Response of Walberswick Parish Council to Lionlink Statutory Consultation
Closing Date 10 March 2026
Walberswick Parish Council has now formally submitted its response to the Lionlink Statutory Consultation and it can be seen below. The Parish Council urges everyone to submit their own objections to Lionlink before the closing date (10th March 2026) and we are happy for anyone to use any of the points from our submission, but please make the response you own; do not just copy and paste the whole of the Parish Council response as complete duplicates risk being ignored. It is perfectly fine to use the Lionlink form to respond if you want to, or email is equally valid and should be sent here: info@lionlink.nationalgrid.com
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1. Walberswick Parish Council ("WPC") are writing in response to the Lionlink (“LL”) Statutory Consultation. WPC has decided not to use the LL consultation form as it does not provide adequate cover of the issues we wish to raise. We instead submit this document.
2. The bulk of our response relates to the specifics of the Walberswick Landfall site and cabling route as this is the area we know best and LL’s landfall proposal is a particular threat to the well-being of our village. NGV’s proposal that Walberswick can absorb up to two years of night-lit construction, noise, heavy works compounds, and coastal disruption without severe economic and wellbeing consequences is indefensible. We object to the proposal in the strongest terms.
3. Beyond the landfall, our concerns and objections also relate to the entire LL proposal. As we set out below, we object to the specifics of LL proposal for the converter station in Saxmundham. We also object to the connection at the substation in Friston as this project should not be located in coastal Suffolk. We believe that there are far better and less damaging solutions.
I. LL’s Approach to Non-statutory and Statutory consultations
4. We have had many exchanges prior to this consultation with LL on the responsiveness to community concerns and the way these have been communicated. Whilst LL personnel have been polite and respond punctually and regularly to emails, it is an enormous frustration that nothing we explain nor share seems to make any difference to LL’s plans. In fact, following each set of non-statutory consultations, the impact and costs put on Walberswick got progressively worse. Since the day that we became aware of Eurolink (renamed Lionlink), we have expressed how incredulous we are with the inclusion of Walberswick on the list of possible landfall sites. The one and only time there was an honest response from LL on how Walberswick could have been included was during the first Eurolink webinair when the Dutch engineers admitted that they had absolutely no knowledge of the Suffolk Coast and had simply dropped a pin in a place that “looked close”. That place just happened to be Walberswick.
5. Since that time, every comment provided to LL from the highest local authority (the MP, Suffolk County and East Suffolk) to the smallest individual voice has said the same thing -- that the landfall site must not be Walberswick. These comments numbered in the thousands because it is inconceivable that LL could consider industrialising a pristine internationally protected coastline of SSSI, SPA and RAMSAR and turn the centre of a historic, thriving and unique nature and tourist-based economy village into a construction and drilling site. And yet, here we are with NGV saying its landfall site is Walberswick and that the costs and damage will be borne by the community and by the environment, whilst the benefits will be reaped by NGV and its shareholders.
6. Given LL’s history to date, we found the language used by NGV in the PEIR literature about its desire to “listen” to the community in these statutory consultations disingenuous. To date, “consultations” have proved to be nothing more than performative. We hope that this time will be different and that NGV will now truly listen, react and pursue a fundamental change from its current disastrous course.
II. Overall Case Against LL in Suffolk Coastal
7. NGV’s entire approach appears to be based on one simple, and easily rectifiable choice made back in 2017. That is, NGV states that it was given provisional approval at that time to bring its Dutch interconnector to a substation in “the Leiston area”. Tying everything back to that one decision simply ignores how many things have fundamentally changed since that time. The PEIR makes scant attempt to admit and address these changes which include:
· There are better, proven offshore options in practice on the European side of the North Sea, including by LL’s Dutch partner TenneT, but are being ignored by the British partner NGV.
· There are better, proven brown-field options, including at the Isle of Grain which the Dutch partner supported in the earlier BritNed interconnector but are being ignored by NGV with LL.
· That the location “near Leiston” is now an area totally dominated by the construction of the Sizewell C (SZC) nuclear plant which is the biggest infrastructure project in the UK and did not exist in 2017. The construction of SZC, which will continue for a minimum of 10-12 years, has barely begun but has already overloaded road and rail infrastructure in the entire area. LL’s schedule coincides with the peak work on SZC and therefore cannot be delivered without introducing very high construction and cost risks to both projects, not to mention the community impact.
· That the consent for the Scottish Power (SPR) converter station in “the Leiston area” was given on very tentative grounds with warnings that the impact was almost too severe to approve – clearly indicating that there was no room for additional infrastructure in the same small area.
