Environmental
Statement
Volume I
Environmental Statement
and Figures
February 2013
NEMO LINK
UK ONSHORE COMPONENTS
Prepared by:
Sophie Clayton/Bobby Clayton
TEP
Genesis Centre
Birchwood Science Park
Warrington
WA3 7BH
Tel: 01925 844004
Fax: 01925 844002
e-mail: [email protected]
for
National Grid Nemo Link Limited
Written:
Checked:
Approved:
SC/BC
IJG
IJG
Table of Contents
1.0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
9.0
10.0
11.0
12.0
13.0
14.0
15.0
16.0
17.0
18.0
INTRODUCTION
PROJECT DESCRIPTION
OPTIONS AND ALTERNATIVES CONSIDERED
PLANNING POLICY REVIEW
LAND USE
GROUND CONDITIONS AND CONTAMINATION
HYDROLOGY AND FLOOD RISK
ECOLOGY
ARCHAEOLOGY AND CULTURAL HERITAGE
LANDSCAPE AND VISUAL EFFECTS
TRAFFIC AND TRANSPORT
NOISE AND VIBRATION
AIR QUALITY
COASTAL TOURISM, RECREATION AND SOCIO-ECONOMICS
ELECTRIC AND MAGNETIC FIELDS AND ELECTROMAGNETIC COMPATIBILITY
PROJECT-WIDE ASSESSMENT OF EFFECTS
ASSESSMENT OF EFFECTS OF THE NATIONAL ELECTRICITY TRANSMISSION SYSTEM
CONNECTION
SUMMARY AND CONCLUSIONS
Appendices (see ES Volumes 2 and 3)
1.1
1.2
3.1
4.1
6.1
7.1
8.1
8.2
8.3
8.4
8.5
8.6
8.7
8.8
8.9
8.10
9.1
10.1
10.2
11.1
11.2
12.1
16.1
ES Scoping and Pre-Application Consultation Table
Statement of Community Involvement
Review of Options
The Horlock Rules
Ground Conditions and Contamination Phase 1 Environmental Study (Main report only – see
Planning Application CD for full data version)
Flood Risk Assessment (Main report only – see Planning Application CD for full data version)
Desktop Records
Extended Phase 1 Habitat Survey
Saltmarsh NVC Survey
Reptile Survey
Water Vole Survey
Wintering Bird Survey
Breeding Bird and Nesting Redshank Survey
Sediment and Invertebrates Survey
Information for Habitats Regulations Assessment (HRA)
Information for HRA Signposting Document
Archaeology and Cultural Heritage Baseline Report
Verified Photomontage Method
Visual Effects Assessment Tables
Abnormal Indivisible Load Investigations
Construction Traffic Air Quality Assessment
Substation and Converter Station Sound Power Levels and Assumptions
Belgian Onshore and Marine Environmental Assessment Non-Technical Summary
Documents and Marine Scoping Responses
3
4
1.0
INTRODUCTION
Project Overview
1.1
The Nemo Link (the Project) is a proposed high voltage direct current (HVDC)
electrical interconnector with an approximate capacity of 1,000 megawatts (MW)
which will allow the transfer of electrical power via subsea cables between the UK
and Belgium. The power would be bi-directional, able to flow in either direction at
different times, depending on the supply and demand in each country. The project
will bring both short and long term local economic benefit, wider benefit to electricity
consumers in the UK and Europe and enhanced opportunities for the integration of
renewable energy to meet climate change targets.
1.2
The proposed subsea cables would run from Pegwell Bay at Richborough in Kent to
Zeebrugge in Belgium (Figure 1.1) passing through English, French and Belgian
waters.
1.3
The UK onshore elements of the Project for which planning permission is being
sought comprise a converter station and substation at the site of the former
Richborough Power Station, and HVDC and fibre optic cables installed below the
ground between the converter station and mean low water at Pegwell Bay. These
elements of the Project are referred to in this Environmental Statement (ES) as ‘the
Proposed Development’. The cables will connect to the other parts of the
interconnector which are the subsea cables from low water across the North Sea
and onshore underground cables and a converter station in Belgium.
1.4
The Project is being developed by National Grid Nemo Link Ltd (NGNLL), part of
the National Grid group, and Elia Asset S.A. (Elia) which is part of the national
electricity transmission company in Belgium.
The proposed substation at
Richborough would be owned and operated by National Grid Electricity
Transmission (NGET).
1.5
The majority of the Proposed Development falls within the administrative boundary
of Thanet District Council (TDC). Approximately 720m of the HVDC cable and a
small area at the south east corner of the proposed converter station compound
(outdoor hard landscape and security perimeter fencing) is within the administrative
boundary of Dover District Council. This ES accompanies a single hybrid
application for planning permission under the Town and Country Planning Act 1990
as follows:
Outline Permission

Proposed HVDC converter station and 400kV substation – matters of
landscaping and access are provided. Matters of appearance, layout and scale
are reserved.
Full Permission

1.6
Proposed HVDC, HVAC and fibre optic cables - all matters are provided.
A full description of the Proposed Development is detailed at Chapter 2. The hybrid
planning application has been submitted to both TDC and Dover District Council
(DDC); through pre-application discussions with both Local Planning Authorities, it
has been agreed that TDC is to adopt the lead with regards the coordination and
5
determination of the hybrid planning application. Decision notices are to be issued
by both LPAs. Further details as to the approach to, and the provisions of the
hybrid planning application are included in the planning application covering letters
to TDC and DDC.
1.7
This ES covers the UK onshore elements of the Project and presents the results of
surveys and assessments of potential environmental effects.
1.8
A separate UK Marine ES has been prepared for the installation of the subsea
cables from the mean high water spring (MHWS) tide mark on the Kent coast out to
the median line between England and France as these works require consent under
the Marine and Coastal Access Act 2009.
1.9
The potential environmental effects of the other elements of the Project (comprising
the marine cables in French and Belgian waters, and the converter station in
Belgium) have been assessed separately, and these assessments will be submitted
to the relevant authorities in France and Belgium with the consent applications for
each of these elements.
1.10
As these non-UK elements form part of the Project for EIA purposes, a description
of these components is included within this ES as well as a summary of their effects
on the environment.
Project Justification
1.11
The UK has two key environmental targets relating to renewable energy and
greenhouse gas emissions. The first of these targets is part of the European
Union’s (EU) integrated energy/climate change proposal. This proposal sets a
target of 20% of European Energy (including electricity, heat & transport) to come
from renewable sources by 2020 (known as the EU 20/20/20 vision
(http://www.energy.eu/directives/com2008_0030en01.pdf). The Renewable Energy
Strategy
published
in
July
2009
(http://www.decc.gov.uk/en/content/cms/what_we_do/uk_supply/energy_mix/renew
able/res/res.aspx) identified that, for the UK to meet its share of the EU target (UK’s
share is 15% of energy sources including electricity, heat and transport), 30% of
UK’s electricity would have to come from renewable sources.
1.12
The second target is incorporated in the Climate Change Act 2008. This goes
further than the EU 20/20/20 vision, and sets a target of 80% reduction in UK
greenhouse gas emissions from 1990 levels by 2050. This equates to a 34%
reduction in greenhouse gas emissions by 2020 as specified by the Climate
Change Committee (http://www.theccc.org.uk/).
1.13
European strategy recognises the urgent need to upgrade Europe's energy
infrastructure and to interconnect networks across borders to meet the EU’s core
energy policy objectives of competitiveness, sustainability and security of supply
(“Europe 2020” EC Communication (2010).
1.14
These objectives are supported by European policy which facilitates the urgent
upgrading and extension of electricity networks, including interconnectors, to
maintain existing levels of security of supply and, in particular, to transport and
balance electricity from renewable sources, which is expected to more than double
in the period 2007 to 2020.
6
1.15
Interconnectors enable power to flow between member state transmission networks
and are vital for ensuring a competitive and well-functioning integrated market for
energy. Despite the existence of common rules for the internal market in electricity,
the European Commission recognises that the internal market remains fragmented
due to insufficient interconnections between national energy networks.
1.16
In 2002 the EU Council set a target for all Member States to have electricity
interconnection capacity equivalent to at least 10% of their installed production
capacity by 2005. The UK is still failing to meet this target. Total UK interconnection
capacity amounts to 3.5GW which represents just over 4% of the 85 GW of installed
generation capacity.
1.17
In December 2009 the UK and Belgium both became signatories to the North Seas
Countries Offshore Grid Initiative (NSCOGI) with the objective to coordinate
offshore wind and infrastructure developments in the North Sea. Interconnection
between countries is a prerequisite to achieving this ambition.
1.18
The UK Government’s vision to ensure safe, secure and affordable supplies for the
future involves the construction of a new fleet of nuclear generation, rapid
expansion of renewable energy (mainly through offshore wind), and the
development of interconnector projects. Specifically, the UK is committed to the
European Commission’s 3rd energy package which states that 15% of the UK’s
demand for energy needs to be generated from renewable sources by 2020. To
meet this target, the UK will need an energy portfolio of 34% wind generating
capacity by 2020, rapidly building on 4% wind capacity of today.
1.19
The vast majority of this wind capacity is expected to be obtained from the Crown
Estate’s licensed Round 3 Development Zones which has the aim to install 25GW
of offshore wind capacity by 2020. This huge investment into the UK renewables
sector is part of an aspiration to develop a large-scale green industry to boost the
UK economy and create jobs.
1.20
By its nature, wind generation is intermittent. It is therefore necessary to have plant
and equipment that can respond to rapid changes in generating output.
Interconnectors, such as the one proposed between the UK and Belgium, provide
an effective way to manage these fluctuations in supply and demand.
1.21
An industry consultation carried out by National Grid Interconnectors Ltd, Elia and
RTE in 2008 concluded that there was significant demand for new interconnection
between Great Britain and Continental Europe.
Respondents considered
interconnection to be an important means to:




1.22
Respond to intermittency of wind generation, which varies according to the
strength of the wind;
Respond to periods of excess power, specifically when wind generation is
greater than electricity demand;
Help meet the challenge of retiring fossil fuel and nuclear plants in the UK; and
Support neighbouring wholesale and supply markets and, in the case of DC
interconnectors, the provision of balancing and ancillary services.
Currently the UK has three interconnectors providing a total of up to 3,500MW of
power transfer capability:
 UK – France: Known as IFA (Interconnexion France Angleterre). This is a
2000MW HVDC connection commissioned in 1986. It is jointly owned and
7


