2 and offshore would inevitably lead to a high risk of contamination and erosion impacts. Even where horizontal directional drilling (HDD) is implemented, we understand there are associated risks that can lead to water level disruption and surface contamination due to cracking and leakage of mud-slurry lubricating material, and possible indirect coastal erosion impacts. We are particularly concerned by the impact the proposal will have on the Annex 1 habitats and species through direct and indirect disturbance, coastal erosion and hydrological disruption potentially leading to changes to the coastal habitats, salinity and water levels, which are known to affect key protected features. We note that these issues are discussed in Chapter 18 and in a separate technical report (para 9.6.2). However, given these potential impacts could occur within the Walberswick landfall zone, they need to be addressed and scoped in at Chapter 8.
Chapter 10. Health and Well Being
Without repeating statements made in other sections of this response, we note that effort needs to be made to improve the baseline data and population information stated in this chapter. (see comments to Chapter 5). In addition, because the G2 site does not conform to LL design parameters in its location within the village, then the greatest level of precaution should be taken in relation to health and well-being of those impacted. Therefore, we believe that it is incorrect to scope out the disturbance or release of contamination in soil or groundwater that can result from construction activities given their potential to affect health. We believe that it is not sufficient to Scope out this impact by saying in Table 10-1 that “best practice control measures set out in a CEMP or Outline Code of Construction Plan (CoCP) will prevent uncontrolled releases of contamination. With these measures in place, the risk of exposure to soil and groundwater contamination will be prevented and adverse health effects will be avoided.” As the location of G2 already appears to violate best practice, then we believe that it is incumbent on LL to recognise that there is the possibility of exposure given the extraordinary closeness of residences and recreation areas. This possibility must be of overriding concern and therefore the impact must be Scoped-in.
Chapter 12. Hydrology, Hydrogeology and Drainage
We note that the SR does not contain any consideration of coastal flood risk and/or the effect of LL (onshore and offshore) on natural sea defences such as coastal margin habitats and saltmarsh. These features are very much prevalent in Walberswick. Moreover, as there is high probability and high potential magnitude of coastal flooding events here, this appears to be an oversight and needs to be scoped in as a likely significant effect for further assessment.
Chapter 14. Noise and Vibration
The siting of G2 in the heart of the village means that EIA related to impacts of Noise and Vibration need to be particularly robust. In 14.5.3, LL again states that its design measures will be such as to select sites to minimise the number of human receptors and yet, by choosing G2, LL has failed to do so. In 14.7.22, LL states that where residential receptors are identified within 1000m of any new noise sources, an assessment will be undertaken in line with BS 4142. It should be noted that the entire village of Walberswick is within this distance from the landing site including all shopping, pubs, village hall, residences, village green, playgrounds and summer camp, playing fields, PRoWs and heavily used beaches.
Section 14.3.3 suggests that a study area of 300m around the Onshore Scoping Boundary is necessary to assess construction noise impacts based on precedent from other projects
and the limitations of prediction methods beyond this distance as noted in the British
Standard BS5228. As above, it should be noted that Walberswick’s main shop, pubs, residences including listed buildings, beaches and PRoW easily fall within this boundary.
Finally, for potential construction vibration impacts, the SR states that an area of 100m is considered to be sufficient to assess potential construction vibration impacts. Because of the inappropriateness of the G2 landing site and the early stages of the cable route, 100m takes in, among others, a large number of homes within the Conservation Area, the main village shops and holiday lets, all of which will be directly susceptible during construction and recovery and must be studied to assess impact and mitigation.
Chapter 15. Transport and Traffic
This chapter is particularly lacking in candour in relation to the constraints of the Walberswick G2 site and cabling route and therefore has erroneously scoped out some essential elements. Specifically, LL states in 15.4.2 that adverse impacts could arise from inter alia: “increased traffic volumes and congestion due to construction traffic; abnormal load deliveries and temporary diversion of traffic due to road closures/diversions.” In 15.5.4, it states that “where road closures are required, the period of the closure would be kept to a minimum and diversions would be via the most appropriate alternative route. Access to properties would be maintained at all times.”
However, the SR fails to note and address that Walberswick is only accessible by vehicle via a single road. Therefore, LL cannot keep the commitments it makes in 15.5.4. Whilst Table 15.2 scopes in the effect of construction traffic on road users and the general public arising from construction, it has incorrectly scoped out the impact of closures/diversions for abnormal load access or other incidents that would close the road. LL cannot scope out these impacts by claiming that they will occur in off peak times or that alternatives will be made available. The fact is that there are no alternative routes to Walberswick and therefore any closure, at any time of the day, planned or unplanned, will deny access to emergency services and deliveries and would potentially deny residents access to their homes and/or visitors ability to leave. Given this extremely precarious and dangerous situation, all impacts related to potential road closures must be Scoped-In for G2 and evidence provided for safe mitigation.
Chapter 16. Socioeconomics, recreation and tourism
The approaches proposed in this chapter are some of the weakest in the SR and are particularly inappropriate to the proper assessment of the Walberswick G2 proposal. The weakness in the proposed assessments appears connected to LL’s failure to properly identify G2 not only within a village, but within a village whose economy is nearly entirely based on nature-based tourism around its beautiful natural beach, extensive walking trails, pristine landscapes and wildlife, quaint village life and beautiful views. In fact, PRoWs at the G2 site are particularly prized as they provide the best viewing points for the largest continuous stand of reedbeds in England and Wales (part of the Minsmere-Walberswick Ramsar site).
We have attempted below to point out the most critical shortcomings that need to be addressed:
- 16.3.10 improperly fails to recognise socioeconomic recreation and tourist (SRT) assets that fall easily within 500m of the landfall site and cabling route. These include tourism and recreation-based businesses, visitor attractions, playground, heritage assets, beaches and PRoWs. These need to be included and factored in assessment of SRT impact.
- Table 16-5 has left out several important community facilities for Walberswick including the Village Hall, the Walberswick Beach, PRoWs , and camping sites. This oversight needs to be corrected and factored into assessment of SRT impact.
- Table 16-8 scopes out the effect of construction on residential property (both direct and indirect). This is clearly incorrect given that G2 is surrounded by homes within 5m of the site. Similarly, it is wrong to scope out the effect of construction on tourist accommodation and businesses because of the exceptionally close proximity (for example within the 100m and 500m buffers) of accommodation and natural attractions. Therefore the SR should be amended to Scope-IN these impacts.
- The impact on tourist accommodation of construction workforce has been scoped out on the argument that workers will come from nearby. That is not at all likely given the low unemployment in the area, the competing energy projects including Sizewell C and the generally older demographic of the area. Therefore, this impact should be scoped in for the LL proposal as a whole.
- Given these and other shortcomings in the quality of the SR in relation to SRT, it is incorrect for LL to suggest in 16.7.1-3d that it can adequately assess impacts based on desk studies. Given the inaccuracy of its information in the SR pointed out above and the very significant potential for the scheme to produce negative effects, the assessment needs to make use of surveys, interviews and other bespoke means to properly baseline, assess and mitigate.
Conclusion
In summary, among other shortcomings, we believe that the selection of the G2 site makes it impossible for LL to meet the standards and commitments it has set out in the SR. This argues for ensuring that LL proceeds with the utmost precaution by maximising throughout the EIA what is “Scoped In” and, in full acknowledgement of the inappropriateness of the Walberswick site, fully investigates, analyses, justifies, and demonstrates the ability to mitigate the impacts of its proposal.