8. The failure of LL and NGV to address these massive changes in circumstances is presumably what has led to the bizarre choice of Walberswick as the only possible landfall site. Rather than trying to defend the indefensible and hide the reality of LL’s impact, NGV and NESO must go back over this location proposal made nearly 10 years ago and find a more appropriate location for its interconnector. This is not only an issue for the Suffolk coastal region, but for the national good as well.
9. In addition to these changes on the ground, a new argument against LL in Suffolk Coastal is the ongoing situation with SeaLink, which, in its DCO application, is seeking land to “co-locate” its substation with LL. It has been made abundantly clear during the DCO process that that there is no need for SeaLink. NGV will be aware of this from the submissions made through the examination of the Sealink DCO. These comments would (or should) have been well known to NGV before NGV finalised its LL PEIR. Moreover, SeaLink has now had to come clean on the inappropriateness of the Saxmundham converter station location and its inaccessibility using the Benhall Railway Bridge. LL should not have proposed this same Saxmundham site in its plans given that the constraints faced by SeaLink are the same for LL. Similarly, at the hearings for Sealink, the developer had to show the true visual impact of the converter station in situ. These bear no resemblance to the gentle, tree covered drawings LL has included in its PEIR materials demonstrating that LL is covering up the true long-term impact of its converter station. Therefore, rather than limiting impact through its “co-location” of its sub-station with that of SeaLink, LL is actually doubling down on the problems already exposed for SeaLink. This is inexcusable.
10. The solution is clear. LL should come ashore in a brown field site closer to where the power is needed. The most obvious location would be at the Isle of Grain where an interconnector from the Netherlands (BritNed) already exists and where the newest interconnector from Belgium (Nautilus) will be located. Isle of Grain is already a mature energy hub with far lower marginal societal and environmental costs then the Suffolk Coast. It is extraordinary that Nautilus, which like LL was originally planned for the Suffolk Coast, rightly changed its location to Isle of Grain whilst LL never considers this in any meaningful way despite it being the obvious and best way forward.
11. Siting, Routing and Discounted Options The irrational choice of Suffolk Coastal for LL then leads on to the PEIR’s litany of mistakes, misstatements and white-washing of the true impacts on Walberswick as a landfall. This comes out clearly in the Siting, Routing and Discounted Options section of the PEIR. Basically, by choosing Suffolk Coastal as its universe of choice, LL has no good siting and routing options, particularly, as pointed out above, with the construction of SZC underway leaving nowhere for LL to sensibly land its cable, build a sub-station and make its way to Kiln Lane converter station.
12. Given this situation, LL was left with a risible list of landing options, including Southwold, Leiston, Dunwich and Walberswick. One by one, LL discounted one inappropriate option after another for any myriad list of reasons. However, once NGV turned its focus on its preference for Walberswick, it is shocking how the concerns highlighted in the rejection of other sites are left unaddressed or dismissed when they arise in Walberswick. For example, if concerns about the impact on internationally protected sites are used to reject other locations, then the same concerns should have discounted Walberswick. If LL was swayed because it would disturb a car parking area in Southwold, then it cannot be silent on LL disturbing every business in Walberswick. If heritage concerns contributed to the rejection of Dunwich, similar heritage and archaeology should have discounted Walberswick. For Aldeburgh, it is still not clear how a landing site that SeaLink is pursuing should be excluded by LL on the basis of offshore concerns. LL’s defence about “coming from the north” as opposed to “coming from the south” convinces no one with expertise as routes around obstacles exist. This is not at all to argue for the SeaLink route as that ill-conceived project is being proved to be unnecessary, unworkable and overly damaging as thousands of documents at the Examination of its DCO demonstrates. But the point is that Walberswick exists as the “preferred route” only because all the routes and landing sites are ill-conceived and, as set out in the rest of our response, LL’s PEIR conveniently ignores or fails to assess the negative and severe impacts of its Walberswick proposal that should certainly have discounted it as a landing site as well.
III. WALBERSWICK IS CATEGORICALLY NOT A VIABLE LANDING SITE
13. Walberswick is: (i) The only option where the landing site is squarely within a settlement area and in immediate proximity to homes and vulnerable populations, (ii) served by a single, fragile access route (B1387) with no diversion possible, (iii) identified in LL’s own PEIR as having significant landscape, health and amenity impacts. These issues are taken up in turn in the remainder of this response.
TRAFFIC/TRANSPORT
14. Although NGV acknowledges that there will be significant construction impacts on local roads (including the B1387, Lodge Road) and Public Rights of Way around Manor Field and the Marshes, the PEIR contains no supporting facts or figures on traffic types, movements, volumes or congestion modelling to justify its choice nor to allow meaningful consideration of what these impacts will be.