1.23
operated by National Grid Interconnectors Limited and Reseau de Transport
d’Electricite. The UK landing point is at Baker’s Gap near Folkestone and a
connection made to the high voltage transmission system at Sellindge.
UK – Netherlands: Known as BritNed. This is a 1000MW HVDC connection
commissioned in 2011. It is owned and operated by BritNed Development
Limited which is a joint venture between NLink International BV, a subsidiary of
Tennet Holding B.V and National Grid International Ltd. The UK landing point
is at the Isle of Grain, Kent and a connection made to the high voltage
transmission system at the Grain substation.
Scotland – Northern Ireland: Known as the Moyle interconnector. This is a
500MW connection between Auchencrosh, South Ayrshire, Scotland and
Ballycronan More, Northern Ireland. It was commissioned in 2001 and is
operated by SONI (System Operator Northern Ireland) on behalf of Northern
Ireland Energy Holdings.
The proposed Nemo Link between the UK and Belgium is one of a small number of
interconnector projects currently under development/construction. Other projects
include:


Republic of Ireland – UK, 500MW interconnector, known as the East – West
Interconnector, linking the Republic of Ireland (RoI) with Deeside, North Wales.
This project has been constructed by Eirgrid, the Transmission System
Operator for the RoI and is anticipated to be in operation in early 2013. The UK
landing point is at Barkby Beach, Prestatyn, North Wales and a connection
made to the high voltage transmission system at Deeside.
UK – Norway: Approximately 1400MW interconnector linking the north east of
England with Norway. This project is jointly being developed by National Grid
International Ltd and Statnett, the Transmission System Operator for Norway.
1.24
Taking into account these other projects, the Nemo Link provides further diversity to
the UK’s interconnection portfolio and will contribute 15% of total interconnection
capacity of 5.4GW which in turn represents 6.4% of installed generation capacity.
1.25
Belgium is particularly suitable for a new interconnector not only because of its
geographical proximity to the UK, but also because its electricity transmission
system is highly connected to Central Europe. The Nemo Link will therefore
provide enhanced opportunities for the UK to trade with wider European power
markets. There is no existing connection between the UK and Belgian transmission
systems, so the construction of a new connection is required to achieve these
objectives.
1.26
South East England is the most suitable location for an interconnector between the
UK and Belgium. The South East offers the shortest route between the two
countries and, therefore, reduces the environmental effects, costs and construction
risks associated with the installation of subsea HVDC cables. In addition, the South
East region (including London) represents the highest centre of electricity demand
in the UK.
1.27
A need case document for the development of the interconnector between the UK
and Belgium has been produced by NGNLL and Elia and this can be found on the
Project website (www.nemo-link.com).
8
Legislative and Regulatory Framework
Electricity Act 1989
1.28
NGNLL has applied for an interconnector licence under the Electricity Act 1989 to
operate the Nemo Link. The holder of such a licence will be under statutory
obligations imposed by section 9 and Schedule 9 of the Electricity Act 1989. These
include the following obligations which apply when the licence holder is developing
any proposals:


‘To have regard to the desirability of preserving natural beauty, of conserving
flora, fauna and geological or physiographical features of special interest and of
protecting sites, buildings and objects of architectural, historic or archaeological
interest; and
Do what he reasonably can to mitigate any effect which the proposal would
have on the natural beauty of the countryside or on any such flora, fauna,
features, sites, buildings or objects.’
Environmental Impact Assessment
1.29
Environmental Impact Assessment (EIA) is a process by which information about
the potential environmental effects of a proposed development is collected,
evaluated and presented to facilitate consultation and to enable decision makers to
take account of these effects (both beneficial and adverse) when determining
whether or not a project should proceed. EIA seeks to identify the potential sources
of environmental effects during the design of a project and to avoid or minimise
adverse effects through appropriate mitigation. It also seeks to compensate
unavoidable effects, for example by providing replacement for environmental
features which are lost or changed due to development.
1.30
European Community Directive 85/337/EEC sets out formal requirements for
member states to implement EIA for projects. Subsequent Directives (1997/11/EC
and 2003/35/EC) have been issued with subsequent amendments. The United
Kingdom Government has implemented these Directives through a series of
regulations. The Town and Country Planning (Environmental Impact Assessment)
Regulations 2011 apply to projects regulated through the planning system in
England.
1.31
The report of EIA submitted under the relevant Regulations is called an
Environmental Statement (ES). The Regulations include specific requirements as
to the content of an ES.
1.32
The Regulations include two Schedules of development which are derived from the
Directives. Applications for projects described in Schedule 1 must be accompanied
by an EIA. Applications for projects described in Schedule 2 may require EIA,
depending on the scale of the development, its characteristics and the sensitivity of
the environment in which the development will take place. The decision as to
whether or not EIA applies to a development is called the ‘Screening Opinion’. The
Local Planning Authority or the relevant Secretary of State can decide whether an
application comprises EIA development under the Regulations. Alternatively, a
developer can decide that its application will be accompanied by an ES, making it
EIA development.
1.33
The Proposed Development set out in this planning application is not considered to
fall under Schedule 1 or Schedule 2 of the Town and Country Planning
9
(Environmental Impact Assessment) Regulations 2011 and therefore EIA is not
required.
1.34
Taking into account Schedule 9 and Section 9 commitments under the Electricity
Act and the relationship of the Proposed Development (subject to this planning
application) to the proposed works in Belgium (which are subject to EIA under
Belgian law), NGNLL and Elia have decided to prepare and submit a voluntary ES
to accompany this application for planning permission. An EIA screening request
was therefore not submitted to either TDC or DDC. A scoping report was prepared
to determine the extent of the matters to be covered in the ES (see below for further
details).
Habitats Regulations
1.35
Development within or adjacent to an existing or candidate Special Protection Area
(SPA) or Special Area of Conservation (SAC) is subject to the provisions of the
Conservation of Habitats and Species Regulations 2010. Under Regulation 21 of
these Regulations, the competent authority is required to undertake an ‘appropriate
assessment’ of any proposed development which is likely to have a significant
effect on a designated site to determine the impact of the proposal on the
designated site’s conservation objectives and determine whether the site’s integrity
would be adversely affected.
1.36
The proposed onshore underground HVDC cables pass through Thanet Coast and
Sandwich Bay SPA/Ramsar Site, Sandwich Bay SAC. In determining the
application for planning permission, Thanet District Council and Dover District
Council, as the competent authorities, are required under the above Regulations to
consider whether an ‘Appropriate Assessment’ is required. To allow the Council to
do this, a document entitled ‘Information for Habitat Regulations Assessment’ which
includes an Assessment of Likely Significant Effects (ALSE) has been produced
and included as part of this application. The document details the development
activities that could potentially directly and indirectly affect the internationally
designated areas of the site and the methods that will be used to avoid impacts, or
mitigate and compensate for those that cannot be avoided.
Environment Statement Preparation
1.37
The main activities undertaken in the preparation of this ES have included:






The evaluation of potential cable routes and converter station and substation
sites and consultation with statutory and non-statutory consultees to gain an
initial understanding of any issues associated with the Proposed Development;
The preparation of a scoping document incorporating recommendations from
the consultees. This document outlined the surveys and assessments to be
undertaken and the potential impacts of the Proposed Development;
Carrying out desk-based assessments and site surveys;
Identifying and assessing the likely significant impacts of the Proposed
Development;
Devising appropriate mitigation measures; and
Assessing the significance of residual and cumulative impacts.
10
Scoping of the EIA
1.38
Scoping is the process of determining the extent of the matters which should be
covered in the EIA. The purpose of the scoping stage is to identify any potential
significant impacts arising from the proposed development and to scope out any
impacts that can be considered insignificant, which do not warrant further
consideration in the EIA. The scoping report brings together the results of early
consultations, desk-based assessments and field surveys already undertaken and
presents proposals for the EIA.
1.39
The scoping stage provides the opportunity for statutory bodies and other
consultees to comment on the identified impacts, the proposed methodologies for
assessment and the scope of the assessment considered necessary and
appropriate. A number of discussions have been held with consultees, particularly
regarding potential effects on the designated sites of Pegwell Bay. In July 2012, a
Scoping Report was prepared and used to provide information to consultees about
the Proposed Development and the proposed approach to the EIA. Thanet District
Council and Dover District Council have issued ‘scoping opinions’ and these have
guided the contents of this ES. The scoping opinions together with consultation
responses from statutory consultees and how they have been addressed in this
planning application can be viewed at Appendix 1.1.
Surveys and Fieldwork
1.40
Studies and surveys were carried out to gather environmental and engineering
information for the ES. These included the following:





1.41
Ecological surveys including a Phase 1 Habitat Survey, saltmarsh National
Vegetation Classification (NVC) survey and preliminary protected species
surveys;
A baseline noise monitoring study;
A traffic assessment;
An archaeological desk-based assessment and walkover survey; and
Landscape and visual assessment.
The results of the surveys conducted have resulted in changes being made to the
cable route alignment and construction methods under consideration. Where
changes have been made, these have been taken into consideration within the EIA
process and necessary surveys conducted in order to assess the likely
environmental impacts.
Assessment of Impact Significance
1.42
Best practice guidance has been used for individual chapters where available and
appropriate. In carrying out the assessment, a general method for the presentation
of environmental impacts has been adopted to ensure consistency in the evaluation
of significance across all specialist topic areas.
1.43
Significance is considered as a function of the two variables: sensitivity of receptor,
and magnitude of effect, giving rise to a significance of impact scale ranging from
minor, through moderate to major. Impacts can be beneficial (positive) or adverse
(negative) as well as neutral (where there is either no impact, or where positive and
negative impacts balance) or indeterminate.
11
1.44
In this ES, impacts assessed as moderate (adverse or beneficial) or above are
considered to be ‘significant’. Minor (adverse or beneficial) and neutral impacts are
not considered significant. However, they are included in the assessment as they
should be considered throughout the decision-making process and may be
important in terms of cumulative impacts.
1.45
Where the judgement of impact significance is not based on these criteria alone, a
quantitative or qualitative assessment of the impact is given depending on the
specialist discipline, the type of information that can be collected from the site and
the professional’s own judgement. Notwithstanding this, impact significance always
takes into account the impact’s deviation from the established baseline conditions
(impact magnitude) and the sensitivity of the receptor.
Identification of Mitigation Measures
1.46
Measures to reduce negative impacts (or enhance positive impacts) are termed
mitigation. Best practice techniques to minimise the environmental impacts of
installing the onshore underground cables and constructing and operating of the
converter station and substation have been identified where appropriate. These
include for example:



1.47
Routeing the cables to avoid or reduce impact on sensitive features;
Reducing the working width along the cable route where there are sensitive
features such as hedges, to reduce impact;
Controlling risk by following published best practice guidelines, such as for the
storage of oil and fuels.
In addition, site and project specific mitigation measures have been identified where
generic, best practice mitigation measures are not suitable.
Assessment of Significance of Residual Impacts
1.48
Any impact remaining after mitigation is the residual impact. An assessment has
been made of the significance of residual impacts, based on the characteristics of
the impact and the receptors’ sensitivity, using professional judgement and relevant
standards and criteria, where available.
Cumulative Impact Assessment
1.49
Cumulative effects are those that may result from the combined or incremental
effects of the past, present or future development activities. A single development
or activity may itself result in an effect which in itself is not significant but when
combined with other effects (significant or not) in the same geographical area and
occurring at the same time, result in a cumulative impact which is significant.
1.50
The cumulative impact assessment has been designed to ensure that it covers all of
the following:


Wider cumulative impacts which are the combined impacts that may occur
between the UK onshore components of the Nemo Link with other non-related
developments that do not form part of the Nemo Link;
Project wide cumulative impacts which arise from the combined impacts
(additive or interactive) of the UK onshore elements of the Nemo Link project
12

with other components of the Nemo Link i.e. UK, French and Belgian subsea
cables and Belgian onshore infrastructure; and
Project related cumulative impacts which are the combined impacts that may
occur between the UK onshore elements of the Project with development
required to facilitate the connection of the Nemo Link. Within this ES, this
relates specifically to the grid connection which will be required to the National
Electricity Transmission System.
1.51
Chapter 2 provides details of the Nemo Link components that do not form part of
this planning application as well as an explanation of the grid connection that will be
required. Project wide and project related cumulative effects are discussed in
Chapters 16 and 17 respectively.
1.52
To identify non-related projects that potentially needed to be considered within the
cumulative impact assessment, all submitted planning applications for
developments that have been consented within a 1km radius of the onshore
infrastructure within the last two years and also any that are still pending
determination, were identified through a planning search.
1.53
Following this, a scoping exercise was undertaken whereby developments with the
potential to interact with the onshore elements of the Nemo Link were either scoped
’in’ or ‘out’ of the detailed impact assessment.
1.54
Projects that were considered so minor in nature and scale that there could never
realistically be the potential for them to contribute to significant cumulative effects,
for example household applications, were scoped out from further assessment.
1.55
For those developments ‘scoped in’, an information gathering exercise was
undertaken to collect relevant data that would allow a cumulative impact
assessment be undertaken. Table 1.1 presents details of the unrelated
developments considered. Figure 1.2 shows the locations of the planned unrelated
developments. All of the developments are expected to be completed prior to
commencement of the construction of the Nemo Link.
1.56
An assessment of the wider cumulative impacts that may occur between the UK
onshore components of the Nemo Link with non-related developments are
documented at the end of each technical chapter. An assessment of other parts of
the Nemo Link (i.e. the subsea cables and Belgian onshore infrastructure), together
with any cumulative impacts of those works and the Proposed Development, is set
out in Chapter 16 below. Further, an assessment of the other related development
(i.e. the connection to the UK transmission system), together with any cumulative
impacts of those works and the Proposed Development, is set out in Chapter 17
below.
13
Table 1.1: Proposed Unrelated Development
Application
Number
Application
Status
Submitted
December
2012
N/A
N/A
F/TH/12/0690
KCC/TH/0351/2010
or DO/10/954
N/A
F/TH/12/0832
F/TH/12/0144
Submitted
December
2012
Approved
November
2012
Approved
by KCC
July 2011
Future
Application
Submitted
October
2012
Approved
by TDC
June 2012
Development Proposals
Peaking plant facility at the former Richborough Power Station site (TR329623). Facility is designed to
provide top-up supply to the local distribution network at short notice, for example during periods of high
electricity demand or low energy generation. Anticipated the plant will operate for up to 720 hours a year
(30 days equivalent spread throughout the year). Development will comprise of 53 diesel fired
generators with approximately 40 megawatts (MW) output, along with associated fuel storage, parking
and access. The site will occupy an area of approximately 3.37 hectares (ha) and is anticipated to be
operational by 2014.
A 2.60 ha internal road network and structural/estate landscaping around the perimeter of the former
Richborough Power Station site. The internal road network is anticipated to be constructed by 2014.
Pegwell Bay Flood Defence Scheme. Installation of new concrete wall 141 metres (m) long and up to
1.2m high to the north of Pegwell Bay Service Station and installation of an earth embankment, 257m
long and up to 1m high to the south of the service station where the 256 and flood defences are at their
lowest elevation. Construction 2013.
Waste related development on land west of Ramsgate Road, Richborough. Construction of a materials
recycling facility, soil washing plant, anaerobic digestion plant and inert materials processing facility plus
a building to house the anaerobic digester.
A 5MW Solar Farm on land to the west of the River Stour adjacent to the former Richborough Power
Station site. Site area is 13.36 ha. Proposals to include rows of photovoltaic panels, ancillary equipment,
security fencing and associated landscaping. The Solar Farm is anticipated to be operational by 2014.
Erection of glasshouses, three water storage tanks and pack house at Ebbsfleet Lane, Ebbsfleet,
Ramsgate, CT12 5TJ (TR335626).
Erection of an anaerobic digestion plant, silage clamp building, bund, two drainage ponds, and
associated hardstanding and landscaping. The site area is approximately 1.5 hectares.
14
Consultation
1.57
A range of consultations have been undertaken in order to ascertain the interests
and concerns of relevant organisations and authorities and to collect baseline
environmental information for the development area.
1.58
The list of organisations contacted is given below:











Thanet District Council;
Dover District Council;
Kent County Council;
Natural England;
Environment Agency;
English Heritage;
River Stour (Kent) Internal Drainage Board;
Kent Wildlife Trust;
Kent Reptile and Amphibian Group;
Kent Bat Group; and
Kent Ornithological Society.
1.59
Information received from consultees has been taken into consideration when
assessing the potential environmental impacts of the Proposed Development and
when formulating avoidance and mitigation measures to be implemented to help
reduce the impacts of greatest significance. A summary of consultee responses is
provided in Appendix 1.1
1.60
Public information events were held on the 15th and 16th June 2012 at Cliffs End
Village Hall and the Bell Hotel, Sandwich, respectively. Information regarding the
proposals for the Nemo Link was displayed and feedback was invited from local
residents. Information on the Richborough Energy Park was also displayed at the
events.
1.61
A publicity leaflet was delivered to 8,953 residents to publicise the event. The mailout area was the same as that used previously to inform the local community of
proposals for the Energy Park. 106 residents who had previously engaged with the
Energy Park developers either by attending their earlier consultation events or by
contacting the developers directly to discuss the Energy Park proposals, received a
personalised letter. Elected members received a separate letter notifying them of a
stakeholder preview which was held at the public information event on the 15th
June. Elected members also received the letter via email.
1.62
In addition a quarter page colour advert was placed in the following publications to
increase the visibility of the public information events


1.63
East Kent Mercury and Thanet Extra (Thursday 1st May and Thursday 7th
June); and
Kent Messenger (Friday 1st June and Friday 8th June).
167 local residents, elected members and interested parties attended the public
information events over the two dates. Twenty seven residents completed
feedback forms at the information event. The project team has responded to
enquires from residents who were unable to attend the public information events.
15
1.64
Main concerns gained from the public information events included the following:




The visual impact of the onshore infrastructure, in particular the converter
station;
Impact on local residents, notably how disruption on local traffic can be avoided
or reduced and how to ensure residents are kept informed of progress;
The effects of the proposals on wildlife; and
Whether the connection between the proposed converter station and the
existing transmission system will require overhead lines.
1.65
NGNLL has also held meetings to discuss the proposals with Local MPs and
Councillors from Thanet, South Thanet Liberal Democrats in the Guildhall in
Sandwich, Sandwich Town Council, Minster Parish Council.
1.66
Further consultation has included presentations to elected members of Thanet and
Dover District Councils and a newsletter. Feedback from the public and elected
members is summarised within a Statement of Community Involvement which is
included in Appendix 1.2.
Structure of the ES
1.67
This Environmental Statement comprises the following volumes:




1.68
Volume 1 - A document drawing together relevant information about the
scheme and containing figures relating to the detailed technical information for
each of the environmental topics assessed;
Volume 2 - Appendices Part 1;
Volume 2 – Appendices Part 2; and
Volume 3 – Non-Technical Summary.
Volume 1 of the ES is divided into the following chapters:
















Chapter 1 – Introduction.
Chapter 2 - Project Description.
Chapter 3 – Options and Alternatives Considered.
Chapter 4 - Planning Policy Review.
Chapter 5 - Land Use.
Chapter 6 - Ground Conditions and Contamination.
Chapter 7 - Hydrology and Flood Risk.
Chapter 8 – Ecology.
Chapter 9 - Archaeology and Cultural Heritage.
Chapter 10 - Landscape and Visual Effects.
Chapter 11 - Traffic and Transport.
Chapter 12 - Noise and Vibration.
Chapter 13 - Air Quality.
Chapter 14 – Coastal Tourism, Recreation and Socio-Economics.
Chapter 15 – Electric and Magnetic Fields (EMF) and Electromagnetic
Compatibility (EMC).
Chapter 16 – Project Wide Assessment of Effects.
16