15. What we have learnt in speaking with LL, however, is that they in fact will have to depend on B1387 to reach very close to the landing site rather than using a haul road from the A12 or the B1125, which was one of their rationales for choosing the Walberswick Landing site compared to other locations. This is because what would have been a haul road route is blocked by a substantive SSSI (Sallow Walk) along the route into Walberswick. Obviously, this SSSI is not new and was pointed out to LL during the non-statutory consultations as one of many reasons why the Walberswick site was inappropriate. Therefore, NGV appear to be falling back on the B1387 even though this is the one and only route in and out of Walberswick. LL itself admits that its HGVs cannot pass one another on the B1387 and therefore will have to limit the B1387 to one way traffic and/or temporary closure to reach and work at the landfall site and to build its cable route towards Hinton. The movement of AILs, which occur in daylight hours, will demand the closure of the road, fully trapping people in and out of Walberswick.
16. Although LL’s team argues that they won’t “cut off access” to Walberswick, in a practical sense, they must. Bringing 30-60 HGVs in to the village (meaning 60 to 120 HGV movements per day) on the B1387, and that two of these lorries cannot pass one another because of their size and the narrowness of the uncurbed road, then the impact is that LL will be closing and/or limiting access to the road to other users for periods throughout its 2 years in Walberswick. Given that LL is now claiming that it cannot use the haul road and instead will rely on the only road into the village, should be a factor to rule out Walberswick as a landfall site.
17. We are appalled that LL has not undertaken any detailed monitoring and modelling of the B1387 in the PEIR. They have launched a “statutory consultation” without the most essential information and plans necessary for the community to judge how the project will impinge on the rights of residents to the peaceful enjoyment of their homes including normal and predicable access. Is LL proposing that Walberswick residents and visitors double or triple their journey time for their departure from the village or to get home for up to two years? How far will the tailbacks be on days when thousands of visitors try to drive into the village and then find themselves trapped within or perhaps at the A12 waiting to turn into the B1387? How are cyclists and pedestrians to be protected from the intimidation of HGVs as the B1387 is a shared space given that Walberswick has no pavements or bike paths?
18. And what of dependable emergency access? If one of LL’s lorries breaks down or has an accident on the B1387, there is no access until the vehicle is removed. Or if traffic lights and tailbacks are on offer, how does an ambulance or other emergency vehicle reach or leave the village?
19. None of these questions can be answered because it seems that LL negligently failed to do the necessary analysis, presumably because it could undermine its case. It is not the community’s responsibility to do road use modelling when the developer fails to do so. But one small piece of information, using data from RingGo, is that the beach side carparks alone create some 90,000 journeys in and out of Walberswick each year. This number doesn’t include any other travel by residents, other visitors and trade. Holidays, weekends and school breaks throughout the year are all peak times for car volumes when thousands of daily journeys of road users will face the severe impact of LL’s failure to consider an appropriate transport strategy.
20. Beyond the issue of the B1387, LL’s draft order limits are suggesting that the project will interfere with other roads. Lodge Road, Stocks Lane and the PROW at the Northeastern corner of Manor Field have been included in the draft order limits for reasons that are not clear and are clearly inappropriate.
NOISE, LIGHT, VIBRATION AND DUST
21. LL must be aware that the excessive working hours being proposed are already under serious challenge at the SeaLink ExA hearings. Yet LL’s PEIR suggests the same extreme approach. This implies that LL’s proposed location is so untenable that the project can only be built if contractors are given a free hand to work 12 hour days (plus one hour on either side) and every day of the year including Sundays and holidays. As was made clear at the ExA hearings for SeaLink, such hours are completely unacceptable and unreasonable as they provide no respite to the local community from the congestion, noise, pollution, and other externalities of the project. The desperation of NGV’s working hours proposal is all the more out of touch given that SZC, SPR and other projects in the area quite rightly are NOT permitted the same.
22. NGV’s proposal shockingly then goes on to demand to expand its 12 hour, 7 day a week, holidays-included working hours to 4 sets of 24 hour days for 10 days (or more) of HDD drilling. We understand that HDD cannot be stopped once it begins which is precisely why locating the landing site within the village with houses abutting the construction site on three sides, protected habitat on the fourth side and with large parts of the entire settlement of Walberswick within 500 metres of the DOL is wholly inappropriate. As with the traffic and the use of the B1387, LL makes the situation even more provocative by purporting to “consult” whilst blithely telling us nothing more than the impact will be significant but that no mitigation has yet been considered. It is the greatest dereliction of this PEIR that this impact was not long ago carefully studied prior to taking any decision on a “preferred” landfall site, much less going to statutory consultation without detailed analysis. We can never accept 24-hour working and drilling within a residential area. It is one of NGV’s many failures that it did not discount the Walberswick landfall site in its earliest stages if such a requirement was technically necessary.