Chapter 17 – Assessment of Effects of the National Electricity Transmission
System Connection.
Chapter 18 – Summary and Conclusions.
Availability of the Environmental Statement
1.69
This ES along with other supporting documents are available on the project website
at: www.nemo-link.com
1.70
The ES is also available for viewing at the following locations:
Table 1.2: ES Viewing Public Locations
Thanet District Council Planning Offices – Cecil Street, Margate, Kent, CT9 1XZ
Dover District Council Planning Offices – White Cliffs Business Park, Dover, CT16
3PJ
Thanet Gateway Plus – Cecil Street, Margate, Kent, CT9 1RE
Dover Gateway – 71 Castle Street, Dover, CT16 1PD
Aylesham Area Office – Aylesham Health Centre, Queens Road, Aylesham, CT3
3BB
Sandwich Area Office – Sandwich Area Office, The Guildhall, Sandiwch, CT13
9AH
Deal Library (and area office) – Broad Street, Deal, Kent, CT14 6ER
Minster-in-Thanet Library – 4A Monkton Road, Minster, Ramsgate, Kent, CT12
4EA
Sandwich Library – 13 Market Street, Sandwich, Kent, CT13 9DA
Dover Library – Dover Discovery Centre, Market Square, Dover, Kent, CT16 1PH
St. Margarets at Cliffe – St. Margarets Library Community Centre, Kingsdown, St.
Margarets at Cliffe, CT15 6BB
Ramsgate Library – Guildford Lawn, Ramsgate, Kent, CT11 9AY
Newington Library – Marlowe Academy, Marlowe Way, Ramsgate, Kent, CT12
6NB
Ash Library – Ash Village Hall, Queens Road, Ash, Canterbury, Kent, CT3 2BG
Westgate Library – Minster Road, Westgate-on-Sea, Kent, CT8 8BP
1.71
Further information about the Proposed Development including hard copies of the
ES can be requested by email, Freephone or post at the details below for a cost of
£150.00 per report. Copies of the Non-Technical Summary are available free of
charge. Copies of the ES and other project documents are also available to
download from the project website.
Email: [email protected]
Telephone: 0800 083 3149 between 9am - 5pm, Monday to Friday
(answerphone service available outside of these hours)
In writing from
Freepost RSLG-YXEU-BJUC,
Nemo Link, PO BOX 68215,
London, SW1P 9UJ
17
18
2.0
PROJECT DESCRIPTION
Introduction
2.1
This chapter provides a description of the UK onshore elements of the Nemo Link
(The Proposed Development) (see Figure 2.1). A description of the other
components of the Nemo Link (i.e. the project-wide components, which include the
subsea cables in UK, French and Belgian waters, and the Belgian onshore
infrastructure) is also included.
2.2
Although it is separate to the Nemo Link Project and does not form part of this
application, a brief overview of the National Grid Electricity Transmission (NGET)
infrastructure, required to connect the Nemo Link is provided at the end of the
chapter.
Proposed Development
2.3
The Nemo Link components in the UK which require planning permission under the
Town and Country Planning Act 1990 (TCPA 90) comprise:






2.4
Two high voltage direct current (HVDC) cables between the landfall and the
mean low water mark;
Two HVDC onshore underground cables from the converter station to the
landfall on the coast at Pegwell Bay where they will be joined to the subsea
HVDC cables;
Fibre optic cables installed with the HVDC cables for the purposes of
operational telemetry and communications;
An HVDC converter station on part of the site of the former Richborough Power
Station which would convert the HVDC power used in the link to high voltage
alternating current (HVAC) for use in the national transmission system and
vice-versa;
A 400 kilovolts (kV) electricity substation on part of the site of the former
Richborough Power Station; and
Three 400kV HVAC underground electricity land cables to connect the above
substation to the HVDC converter station and up to two telecommunications
cables for telemetry, control and protection purposes only.
The Nemo Link will operate at a nominal voltage of +/- 350-400 kV.
Converter Station and Substation Site
2.5
The converter station and substation will be constructed on part of the site of the
former Richborough Power Station off Ramsgate Road, Sandwich (A256) (Figure
2.2). The Power Station was decommissioned in 1996. The site is approximately 4
kilometres (km) southwest of Ramsgate, 3.5km north of Sandwich and 1.6km inland
from the east Kent coastline.
19
2.6
Thanet District Council (TDC) and Dover District Council (DDC) granted planning
permission for the demolition of the chimney and cooling towers at the site in
January 2012. Demolition took place in March 2012.
2.7
Planning applications were submitted in December 2012 by Richborough A Ltd for
the parts of the former power station site adjacent this application site. One
application is for a ‘peaking’ power generation plant. Another application is for
roads and landscape works around the perimeter of part of the former power station
site.
2.8
Access to the converter station and substation would be via the existing former
power station entrance from the roundabout on Ramsgate Road (A256). This
access has been improved to contemporary highway standards by work undertaken
in 2011.
2.9
There will be permanent roads around the perimeter of the converter station and
internal roads to provide access to the different building units. The perimeter road
will be constructed ahead of construction of the converter station and substation
and it is being developed under a separate application submitted by Richborough A
Limited (see Table 1.2, Chapter 1). The roads will be used to provide access for
regular and ad hoc maintenance activities and for the delivery of materials to site.
2.10
Landscaping will be implemented around the perimeter of the converter station and
substation to help integrate the proposed development site into the landscape
setting. Landscaping will largely consist of tree planting at the eastern boundary
with existing shrub and poplar trees at the northern boundary being retained and
enhanced. Species rich grassland, areas for a mixture of native and fruit tree
planting and ecological corridors are also proposed as part of the wider landscaping
works. The landscaping will be implemented at the same time as the perimeter
road and is being developed under a separate planning application (see Table 1.2,
Chapter 1).
Converter Station Design
2.11
The converter station will occupy a site of 4.85 hectares (ha) contained within a
secure fenced compound. The majority of electrical equipment will be indoors to
prevent exposure to saline pollution which can lead to damage and the need to
replace equipment.
2.12
The converter station will comprise the following components:

Main Building: This will contain specialist HVDC electrical equipment including
the power electronics equipment that converts electricity from AC to DC (and
vice-versa). The main building will be constructed in part around the steel frame
of the former Richborough Power Station’s turbine hall which was left in situ
following demolition works. The main building will comprise three main parts.
The tallest part to a maximum height of approximately 30.8m will be based
around the former turbine hall frame and will be approximately 38.3m long and
20
93m wide. The remaining two parts will be approximately 25m high, 65.1m
long and 93m wide (main extension) and 18m high, 45.7m long and 65.5m
wide (transformer extension). The total length of the main building will be
approximately 149m. Lightning conductors will be installed approximately 5m
higher than the roof of the main building.
2.13

Service Building: There will be a service building attached to the eastern extent
of the northern face of the main building which will house the control room,
workshop, auxiliary power supply and cooling system. This building will be
approximately 27.4m long, 13.6m wide and 14.5m high.

Storage Building: This will be attached to the western extent of the northern
face of the main building and will be used for the storage of equipment spares
and tools. The dimensions are the same as the Service Building.

Single Phase Converter Transformers: Each transformer is approximately
10.2m long, 8.2m wide and 9.8m high. These transform the voltage from the
national transmission system voltage level to the DC converter station voltage
level. The transformers will be outdoors north of the main buildings. There will
be four transformers on site. Three will be in use at any one time and one will
be a spare in case of a fault arising on one of the operational transformers.
Each of the transformer bays will be separated from the adjoining one by
concrete fire walls and acoustic enclosures. The transformer bays may have a
system of rails constructed in the footings to allow quick removal and
replacement of a transformer in the event of failure in service. The transformer
bays will be provided with bunding, drainage and an underground oil
containment system to prevent any transformer oil escaping into the
environment.

Mechanically Switched Capacitor (MSC): This compound will be used to
regulate and stabilise transmission voltages. This will be approximately 30.2m
long by 25m wide with a height of approximately 11.8m.

Shunt reactor: This has similar dimensions to a Single Phase Transformer and
will also be used to regulate voltages.

Outdoor High Voltage Electrical Equipment: This connects the transformers,
MSC compound, shunt reactor to the electrical plant in the Main Building and
also to the underground cables that connect the converter station to the
substation. The equipment includes busbars, circuit breakers, switches,
insulators and other connecting equipment. The tallest equipment will be
overhead gantries at approximately 15m high.

Distribution Network Operator Substation: This will provide low voltage (11kV)
supplies to the converter station from the local electricity network.

Diesel Generator: This will be approximately 8m long, 3m wide and 3.5m high
and will be used to provide back-up electricity supply in the event of a failure of
the low voltage electricity supply from the Distribution Network Operator.
Figure 2.3 shows a layout of the component parts of the converter station. The
converter station building will be constructed of brick to a height of approximately
21
3m. The remaining sections of the buildings will be formed by a steel frame clad
with metal panels and insulated. Panels will graduate from dark green to light green
to the roofline.
2.14
The converter station will be designed for a 40 year lifespan, with only control
equipment expected to require replacement during that time.
2.15
Lighting will only operate when access to the site is required during maintenance
activities or emergencies; infra-red CCTV will trigger lights to be switched on by
intruder detection. Lighting will be controlled to avoid the unnecessary illumination
of areas beyond the development. Glare and the spread of upward light will be kept
to a minimum to reduce sky glow and minimise visual intrusion within the open
landscape. The need to illuminate the whole perimeter is not necessary. The
entrance and walkways for access/egress and emergency exits will however need
illuminating for safety reasons. Consultation with Manston Airport has confirmed
that beacons are not required on the converter station.
2.16
The perimeter and internal roads will be used to provide access for regular and ad
hoc maintenance activities and for the delivery of materials to site. The main access
into the converter station and substation from the site access off the A256 will be
constructed so that it can accommodate the delivery of transformers by large
vehicles which comprise Abnormal Indivisible Loads (AILs). Access off the A256
roundabout at the entrance of the former power station site will have areas of ‘overrun’ in excess of a standard junction design to allow the wide track required for the
transformer delivery vehicles. The proposed road layout is shown on Figure 2.3.
2.17
Transformers for the converter station and substation will be delivered during
construction under a Transport Order. The route to each part of the site will remain
able to accommodate these loads. Reliability data on transformers of this nature
indicates that failures would not be anticipated at intervals of less than 10 years. In
the event of transformer failure at the converter station, the spare transformer held
on site would be installed and the failed transformer removed to the ‘spare’ storage
area. Transportation of the failed transformer to a contractor’s factory for repair
would then be arranged including the appropriate Transport Order from the
Highways Agency for the abnormal movement.
2.18
Sixteen car parking spaces plus two disabled spaces will be provided. These are
divided into two areas of parking to the east and west of the converter station
building. These will be for operations staff who will be required to monitor and
maintain electrical equipment and plant at the converter station. The spaces are in
excess of normal daily requirements to accommodate visitors and contractors
visiting the converter station and substation site during periods of maintenance.
2.19
The converter station will be surrounded by a 2.4m high palisade security fence.
Electrified security fencing will be installed immediately inside the fence increasing
the overall height of fencing to 4m (Figure 2.4). The completed site will be surfaced
with stone chippings.
Substation Design
2.20
A new 400kV substation is required to connect the converter station to the national
grid electricity transmission system. The 400kV substation forms part of this
22
planning application, however, the connection between the substation and the
national grid is still in early development and does not form part of this planning
application. The connection project is being promoted separately by National Grid
Electricity Transmission (NGET).
2.21
The 400kV Gas Insulated Switchgear (GIS) substation will be built in a separately
fenced compound immediately west of the proposed converter station. The
substation will be connected to the converter station by underground high voltage
alternating current (HVAC) cables.
2.22
The proposed substation will occupy a footprint of approximately 2.65 ha, and will
contain indoor and outdoor electrical equipment. It includes a GIS Hall containing
the switchgear, outdoor Gas Insulated Busbars (GIB), overhead line gantries, two
Supergrid Transformers (SGTs), along the southern extent of the site, a
Mechanically Switched Capacitor (MSC) and a Static Var Compensator (SVC)
compound in the northern part of the substation compound. The MSC and SVC are
specific types of equipment used to regulate and stabilise transmission voltages
and will be located on the north west corner of the substation site. The SVC
compound will contain a transformer and outdoor electrical equipment with a
building for control and operation of the equipment (Figure 2.3).
2.23
The GIS Hall will be approximately 52.2m long, 21.5m wide and 15m high, central
to the substation site and will take the form of a structural steelwork frame, clad with
profiled metal panels, similar to the external appearance of the converter station.
2.24
The Supergrid transformers are approximately 22.5m long by 13.3m wide with a
height of 10.6m. The MSC enclosure is approximately 30.2m long, 25m wide and
approximately 11.8m for the tallest equipment. The SVC equipment would be
approximately 52.6m long, 39m wide and 6.3m high for the tallest equipment. There
are 3 buildings connected to the SVC equipment these would be approximately
12m long, 10.2m wide and 4.4m high.
2.25
The substation compound will also contain an amenity building 16m long, 12m wide
and 4.2m high, a diesel generator building comprised of a single storey prefabricated modular unit 8m long, 3m wide and 3.5m high and a fire water tank, 6m
high.
2.26
The layout of the substation includes two overhead line gantries in the south west
corner of the site approximately 12.7m in height. NGET is currently assessing
options for the connection between the substation and the national grid electricity
transmission system. The connection would be the subject of a separate consenting
process. The layout of the substation has included two overhead line gantries, on
the basis that of the technology types that could be utilised for the connection, the
use of overhead line gantries to provide the terminal connection to the substation,
would be the tallest equipment that could be proposed within the substation to
perform this function.
2.27
The maximum height of the remaining outdoor electrical equipment required to
connect the above equipment together, will be approximately 8m.
2.28
All outdoor areas where plant is installed will be surfaced in stone chippings. The
substation will be enclosed by a 2.4m high palisade fence with a 4m high electrified
23
pulse security fence installed on the internal side of the palisade fence. Internal
surfaced roads will be required to access the buildings, for maintenance and car
parking.
2.29
External lighting will be installed within the fenced compound containing the
substation. This will only operate when access to the site is required, during
maintenance activities or emergencies outside daylight hours. Lighting will be
controlled to avoid the unnecessary illumination of areas beyond the development.
2.30
Permanent access to the substation will be a continuation of the permanent access
developed to the converter station. Direct access into the substation compound is to
the north of the converter station site. Thirteen car parking spaces will be provided.
Construction of Converter Station and 400kV Substation
2.31
The construction of the converter station and substation is planned to be
undertaken over a period of 36 - 42 months from mid-2014 to mid-2018. Both the
converter station and the substation will be commissioned in October 2018.
2.32
Construction will include the activities summarised below:

Preliminary Works: Further site investigation and preconstruction surveys
required to be undertaken in advance of construction;

Site Preparation and Establishment: Vegetation clearance if required,
development of internal site access and establishment of all temporary facilities
including site offices, storage areas and welfare facilities and development of
electricity and water supplies and erection of security fencing or hoarding. It is
proposed that a laydown area will be established and will occupy a site of
approximately 1.6ha adjacent to the substation site on its western edge;

Earthworks: This will include the development platforms on which the converter
station will be located and infill works to create a level site for the converter
station and substation consisting of fill material in the existing cooling tower and
pump room voids. It is anticipated that piled foundations will be required with
footings in construction platforms founded in natural ground or in compacted fill.
Piles will be lifted into position and driven in by a piling rig. A concrete mixing
plant will be installed on site to mix concrete for the foundations and footings.
Crushed rock base course material will be required for hard-standing areas.
Final ground levels will between 3.166 and 3.637mAOD for the substation
compound to alleviate flood risk for 1:200 year and 1:1000 year flood events
plus climate change (see Chapter 7 for further details) and 3.166mAOD for the
converter station compound;

Civil Engineering Works: Construction of building platforms on the piled
foundations, development of the site’s permanent drainage system and
construction of permanent access, internal roads and car parking
arrangements;

Buildings Construction: Construction of all buildings including erection of steel
frames and cladding;
24

Cable Installation: Installation of underground DC cables from horizontal
direction drilling (HDD) location to the converter station. Installation of
underground AC cables to connect the converter station to the substation.
Installation of underground 11kV cables within the converter station for auxiliary
supplies;

Mechanical and Electrical Works: Installation of high voltage AC and DC
electrical equipment in both the converter station and substation and delivery of
transformers;

Commissioning: Following completion of all construction works there will be a
period of commissioning and testing; and

Site Reinstatement and Landscape Works: Removal of site offices and
temporary facilities, land reinstatement and landscape works.
Construction Access Arrangements
2.33
Prior to commencement of construction, a Traffic Management Plan (TMP) will be
prepared in consultation with Kent County Council’s Highways Department. This will
set out all construction access arrangements including agreed access points,
delivery routes and times.
2.34
The access roads into the converter station and substation site will be constructed
prior to the commencement of converter station and substation construction works.
2.35
During the construction period a range of vehicles will be accessing the site
including flatbed trucks delivering plant and equipment, plant including excavators,
bulldozers and cranes as well as cars and vans associated with construction staff
movement.
2.36
Equipment will be delivered to the site, erected and connected using mobile cranes
and hydraulic access platforms. The switchgear and busbars will be delivered to
site in modules, using normal road transport. The modules would be stored on site
in designated storage areas until required for erection.
2.37
Transformers will be delivered to site on heavy-load low loaders and would be
classed as abnormal indivisible loads. The transformers may be factory fitted with
wheels, and lowered from the low loaders using hydraulic jacks direct onto a
permanent rail system built into the transformer footings. Each transformer will then
be winched into position on the rail system to allow a rapid transformer change.
Alternatively the transformers will be skidded into position by the use of a hydraulic
system. Further information about the delivery of transformers to site is included at
Chapter 11 (Traffic and Transport) and Appendix 11.1.
Construction Site Layout
2.38
The construction site for the converter station and substation will be securely fenced
during the construction period. During the construction period there will be a
number of temporary facilities including:

Site offices including offices and meeting room;
25






Staff welfare facilities including portable chemical toilets, kitchen and mess
room;
A laydown area for storage areas for construction vehicles, plant, equipment
and other construction materials;
Appropriately bunded areas to be used for the storage of oils and other fuels;
Wheel washing facilities to be used by construction vehicles and plant;
Rock crushing and concrete batching facilities; and
Segregated waste management storage areas.
HVDC Cables in the Pegwell Bay Intertidal Area
Cable Design
2.39
The Nemo Interconnector will include two subsea HVDC cables between the
landfall points at Pegwell Bay to mean low water and continuing to Zeebrugge. The
cables will be one of two subsea cable types: Cross Linked Polyethylene (XLPE) or
Mass Impregnated (MI). The cables will be rated between 350kV and 400kV. The
size of the subsea cables will depend on the final design and rating but will be
approximately 15cm diameter.
2.40
Extruded HVDC cables use XLPE for their insulation. The insulation is extruded
over a copper or aluminium conductor (copper has a lower resistance and thus a
higher power density, although it is heavier and more expensive than aluminium)
and is covered with a water tight sheath. The sheath is generally extruded
seamless lead for subsea cables
Subsea cables have an additional layer of
galvanised steel wire armour to increase the cable’s tensile strength to help it
withstand the stresses of submarine installation. This armour is usually a single
layer of wires, helically wound around the cable (although in deeper waters or over
rocky sea beds this may be a double layer), and covered in a sleeve of bitumen
impregnated polypropylene yarn to inhibit corrosion.
2.41
MI cable type cable has been widely used on major interconnector projects in
service to date including but not limited to:




UK-France interconnector (IFA);
BritNed, linking the UK and the Netherlands;
Basslink, linking Australia with Tasmania; and
NorNed, linking Norway with the Netherlands.
2.42
The MI cable is a stranded type single copper core cable that has paper insulation
impregnated with high viscosity mineral oil. This cable type is not pressurised like a
fluid-filled cable (which has low viscosity oil) and has no free oil to leak out in the
event of a cable sheath rupture.
2.43
The MI cable core has a concentric construction comprising a central stranded low
resistivity copper conductor with a screen, mass impregnated paper insulation
layers, and an outer dielectric screen made of semi-conducting paper. The core is
26
contained in a lead sheath to protect the insulation from water ingress and a
polyethylene sheath is extruded over this to protect it from corrosion. One, and
sometimes two, layers of galvanised steel armour wires are applied in a helix to
provide mechanical strength during cable handling and installation and protection
from external damage. The armour wires are bedded into a layer of bituminised jute
strings and a layer of polypropylene string is applied over them to bind them in and
provide abrasion resistance and to improve handling.
Cable Installation
2.44
The cables will be bundled together in the same trench and jointed to the HVDC
onshore underground cables in the transition joint pit (TJP). The approximate
distance between Low Water and the TJP will be 1,800m.
2.45
The TJP will be an excavated pit (15m long x 5m wide x 2.5m deep) with a
reinforced concrete plinth laid in its base. The cables will be jointed on the plinth
and once this is undertaken, the excavation will be backfilled to original ground
levels. On completion of works, there will not be any visible sign of the TJP on the
surface.
2.46
The TJP will be above High Water close to Pegwell Bay Service Station (Figure 2.7)
in Sandwich Bay Special Area of Conservation (SAC), Sandwich Bay Special
Protection Area (SPA) and Ramsar site, Sandwich Bay to Hacklinge Marshes Site
of Special Scientific Interest (SSSI) and Sandwich and Pegwell Bay National Nature
Reserve (NNR). These sites of nature conservation have predominantly been
designated for their bird and habitat interest (see Chapter 8, Ecology).
2.47
Access to the site of the TJP off the A256 will be required for mechanical excavator,
concrete deliveries, winches and similar equipment. TJP construction will be
completed well in advance of cable landing operations to avoid any possibility of
delay to the landing operation.
2.48
In preparation for the subsea cables being hauled ashore, the works area,
comprising approximately 1300sqm will be marked off with a tape or a buoy line to
protect the site and the public (Figure 2.5). On the rising tide a shallow water cable
laying vessel will move into position as close to the top of the beach as the tidal
conditions allow. A pulling device, either a winch or a tracked vehicle, and rollers
and quadrants necessary to guide the hauling rope and subsequently each cable,
will be put in place. The cables will be laid from the vessel to the shore individually
A hauling rope will be installed between the beach pulling device and a cable end
on the vessel running through the TJP. Access to this works area will be via the
A256.
2.49
Depending on the state of the tide, the intervening distance between the vessel and
the TJP may be entirely water, entirely dry (with the installation vessel resting on
the seabed) or more probably a combination of both scenarios. Each cable will be
supported at the sea surface by floats attached as the cables leave the vessel and
supported on rollers placed on the seabed where it is above the water line.
27
2.50
Each cable will be hauled towards the TJP with floats being removed as necessary.
When sufficient length of each cable has been passed to the shore to allow for its
correct alignment for jointing to the land cable, it will be secured in the TJP.
2.51
Once the cables have been secured at the TJP and tested to confirm that no
damage has occurred during the installation process, each cable will be
manoeuvred into its correct alignment in relation to the pre-determined route
between the TJP and low water. For cable sections still afloat, the manoeuvring will
be accomplished using workboats, before the remaining floats are removed and the
cables allowed to sink to the seabed. Any cables on dry land leading up to the TJP
will be manoeuvred using excavators or similar prior to burial.
2.52
The experience of Thanet Offshore Wind Farm installing its cables in this area
suggests that the subsea cables can be buried by the main installation vessel
offshore up to a point approximately 1.5km to 2km from the beach. Inshore from
this point, including the intertidal area between low water and high water, other
burial methods will be needed. The methods described below are similar to those
used for the installation of the Thanet Offshore Wind Farm cables.
2.53
In dry areas of the beach, a single trench will be excavated alongside the cables
using conventional mechanical excavators adapted for working on soft soils. The
excavated material will be placed to one side for re-use. Rollers will be used in the
base of the trench to pull the cables along it. The cables installation trench will be
approximately 1-2m wide and the cables will be buried to a target depth of circa 23m. The temporary works footprint will be approximately 10m. A cofferdam may be
required to keep water from entering the trench during excavation.
2.54
Using mechanical excavators the cables will be manoeuvred into the trench bottom
and buried with the material excavated from the trench.
2.55
On completion of trench backfilling in the saltmarsh area on the seaward side of the
TJP, a post and rail and post and wire fence will be erected around the area subject
to works, similar to that erected around the Thanet Offshore Wind Farm cables
installation. Appropriate signage will be fixed to the fence warning that the land
may be unstable.
2.56
The landing operation including landfall preparation and subsea cables installation
is expected to take approximately 4 weeks.
HVDC Onshore Underground Cables
Onshore Underground Cables Design
2.57
HVDC onshore underground cables will connect the subsea cables to the converter
station. The onshore underground cables will be of the same type as the HVDC
subsea cables (XLPE or MI) which will minimise the complexity of the joint at the
TJP. The additional layer of galvanised steel wire armour required for the subsea
cables is not required for the onshore cables. The diameter of each of the onshore
underground cables will be approximately 15cm. The distance from the TJP to the
converter station is approximately 2.1km. The fibre optic cables will be installed
with the onshore underground cables and will be approximately 50mm in diameter.
28
Onshore Underground Cables Installation
2.58
The HVDC onshore underground cables will be delivered to a temporary
contractor’s compound of approximately 30m x 50m in Pegwell Bay Country Park
(Figure 2.5). Access to the compound will be via an existing access route into the
Park. It is anticipated that each drum would weigh approximately 20 tonnes and
would hold around 500m of power cable. The compound will form the base for the
cable installation works from which the main items of plant and workers will travel,
minimising the need for transport.
2.59
The HVDC onshore underground cables will run from the TJP on the coastal side of
the existing cycle track which runs parallel to the A256 Sandwich Road, through
Pegwell Bay Country Park (a former landfill site), then into Stonelees Nature
Reserve and the BayPoint sports complex (the former Pfizer Sports Ground). From
the sports complex, the cables will be routed beneath the A256, Minster Stream,
and a compartment of Hacklinge Marshes SSSI by HDD. The onshore underground
cables will terminate in the converter station site (Figure 2.6).
2.60
Prior to commencement of works along the cables route, a photographic inventory
will be taken and in particular records of the presence and condition of items such
as fences and gates will be made and, where possible, agreed with the landowner
prior to commencement.
2.61
Secure temporary fencing will be erected around the working area (which will vary
as the cables installation progresses). The fencing will define the working area,
protect any sensitive areas and prevent third party access. Access gates will be
installed suitable for both personnel and for movement of plant and equipment. As
vehicle movement will be restricted to one side of the cables trench, a one-way
system with entrance and exit gates or a turning circle will be established at the end
of the fenced section. When each section is complete the fence will be extended or
removed and re-erected around the next work section.
2.62
The onshore underground cables will be installed onshore in three distinct ways
along the length of the route.