23. Even without the shocking revelation about the proposed 24-7 drilling, the PEIR makes no attempt to address or explain how the regular 12 hours a day, 7 days a week noise, vibration, wind-blown dust and night-time lighting will be experienced in a quiet rural village. The PIER says most noise effects would not be significant but not even bothered to measure them. No attempt has been made to understand how far sounds travel in and around Walberswick. Without this, the PEIR certainly cannot make any assessment of impact. This was made clear to people at the Walberswick consultation event who could gleam no details from the LL experts in the room that any work had been done in this regard. Nor could LL clearly explain how loud anything would be and exactly what measures are available to reduce or limit disturbance to the community and protected habitats. We know that Manor Field and the marshes are an acoustic bowl and that sound travels easily throughout the village. It shameful and a dereliction of its statutory responsibilities that LL did not think “consultation” with the community actually required that they undertake site specific investigation to what clearly is one of our biggest concerns.
24. Similarly, scant information on vibration impacts is provided. On what basis can the PEIR say vibration impacts are not expected to be significant when no analysis of construction traffic impact has been done? Heavy vehicles using narrow roads can cause noticeable vibration in nearby homes over long periods. On what basis does NGV claim this will not be the case in Walberswick and its historic homes?
25. NGV says dust will be managed using standard measures like water spraying. Where does NGV propose to get this water? Wind speed at the landfall is not even considered despite Walberswick’s exposed coastal setting. Wind-blown dust affects homes, public spaces and nearby protected sites but there is no indication that LL has considered wind-triggered impacts or mitigation. Since NGV has done no analysis whatsoever, we draw to LL’s attention that Manor Field is perhaps the windiest location in the village because of the way the field rises from the sea. We have been monitoring wind speeds at the homes along the northern side of the field and have found that even on days without storms, some very strong winds (circa 10-15 M/S) are recorded coming off Manor Field. NGV has not done the necessary analysis within its desk-based PEIR to analyse this additional risk to human health and well-being.
26. Walberswick is known for its beautiful and very dark night skies. There is purposefully no street lighting or lit signage in Walberswick to preserve this special community asset and to protect species that depend on darkness (discussed more in the section on Ecology). Yet the PEIR gives no detail on construction or operational lighting levels, how long lights would be on at night, or how light pollution would be limited, or the impact this will have on humans, birds, bats and other wildlife including the light spill into internationally protected sites.
IMPACT ON PUBLIC RIGHTS OF WAY AND FOOTPATH CLOSURE
27. Through the non-statutory consultation, LL incorrectly described Manor Field as “south of the village” despite it being in the centre of the village. It remains one of the most appalling and negligent misrepresentations in NGV’s approach and its denial of the landing site’s true location and importance to village residential and visitor life is at the heart of the poor quality of NGV’s analysis and conclusions regarding the “preferred” landfall location.
28. As NGV was informed throughout the non-statutory consultations, Walberswick’s network of PRoW and footpaths are central to village life and connect not only the various parts of the village but are key links to neighbouring Southwold and Dunwich. Our ProW span from local access to the nationally renowned King Charles III coastal path. And yet, to further demonstrate how ill-conceived the landfall site is, the DOL actually takes in every major PRoW that provides access to the beach, the marshes, and all routes to Dunwich. The cabling route also cuts across (and therefore limits access) to footpaths to Blythburgh. Only street access (which in Walberswick has no sidewalks) is left for access to the Walberswick beach and to connect the eastern and western edges of the settlement on the southern side of the parish. One of the key routes to the Walberswick beach – the Spong Bridge route along Manor Field is also within the DOL. The PEIR says “The construction of the Proposed Onshore Scheme would also require the temporary diversion of public rights of way, which is assessed as likely to give rise to significant effects.” A greater understatement is hard to imagine.
29. To counter NGV’s misrepresentation, WALL has undertaken professional footfall monitoring of the footpaths around Manor Field. The results clearly demonstrate the scale of use and the fact that Manor Field is an essential recreational space for residents and visitors rather than some distant, agricultural field. Between May 2024 and December 2025, a total of 147,447 people used the affected footpaths. Whilst there were some periods of heavier use – summer, school holidays, warmer weekends, Christmas/New Year, Easter holiday --- there was never a time when these PRoW were not used. Because of the beauty of Manor Field, its view of sea and marshes and the teaming bird life in and surrounding it, it is also used extensively by organised walking and running events. A large number of charity events and organised runs make use of it every year. LL’s 7 days a week work schedule would make all of these impossible – or at a minimum, undesirable as the point of running in and through Walberswick, including Manor Field, is for its natural beauty not to be dodging an industrial construction site!