2.63
Standard trenching;
Surface laid with capping; and
Horizontal directional drilling (HDD).
The description of installation techniques below refers to the different parts of the
cables route from the TJP to the converter station (see Figure 2.6).
Between TJP and Pegwell Bay Country Park
2.64
Between the TJP and Pegwell Bay Country Park, the cables will be installed using
standard trench methods. Prior to excavation, the surface will be cleared of
vegetation. Trenches will be excavated by hydraulic excavators, except where any
risk to existing services is identified where digging by hand will verify the position of
existing services. The trench cross section will be 1.5m at the surface and will taper
29
to 1m at the bottom of the trench. Excavated topsoil and subsoil will be stored
separately for reinstatement.
2.65
The trench integrity will be assessed in different soil types, and where required the
sides will be shuttered with timber or metal sheets secured by cross braces. This
will prevent collapse and will protect personnel during the works. Where
appropriate, scaffold poles will be placed around the trench to create a safe working
environment for personnel.
2.66
Prior to the onshore underground cables being laid, a layer of cement bound sand
(CBS) will be placed in the bottom of the trench (approximately 60cm deep) to
protect the cables and to help dissipate heat generated when the cables are in
operation.
2.67
Rollers will be placed in the trenches at 2m-3m intervals for cables installation.
Pushing machines will also be placed along the route at appropriate distances. A
winch will be placed at the end of each section. A wire from the winch will be
connected to the cable via a pulling eye. This will guide the cable between the
pushing machines.
2.68
The cables will be pulled into the trench, the cable rollers removed and the cables
placed at the bottom of the trench with a separation distance of approximately
50cm.
2.69
Concrete slabs will be installed 60cm above the top of each cable and plastic
warning tape will be laid directly over the slabs. The material excavated from the
trench will be used to complete backfilling of the trench. The topsoil will be used to
ensure that the upper profile of the backfilled trench is restored to the previous
condition. Any excess subsoil will be removed from site.
2.70
A 10-15m working width for cables installation and a permanent easement of
approximately 5m will be required.
Pegwell Bay Country Park (Northern Section)
2.71
In the northern part of Pegwell Bay Country Park, the cables will be laid on the
existing land surface and chalk will be used to cover them (Figure 2.6). This method
of installation will avoid the risk of disturbing any potentially contaminated ground of
this former landfill site and opening up potential contamination pathways during
cable installation.
2.72
To form a level surface, vegetation and minor undulations will be removed. Cables
will be laid on top of the existing ground within concrete troughs that will be covered
with a concrete lid. Warning tape will then be used to protect the cables.
2.73
A chalk capping layer with 1:5 slope and 1m wide flat section on top will then be
built up over the concrete capping to marry in with existing levels. A cellular
30
confinement system (to manufacturer’s recommendation) will be used to prevent
slippage and potential exposure of cables.
2.74
The chalk cap will be seeded with approved seed mix, for example lowland
limestone mix (British seed houses RE4) or general landscaping wildflower mix for
calcareous soils (WFG5). Where available, local seed will be used rather than a
proprietary seed mix. This will improve the vegetation and biodiversity interest of
the Country Park.
2.75
Much of the land in Pegwell Bay Country Park has already been subject to a
‘capping’ treatment to further cover the landfill below and to allow native vegetation
to establish. The proposed method of cables installation will effectively replicate
this treatment which has been successfully implemented in other parts of the
Country Park.
2.76
A joint pit is required within Pegwell Bay Country Park. This is shown on Figure 2.5.
This will be created using a similar technique to that described for the TJP in Figure
2.7 (joint between the subsea and onshore cables). Joints between onshore cables
require less space and can be achieved more quickly than for the joint between the
subsea cables and the onshore cables. The onshore cables joint pit will be
approximately 15m long and 4m wide. Cable jointing will take approximately 5 days.
Pegwell Bay Country Park (Southern Section)
2.77
This part of the Country Park has previously been subject to capping with chalk.
Trial pits will be dug prior to commencement of works to ascertain the depth of
existing chalk cap over the former landfill site.
2.78
If chalk depth is greater than 1m, the standard trench method described above will
be used. If chalk depth is less than 1m, a hybrid method of trenching and further
capping similar to the method employed in the northern section of the Country Park
will be employed.
Stonelees Nature Reserve
2.79
Standard trenching methods will to be used in this Section. The alignment of the
onshore underground cables will be very close to the edge of the existing cycleway
through Stonelees Nature Reserve to minimise disturbance to adjacent land.
BayPoint Sports Complex to Converter Station
2.80
The onshore underground cables will be installed by open trenching into BayPoint
sports complex. Horizontal Directional Drilling (HDD) will be used from BayPoint
sports complex directly into the converter station to avoid surface disturbance of a
newly constructed roundabout on the A256, avoid disturbance to Minster Stream
and also avoid disturbance to a compartment of Sandwich Bay to Hacklinge
Marshes Site of Special Scientific Interest (SSSI).
2.81
The drilling requires a ‘launch pit’ working area from which the main driving of the
rig will be undertaken and a ‘receptor pit’ working area which will receive the drill
31
driven from the launch pit. The launch pit will be on the converter station site and
comprise of a working area approximately 25m x 40m.The receptor pit on the
BayPoint sports complex will comprise of a working area of approximately 30m x
50m. Access to the launch pit working area will be along the A256 and will utilise
the existing entrance to the former power station site. Access to the receptor pit
working area will be via the A256 and existing sports complex entrance.
2.82
The receptor pit working area will require some temporary roadways to be
constructed to provide suitable access for drilling plant and associated equipment.
The launch pit working area has sufficient access for working and does not require
temporary roadways.
2.83
Installation of conduits by directional drilling is described below and comprises
drilling the pilot holes; reaming (to make the holes bigger); and pulling the conduits
through the reamed holes.
2.84
The following typical equipment will be mobilised to the site and used in the
operation of directional drilling:
•
•
•
•
•
•
•
Excavator;
Drill Rig;
Generator;
Bowsers;
Mud Pump;
Tool and Spares Container; and
Auxiliary pumps.
2.85
The hydraulic drilling process would be undertaken from existing ground level. The
drill string would utilise a drill of approximately 85mm diameter and approximately
6m long with a bend radius of approximately 60m. The head at the end of the drill
string would eject a jet of drilling fluid or ‘mud’, emulsifying the material in front as
the drilling rig pushes the drill string forward. The drill head is slightly bent so that
the jet of mud is slightly off-centre. The direction of drilling is steered by rotating the
drill string and head. The spoil produced would be suspended in mud and washed
back up the bore to the entry point. The location of the drill head will be monitored
with an In Ground Positioning System (IGPS).
2.86
To control water ingress, a short section of oversized bore (approximately 600mm)
would be drilled initially at the entry point. This section will be plugged with
concrete. The main 400mm diameter bore will be drilled through this plug. The plug
will be fitted with a water control valve, through which the drill string passes. The
valve controls the passage of mud and would stop any ingress of water.
2.87
The project will require 3 ducts to be drilled: 2nr 400mm medium density
polyethylene (MDPE) ducts for the HVDC cables and 1nr 355mm MDPE duct for
pilot and fibre optic cables. These will be drilled at approximately 2.5m centres with
the smaller fibre optic duct drilled on the centre line.
2.88
There would be a small pit at the drill launch point to contain the mud and cuttings
exiting from the bore. This will be approximately 6m x 2m x 2m, depending on
ground conditions and the required drilling technique. The drilling system would
32
use a closed-circuit mud management system and the mud would be constantly
pumped out of the pit for processing and re-use.
2.89
The bore would be drilled to within approximately 1m of the exit point and then the
mud circulated out and replaced with water. The water would be used to drill the
last section and ‘punch out’ through into a receiving pit approximately 6m x 2m x
2m. At the last point before emergence of the drill head the drilling fluid pressure
can be reduced and the thrust of the rig can be used to punch out the drill head.
There would be a limited escape of water as the drill string punches out but then the
mud pumps would be turned off.
2.90
If required, the bore can be reamed to make it larger enough to accept the duct.
The drill string would be pulled back through the bore with a reamer attached to
make the hole larger. This will be repeated until the bore is the appropriate size.
2.91
Each duct will be constructed from pipe lengths of MDPE. The pipes would be laid
out and welded together on site to form a duct of sufficient length for the bore.
2.92
The duct may be ‘pushed’ through the bore or pulled from the exit point into the
bore. A ‘tremie’ pipe would be pulled in at the same time on the outside of the
conduit to fill the annulus between the duct and the bore with grout (clay or a
cement mix). The material would be pumped down the tremie pipe as it is slowly
withdrawn from the bore.
2.93
The depth of the bore will depend on the surface features. From the launch pit, the
bore will be at a depth of 1.2m. This will increase to approximately 8m under the
SSSI and 9m under Minster Stream. A depth of 8-10m will be maintained along the
rest of the route with the depth gradually decreasing until it reaches the receiving pit
where it will be at 1.2m.
2.94
The HDD operation between BayPoint sports complex and the proposed converter
station is for a total length of approximately 330m and will comprise 2 HVDC cables
and 1 fibre optic cables (3 bores in total). Each bore will be drilled continuously at a
rate of approximately 20m per hour giving an installation time of 16.5 hours per
bore. This will be doubled to 33 hours per bore to allow for any unforeseen
complications during drilling. There will be a rest period of 1 day (i.e. no drilling at
all) between each of the cable installation phases. HDD is anticipated to take
approximately 1 week.
2.95
At the end of the drilling operation, a draw wire would be left in each duct and the
ducts would be plugged to await cables installation. Drilling fluids and any wastes
would be cleared from the site and excavations backfilled. Any contaminated waste
will be taken to a certified waste site.
2.96
HDD and ducts installation would be completed well in advance of cables delivery
to avoid any possibility of delay to the installation.
2.97
As the cables installation approached the ducts, the duct ends would be excavated,
the plugs removed and draw wire retrieved. The cables trench would be excavated
to the ducts on each side and the cables pulled through the ducts and along the
trench.
33
2.98
The void between the cable and the duct will be filled with bentonite material to seal
the void and aid heat dissipation.
HVAC Land Cables
2.99
Three 400 kV HVAC cables and two telecommunications cables will connect the
converter station to the 400 kV substation. The HVAC cables will be cross-linked
polyethylene (XLPE) type and will be approximately 150mm in diameter. The total
length of the HVAC cables route is approximately 200m.
General Construction Information
Environmental Management
2.100
During construction, the appointed Contractors will be required to operate under a
detailed site specific Construction Environmental Management Plan (CEMP). It will,
as a minimum, set out the requirements to implement the mitigation measures
identified within this ES. The CEMP will set out a variety of control measures for
managing the potential environmental effects of construction works including control
and management of noise, dust, surface water runoff, waste and pollution control.
In addition, the site environmental management will be audited by the developer
and appropriate specialist environmental consultants.
Contractor Responsibilities and Communication
2.101
Contractors will be required to conform to all relevant legislative and statutory
requirements and to comply with British Standards and relevant codes of good
practice during construction works.
2.102
Communication will be undertaken with local residents and communities which may
be affected by or interested in the works. Typical communications include the
delivery of leaflets to local properties, newspaper advertisements and the
establishment of a ‘freephone’ telephone number for interested persons to call with
questions or observations on the works.
2.103
The approach to communications during the works is intended to ensure that
potential causes for complaints or disturbance are avoided where possible and that
if any issues of concern arise, there is a means of communicating with the
developer on that issue.
Staffing and Employment
2.104
The number of staff on site will vary according to the construction phase and
activities being undertaken.
2.105
Staff levels will be at their highest during the earthworks and civil engineering works
phases. Staffing levels will generally decrease as construction is progressed
through to the commissioning phase.
34
2.106
The appointed Contractors will employ a Site Environmental Manager (SEM) or
Environmental Clerk of Works (ECoW) who will be responsible for the preparation
and implementation of the CEMP ensuring that mitigation measures identified in this
ES are appropriately implemented. The SEM or ECoW will be supported by
environmental specialists such as ecologists or archaeologists as required.
Hours of Working
2.107
For the purposes of the Environmental Appraisal it has been assumed that
construction activities will in general be undertaken during daytime periods only,
however, exact arrangements will be agreed with Thanet District Council and Dover
District Council. On weekdays this is anticipated to involve work from 07:00 to
19:00. At weekends, the working hours will be approximately 07:00 to 14:00. There
will be some periods where 24 hour working will be required.
Construction Waste and Spoil
2.108
Subject to geotechnical testing, all excavated materials will be re-used on site
wherever possible. Where waste materials are to be disposed of off-site, this will be
at licensed waste disposal facilities in accordance with a Site Waste Management
Plan (SWMP). The SWMP will be prepared by the Contractor in consultation with
the Environment Agency (EA). A high level SWMP has been prepared as an
accompanying document to this planning application.
General Operation and Maintenance
2.109
The 400kV substation will be an unmanned site subject to infrequent inspections
and maintenance visits whilst in operation. The frequency and duration of
maintenance visits will be dependent on the manufacturer’s recommendations
related to the equipment installed on-site.
2.110
The converter station is likely to operate with approximately 6 personnel per day
divided between 3 shifts over a 24 hour period.
2.111
Inspections and safety checks of the converter station and substation will be
undertaken periodically so it is likely that a small number of staff will be present on
site on a regular basis. National Grid Nemo Link Limited (NGNLL) will be
responsible for on-going maintenance and upkeep of the converter station and
NGET will be responsible for the 400kV substation. This will include regular
inspection of the site and equipment as well as safety checks. From time to time
during refurbishments, detailed inspections and replacement of some components,
there may be larger numbers of personnel on the converter station or substation
sites.
35
Decommissioning
2.112
The anticipated operational life of the converter station, substation and cables is
approximately 40 years. This could however be extended should components be
replaced. It is likely that after 40 years a refurbishment of the equipment will be
undertaken rather than decommissioning.
2.113
Should decommissioning of the converter station and substation be required, the
activities undertaken would be similar in nature to those described previously for
construction. The main components would be dismantled and removed for recycling
wherever possible or for disposal in accordance with the relevant waste disposal
regulations at the time of decommissioning.
Wider Project Components
2.114
The Proposed Development for which planning permission is being sought forms
part of a wider project known as the Nemo Link. The elements of the Project that fall
outside the jurisdiction of the local planning authorities in Kent comprise high
voltage direct current (HVDC) subsea cables passing through UK, French and
Belgian waters, and onshore infrastructure in Zeebrugge, Belgium consisting of a
converter station, substation and onshore cables (see Figure 1.1).
2.115
Applications for consent for the other elements of the Project are being submitted to
the relevant national authorities and each element has been subject to
environmental assessment.
Non-technical summaries of the environmental
assessment documents for the other elements of the Project are appended to this
ES (see Appendix 16.1). The full environmental assessment documents for all
elements of the Project can be viewed at http://www.nemo-link.com
Subsea Cables in UK, French and Belgian Waters
2.116
The subsea cables will be the same as those described for the intertidal area. The
cables will be installed in a bundled configuration, comprising two cables buried in
the same trench.
2.117
Two significant preparation activities are likely to be undertaken prior to installation
of the cables system. These are:
2.118