30. This suggests that even if PRoW can manage to remain technically “open”, the aspects that make this recreational area special because of its natural beauty, peacefulness and spectacular long views of the sea and coastline will be lost during the entire period of construction and for some time after whilst the ecological harm and scars on the landscape try to heal. Therefore, we would say that the loss of this community asset cannot be meaningfully ‘mitigated’ and the negative impact on the people, economy and ecology will be extreme.
31. Despite recognising that “significant effects” are likely, LL provide only the statement that “mitigation measures are being developed to minimise significant effects”. No details have been provided, no diversion routes have been proposed (most likely because none are available), and no assessment has been offered of accessibility, safety, or continuity of public access and enjoyment during construction. It is not surprising, perhaps, that NGV has shied away from “mitigation” because of the simple and obvious truth: No mitigation is possible for an area that has such very high levels of footfall and that is central to community wellbeing, recreation, and tourism. Given that the DOL area is so large, there is no “diversion” possible beyond putting people on to the Street – the same B1387 being commandeered by LL on the way into the village. Roadways without footpaths are not an acceptable “diversion” to PRoW. We call on NGV to be honest about the impact of their proposal and challenge LL to provide detailed, practical, and safe mitigation measures that can be consulted upon before any further action on their proposal goes forward.
ECOLOGY
32. The PEIR is particularly weak and incomplete because of its poor quality related to Ecology. In short, we believe that the PEIR falls well short of the Environmental Impact Assessment Regulations 2017 in that it lacks the baseline ecological information required. Without adequate survey data, it is impossible to assess the likely significant effects of the development or judge whether the proposed landfall at Walberswick is environmentally acceptable. From our knowledge and study of the site, we believe it is not acceptable.
33. Reptiles: No reptile surveys have been carried out by LL around Manor Field or along key parts of the cable route, despite East Suffolk being known for important reptile populations. Professional independent surveys supported by WALL show reptiles are present and at risk of being killed or injured, meaning the proposal could breach wildlife legislation without major mitigation.
34. Marsh harriers: Although LL says that reedbed vantage point surveys were undertaken, surrounding farmland—including Manor Field—have not been surveyed, despite being regularly used for feeding. Marsh harriers are a qualifying species of the adjacent SPA, and disturbance could affect the integrity of the SPA population. The only safe drilling window (September–March) conflicts with other species’ requirements. In addition, it is essential to note that the SPA provides an important mitigation area for the lost foraging grounds at the current SZC site. Therefore, disturbing the marsh harriers here in Walberswick unwinds the mitigation put in place for Marsh Harriers as part of the SZC consent.
35. Nightjars: LL’s surveys failed to record nightjars in areas where WALL’s professional surveys confirm their presence. As another SPA qualifying species, inadequate survey work creates a real risk of significant adverse effects.
36. Red‑throated divers: Large numbers forage offshore in winter. Natural England has already advised that offshore works should not occur between November and March to avoid unacceptable impacts. This directly conflicts with the seasonal constraints needed to protect marsh harriers, leaving no acceptable window to undertake drilling activity at the landfall site.
37. Bats: Ten bat species have been recorded around Manor Field—an assemblage of national importance—yet the PEIR incorrectly assigns only county-level value. Several breeding roosts rely on a narrow habitat corridor leading directly to Manor Field. Proposed 24‑hour drilling and lighting, and “normal” lighting even when drilling is not taking place would cause major disturbance. The only safe working window (November–March) again conflicts with other species’ requirements.
38. Invertebrates: Important invertebrates, including moth species sensitive to light, hydrology and water quality changes, use the marshes below Manor Field. These risks have not been assessed. This needs to be corrected.
39. In summary, LL’s ecological baseline is woefully incomplete and does not meet EIA Regulations. The PEIR wrongly concludes that international‑scale impacts are unlikely, despite clear risks to SPA species and functionally linked land. Seasonal mitigation is impossible because the requirements of different protected species directly conflict. If LL had properly met its requirements and undertaken the necessary work, they themselves would have concluded that Walberswick is not a viable landfall site. LL must therefore reconsider its plans.
ARCHEALOGICAL AND HISTORICAL REMAINS
40. As noted in para 12, LL says it dismissed (rightly) Dunwich as a landing site because of danger of disturbing archaeological and heritage assets. However, it has not done the same for the Walberswick site and instead widely ignored the potential impacts that the Manor Field landfall and the wider DOL would have on land that is known to be the ancient village and medieval harbour of Walberswick. A BBC documentary – “Villages by the Sea” – delves into this special aspect of Walberswick and LL might have easily done its homework rather than producing a PEIR which fails to adequately assess the archaeological risks.
41. Although NGV state that the historic environment has been considered ,no meaningful investigation has been carried out beyond the end of Stocks Lane or around the caravan site. This omission is serious. From the early 14th to late 16th centuries, Walberswick was a major trading port serving Dunwich, Southwold and Blythburgh. According to the Walberswick History Group, recent research by Dr Tom Johnson (University of Oxford) indicates that the harbour would have contained substantial structures linked to trade, shipbuilding and fishing. When the new river entrance was cut in 1590, the old harbour silted up, increasing the likelihood that remains are well preserved and potentially of national significance. The site is difficult to investigate due to mudbanks, saltmarsh and shifting river channels, which explains the lack of finds to date but not the lack of assessment. The proposed cable route may pass directly through this sensitive area.
42. Historic England raised concerns about slurry breakout from HDD but as with most inconvenient truths uncovered in relation to the Walberswick site, NGV has brushed it aside. In this case, they say that any remains would simply be removed despite such an approach being inadequate and inappropriate. If a medieval harbour survives, it should not be removed. Even deeper drilling risks destabilising waterlogged deposits, including older maritime timbers. Given these risks, the harbour area should be given far greater priority. We believe a thorough archaeological evaluation is required before any decision is taken, with specific assessment of the potential impacts of HDD.
AGE AS A PROTECTED CHARACTERISTIC AND ARTICLE 8 OF THE ECHR
43. One of the greatest failures of the PEIR is that it fails to adequately consider the impact on “human receptors”, and where it mentions even significant impact, fails to provide detail or any measures for mitigation on which the community could meaningfully react. There are two aspects to this I would like to highlight.
44. First, although LL concedes that Walberswick’s population has one of the oldest age profiles in England, it does not assess, nor attempt to address, the impacts of the scheme on age as a protected characteristic. As NGV must be well aware, the Equality Act 2010 makes age a protected characteristic, and public bodies must have due regard to the needs of older people when exercising planning and regulatory functions. However, the PEIR and associated consultation materials contain no detailed analysis of the age profile of Walberswick, no Equality Impact Assessment specific to the village, and no evidence that NGV have considered the heightened risks to older residents living immediately adjacent to the proposed HDD works, cabling route and trying to navigate the multi-year traffic disruption.
45. Government Census 2021 data shows that:
· 43% of Walberswick residents are aged 65 or over, compared with 18.6% nationally.
· 35% of the village is aged 70+, far higher than both national and district averages.
· 11% are aged 85+, an exceptionally high proportion for any community.
46. This means Walberswick is not simply an “older than average” village; it is a community with a concentration of residents who are more vulnerable to noise, vibration, disruption, anxiety, access changes, and construction‑related hazards and must receive special protection. In fact, several of the oldest residents of Walberswick live in homes that abut the landfall site and therefore suggests that an extraordinary level of additional assessment and care is necessary.
47. It is our understanding that NGV have not undertaken any age‑specific assessment of construction impacts nor identified older residents as a vulnerable group much less proposed any tailored mitigation, communication methods or access arrangement. Planning policy, HSE guidance, and statutory nuisance legislation all require heightened protection for vulnerable groups, including older residents. Therefore, NGV have not demonstrated compliance with their Public Sector Equality Duty, but instead have disregarded its legal obligations.
48. This omission is particularly serious given, as noted above, that HDD works are proposed within 50 - 100 metres of homes and that older people are more susceptible to the very impact that HDD will cause including:
· Sleep disturbance and cardiovascular stress from continuous drilling noise
· Anxiety and confusion caused by prolonged disruption
· Increased risk of falls or isolation if footpaths or access routes are altered
· Difficulty navigating construction traffic, uneven surfaces, or diversions
· Reduced ability to evacuate quickly in the event of an incident
49. In addition to shortcomings in addressing the needs of this vulnerable group, we draw to LL’s attention that their desire to undertake HDD in the centre of the village and in such close proximity of homes is clearly a violation of Article 8 of the European Convention on Human Rights (ECHR) as it applies to NSIPs.
50. As NGV should be aware, Article 8 protects homes, private life and family life. Specific to the case of the landfall site, Article 8 is engaged where the NSIP involves serious noise, vibration or safety impacts. Therefore, NGV has failed in its PEIR to take this into account as it does none of the following:
· give consideration of individual circumstances;
· make an assessment of alternatives and mitigation; and
· give a clear justification why specific homes must be affected.
51. Had NGV done any analysis of its obligations under Article 8 in the case of HDD at the landfall site it would have discounted the Manor Field selection at the very start of the process given that its location is in the centre of the village and closely surrounded by homes.
52. Going back to the statements made at the start of this response which point out that while NGV spent considerable time and pages to explaining why other sites were rejected, it failed to look at the reasons which made the Walberswick site likewise unsuitable. We believe that in failing to address Article 8, as well as Age as a Protected Characteristic, the PEIR has failed and the LL proposal cannot be taken forward. The landing site proposal cannot be considered compliant with the Equality Act 2010, with Article 8 or with good practice for major infrastructure projects.
ECONOMIC IMPACT
53. Throughout the non-statutory consultation, the Parish Council made it abundantly clear, as was noted in the PEIR, that the village’s vibrant and successful economy is reliant on tourism and hospitality businesses (including pubs, cafes, small camp site, shops and holiday let accommodation). We pointed out how important the day trip visitors, who come to Walberswick’s unspoiled beaches and other natural beauties and charms, are to the survival of the village. Yet, we can find no acknowledgement or analysis of the serious impact that the two years of LL construction would have on this economy. Likewise, there is no evidence provided by the PEIR on why NGV believes its impact would not be significant.
54. We remind NGV of the following facts about the Walberswick’s eco-tourism driven economy:
· Walberswick is one of the most sensitive locations on the Suffolk coast—economically, environmentally and socially.
· Its visitor economy, cultural identity and community wellbeing are inseparable from its landscape quality, tranquillity, nature‑based tourism, and ease of access.
· LL’s own PEIR acknowledges this explicitly in describing it: “Walberswick is a high‑end visitor destination, immediately adjacent to internationally designated habitats, with significant tranquillity and place‑attachment value.”
55. The PEIR predicts major adverse construction effects on the local landscape, significant health and wellbeing impactsfor residents and risks to route quality and visitor experience along the coastline. Yet it is as if the authors of the PEIR didn’t read their own analysis as it then goes on to conclude that socio‑economic impacts lean toward “minor” or “negligible” effects, largely on the basis that physical access is “retained” and no permanent above‑ground structures are proposed.
56. This is a farcical conclusion. For a community like Walberswick—where experience quality, peace and quiet, night‑time darkness, landscape integrity, and reputation are the key economic assets (which even the PEIR acknowledges) — such conclusions are not credible without much stronger, Walberswick‑specific commitments.
57. Elsewhere, the PEIR acknowledges again that major adverse landscape and tranquillity effects will occur during construction across the Walberswick sandlands plateau and fringe. These effects extend beyond the Order Limits and directly influence the setting visitors come to experience. The significance of these impacts is heightened because Walberswick is not just scenic—it is a destination whose entire value proposition is built on tranquillity, openness and natural beauty. The construction period is not short – lasting 2 years if it remains on a schedule that requiring working every day of the year and through many nights.
58. The failure to translate these place‑attachment harms into socio‑economic consequence pathways is a critical underassessment: what matters in Walberswick’s tourism market is experience-driven, reputation‑sensitive and seasonal. It is not simply that physical access to the beach is technically provided, but the quality of the experience when one gets there. It is the same argument about the experience of walkers. Walberswick’s recreational environment—its beach, dunes, common land, footpaths connecting Dunwich, Walberswick, Southwold and Blythburgh and access to the Minsmere–Walberswick reserve—is a core part of its economic identity. Noise, lighting, construction compounds, and localised temporary diversions can reduce dwell time, shift walkers and bird watchers away, and create pressure on a landscape already constrained at peak use. Even if visitors still “can” access some of these features, many are expected to prefer not to, particularly if they perceive the area as partially industrialised or disrupted. Given LL’s plans, such a perception is inevitable.
59. Typically, the PEIR seeks to paper over harm even though a more localised level of harm was used by LL to demonstrate the inappropriateness of the Southwold site. When it comes to Walberswick, LL’s “minor adverse” conclusion assumes that visitor behaviour does not materially change and that construction does not affect peak‑season desirability. This is patently untrue.
60. Small changes in footfall on key weekends or during school holidays can have outsized effects on turnover. Perceptions (“Walberswick is closed”, “the beach is fenced off”, “too noisy”) can spread rapidly in visitor markets that rely heavily on social media, word‑of‑mouth and repeat custom. In September and October 2025, visitor numbers at the Walberswick car parks were down 25% and 20% percent month on month compared to 2024. This drop coincided with the imposition of SZC related traffic lights and congestion on the A12 on the way towards Walberswick and can be assumed to have kept visitors away from the Suffolk Coast.
61. Even modest tourism suppression translates into hundreds of thousands of pounds in lost spend in a single season; if peak periods overlap with noisy or visually dominant works, impacts could easily rise. For local accommodation providers, cafés, and day‑trip businesses, these variations are not “minor”—they directly shape survival.
62. Typical mitigation proposals – advertising materials, ‘still open’ signage and the ilk – will not address the specific impacts felt in Walberswick. That is because the value proposition is one of providing tranquillity, beauty, quiet, dark skies and an authentic village experience. None of these are compatible with the noise, dust, light pollution, industrialisation and constrained and unpredictable access associated with LL.
63. In summary, the evidence of significant socio-impact harm of the LL proposal is strong and we must object to LL’s landfall in Walberswick in the strongest term. This comes from:
· the significant negative impact and significant downgrading of the recreation and amenity value for residents and visitors including industrialisation on and along the B1387, the cable route and in Manor Field.
· Working hours 12 hours a day, every day of the week, and at night provide no window of quiet or respite.
· Increase in journey times and unpredictability in journey times caused by the use of the B1387 by LL HGVs and workers are destroyers of repeat visitors and will quickly spread. The experience of Walberswick beach day visitors demonstrate how sensitive day visitors are to travel delays and unpredictability.
· Reputational damage that would be long lasting beyond the end of LL construction.
CUMULATIVE IMPACT
64. LL must be aware through its sister project, SeaLink, of the strength of arguments against SeaLink on grounds of cumulative impact. Rather than repeat all of these here, we direct LL to the dozens of documents related to cumulative impact, including the LIRs submitted by Suffolk County and East Suffolk Councils, that have been submitted to the SeaLink examination. The impact of Lionlink is precisely the same as SeaLink with the exception that the Landing Site and cable route from Walberswick adds an additional layer of impact on top of the already unmanageable situation at the Saxmundham and Friston end of SeaLink. These are further layered by the site-specific impacts of the landfall and the additional communities that would be blighted with LL’s cable route coming to the substation from the north.
65. It is ridiculous that NGV repeatedly states that cumulative effects and any additional mitigation will be addressed only at ES stage. LL would have known about these well-documented impacts prior to publication of its PEIR and should have used this existing documentation, readily available in the public domain and from is sister organization NG. To avoid addressing them is disingenuous. SZC’s traffic tracker reports weekly on the road closures and other diversions associated with its project that directly impact the area of LL’s project. Over the past two weeks, for example, if LL was being constructed, its HGVs and workers would have had to follow a 100-mile diversion to get around the closure of the Friday Street junction on the A12. How can the PEIR be taken seriously when this obvious cumulative impact not only on the community but on NGV’s own ability to deliver the project is so glaringly obvious? Ignoring this existing and overwhelming evidence already provided through the SeaLink examination undermines the PEIR and demonstrates NGV’s desire to avoid addressing its project planning failures in its stubborn refusal to seek an alternative location.
66. One additional element of cumulative impact that bears highlighting is the impact that LL would have on SZC. For good or evil, SZC is underway and is the biggest infrastructure project in the UK if not in Europe. Moreover, it is being financed almost entirely by the taxpayer and by all of us who pay our electricity bills. SZC is struggling to deliver within the insufficient and overburdened road and rail system in Suffolk Coastal, in an area with a major shortage of housing for workers and within a heavily protected environment. One does not have to have any love for SZC to recognise that it is in the overriding interest of the local community and the nation that SZC gets built as quickly as possible, without the huge ballooning of costs and years of delay that have befallen every other nuclear plant of its kind in the UK and across the globe. It is this interest, both National and Local, that should unequivocally preclude a project like LL from trying to squeeze into the same small area.
67. As we discussed in paras 7-9, there is no compelling reason to bring LL onshore in Suffolk. The building of LL will directly interfere with supporting infrastructure being built by SZC (such as the SZC link road), adds considerable risk and congestion to inappropriate road networks, disrupts commuter rail (as a result of the Benhall bridge), requires even more workers to be bussed in, takes even more housing that is already beyond strain by SZC. Moreover, the timing of LL coincides with peak activity of SZC. How can any responsible project manager suggest it is realistic to try to deliver LL at the same moment when SZC’s 10,000 workers and thousands of HGVs are on the same inadequate roads that LL hopes to use? Any discussion of “coordination” is misplaced. There is no room for any additional infrastructure in Suffolk Coastal that will not impact SZC. Completing SZC – lowering the impact on the community and the Nation – must have priority over bringing in new NSIPs particularly those like Lionlink that offer no local benefit nor particular connection to this area.
68. In conclusion, we object in absolutely the strongest terms to the LL proposal. The PEIR fails in its obligation to provide the information required to justify the selection of Walberswick, assess ecological harm and provide the detail needed for a meaningful consultation process. In sum, we cannot accept the overall scheme given the shortcomings of its substation option already demonstrated through the SeaLink examination and the project’s cumulative impact. We have highlighted the many reasons that the landfall site in Walberswick is wholly inappropriate including its inaccessibility and the excessive risks to the community of its transport strategy, ecological and human harm, socio-economic impact and contradiction with the Equality act and Article 8 of ECHR.
Walberswick Parish Council