Clearance of out-of-service telecommunications cables that cross the cables
route; and

Preparation and deposit of bridging and separation structures over any cables
and pipelines that the interconnector cables route crosses.
The cables will be buried into the seabed either by a plough or trenching machine
deployed by the main laying vessel directly or by a support vessel following behind.
To ensure cable protection is immediate, operations may be simultaneous with
burial equipment being deployed by either the cable layer or the support vessel.
36
Alternatively cables may be buried in a ‘post-lay burial’ (PLB) operation, where a
burial machine is deployed days or even weeks later by a separate vessel.
2.119
The programme for the commencement of installation has not yet been agreed but
it is likely that installation of the subsea cable will begin between 2015 and 2017. In
general, installations in European waters are undertaken in the summer season,
broadly between April and October. This period is determined primarily by the high
probability of adverse weather occurring outside of this period.
2.120
The schedule will also be affected by factors such as the requirement for any
ecological mitigation, cable delivery and the availability of vessels.
Belgian Onshore Components of the Nemo Link
2.121
Onshore infrastructure in the UK will be mirrored in Belgium. Components will
include:






Two HVDC subsea cables to make landfall at the beach to the north of the De
Fonteintjes nature reserve, west of the Port of Zeebrugge, Belgium;
Two HVDC onshore underground cables from the converter station to the
landfall on the coast in Zeebrugge where they will be joined to the subsea
HVDC cables;
Fibre optic cables installed with the onshore and subsea HVDC cables for the
purposes of operational telemetry and communications;
A HVDC converter station is proposed for a former military site west of the Port
of Zeebrugge on the eastern side of the N31 national road;
A 400kV electricity substation, called Stevin, on another former military site on
the western side of the N31 national road; and
Three 400 kilovolts (kV) high voltage alternating current (HVAC) underground
electricity land cables to connect the Stevin substation to the high voltage direct
current (HVDC) converter station and up to two telecommunications cables for
telemetry and control purposes only.
Proposed Connection of Interconnector to the National Electricity Transmission
System (NETS)
2.122
New infrastructure will be required to enable the 1000MW capacity of the
interconnector to be connected to the existing National Electricity Transmission
System (NETS). A site has been selected by NGNLL at Richborough for the
proposed converter station and substation. There is no existing National Grid
Electricity Transmission (NGET) 400kV infrastructure in the area surrounding
Richborough to enable a connection to be made. There is therefore a requirement
for a high voltage transmission connection from the proposed substation to a point
on the existing NETS.
2.123
Although they are both part of the National Grid group, National Grid Nemo Link
Limited (NGNLL) and NGET are separate legal entities and their statutory roles are
37
clearly segregated under the Electricity Act 1989. The development of the grid
connection is the responsibility of NGET and is part of its statutory functions as the
holder of a licence to transmit electricity under section 6(1)(b) of the Electricity Act
1989. The operation of an electricity interconnector is a separately licensable
activity under section 6(1)(e) of the Electricity Act. The Act expressly provides that
the same person or company may not hold an interconnector licence and a
transmission licence. It is also important to understand that under the Act, NGET is
obliged to enter into a Bilateral Connection Agreement with NGNLL as would be the
case for all other customers seeking a NETS connection.
2.124
This NETS connection is the responsibility of NGET and will require relevant
consents to be obtained in due course. The form and route of the grid connection
are not yet known, do not form part of this planning application under the TCPA 90
and will be promoted separately by NGET. The type of consent required will
depend on the type(s) of technology proposed for the connection. If an overhead
line is proposed for all or part of the connection, a development consent order
(‘DCO’) will be required under the Planning Act 2008. If an underground cable is
proposed for all of the connection, the proposed installation would be undertaken as
permitted development under Part 17, Class G of the Town and Country Planning
(General Permitted Development) Order 1995. Should a combination of overhead
line and underground cable be proposed for the connection, a DCO would be
required for the entire route.
2.125
In developing the NETS connection, NGET assesses and examines strategic
options and based on this develops route corridors options before the selection of
the preferred route corridor option. As part of developing the NETS connection,
NGET would carry out appropriate consultation and environmental studies. If an
application for development consent under the Planning Act 2008 is required,
NGET would undertake the consultation process prescribed under the Planning Act
2008 and Environmental Impact Assessment as set out in the Infrastructure
Planning (Environmental Impact Assessment) Regulations 2012. NGET anticipates
that, if a DCO application is required, it will be submitted to the Planning
Inspectorate in the third quarter of 2015. Should a proposed connection consist
entirely of underground cables installed as permitted development, EIA would not
be an automatic statutory obligation. In those circumstances, NGET would come to
a view as to whether an EIA was required under the Town and Country Planning
(Environmental Impact Assessment) Regulations 2011. Appropriate consultation
and environmental studies would be undertaken in the event that EIA was not
applicable for underground cables.
2.126
Although it does not form part of the Nemo Link project for EIA purposes, the need
for a grid connection arises as a direct result of the Nemo Link. Accordingly, the
likely significant effects of the grid connection need to be considered as part of this
ES. On the basis that NGET is considering a range of different connection options.
This ES therefore includes an assessment of the likely significant effects of a
connection from Richborough to what NGNLL considers to be likely connection
38
points on the national electricity transmission system (Canterbury North, Cleve Hill
and Kemsley). The effects of a connection to each of these locations using either
overhead line or underground cable is considered and set out at Chapter 17.
39
40
3.0
OPTIONS AND ALTERNATIVES CONSIDERED
Introduction
3.1
This chapter summarises the work carried out to identify and assess suitable sites,
shore landings and cable routes for the Nemo Link which led to the decision to
locate the Proposed Development at Richborough.
3.2
The chapter presents a review of the factors that influenced the choice of landfall
and the cable route for the proposed interconnector and the site of the converter
station. Technology options considered are also discussed.
3.3
A full account of the process that led to the development of the current proposals is
set out in the ‘Nemo Link: Review of Options Report’ (February 2013) which is
provided at Appendix 3.1.
Siting of the Nemo Link
3.4
In all, 28 potential converter station sites were considered by the Nemo Consortium,
along with associated cable landings and routes and connections to the national
electricity transmission system. The work was carried out in a number of phases
during the period 2006 to 2011.
3.5
Prior to 2006, the Nemo Consortium identified 10 locations where an interconnector
might be connected to the high voltage national electricity transmission system.
These were either adjacent to existing NGET substations or in areas where a
substation could be considered feasible. The locations are listed in Table 3.1 below
and shown at Figure 3.1.
3.6
During 2006-7 the Nemo Consortium considered sites and potential landfalls for
each of the 10 potential connection points. The feasibility of a grid connection point
at Richborough was then considered as an 11th option, and Richborough
subsequently formed the basis of an application in 2008 to National Grid Electricity
Transmission (NGET) for a connection to the national electricity transmission
system.
3.7
The potential landfall sites were in locations where there appeared to be sufficient
absence of built development to allow cables to be brought ashore and to be routed
to the potential connection point.
41
Table 3.1: Potential Grid Connections and Landfalls Considered in 2006/2007
Ref
Grid Connection Points
Landfall
1
2
3
4
5
6
7
Sizewell NGET 400kV substation
Bramford NGET 400kV substation
Bradwell NGET 275kV substation
Rayleigh NGET 400kV substation
Shellhaven (Thames Gateway)
Grain NGET 400kV substation
Kemsley NGET 400kV substation
8
9
10
11
Cleve Hill NGET 400kV substation
Canterbury North 400kV NGET
Sellindge NGET 400kV substation
Richborough
Sizewell
Vicinity of Felixstowe
Bradwell
Shellhaven
Shellhaven
Grain
Swale estuary or north of
the Isle of Sheppey
Cleve Hill
Richborough
Folkestone area
Richborough
3.8
The first marine routeing studies and site studies investigating potential converter
station sites and cable routes were undertaken in 2006. These studies were
undertaken primarily using desktop analysis, supplemented by visits to areas and
sites which showed good potential from the desktop studies.
3.9
The issues considered important for a potential converter station site were:






A site of approximately 4 hectares;
The potential for securing the necessary consents and licences;
The scale of anticipated environmental effects and the sensitivity of the
environment;
Whether appropriate interest in land may be available for each potential
converter station site (purchase or long lease);
The feasibility of an appropriate high voltage alternating current (HVAC)
connection to the grid system from the converter station; and
The feasibility of an appropriate high voltage direct current (HVDC) connection
between the converter station and a suitable subsea cables landfall.
3.10
During 2007, land ownership of some sites was investigated. For sites that
appeared to show potential for a converter station development after the desktop
study and site visits, further information and stakeholder opinion was sought from
local planning authorities, Natural England and the Environment Agency. This
culminated in the development of an interim report of the feasibility of all options,
enabling a short list of sites to be taken forward by the Nemo Consortium.
3.11
Subsequent to this, in respect of the short listed sites, further liaison was
undertaken in 2007 with the local planning authorities (Canterbury City Council,
Dover District Council, Swale Borough Council and Thanet District Council), Natural
England, the Environment Agency and Kent Wildlife Trust.
3.12
Details of the findings in respect of each of the shortlisted locations listed above are
set out in the Options Report at Appendix 3.1.
42
Short List of Sites – Kemsley, Shellhaven and Richborough
3.13
Of the 28 site options identified in 2006/7, the Nemo Consortium concluded that the
sites to take forward were Shellhaven, Kemsley and Richborough. Of the three
sites, Richborough was not an existing grid connection point, and therefore the
evaluation needed to recognise the requirement for an onward connection to the
national electricity transmission system from that location. The Nemo Consortium
considered that a connection could feasibly be made to a number of locations in the
region, although the development of the connection would be a matter for NGET to
determine through its strategic options process.
3.14
The announcement of the Thames Gateway development in 2007 ruled out
Shellhaven as an option, leaving a short list of two sites: (i) Kemsley and (ii)
Richborough.
3.15
In 2006, Metoc completed a desktop study of marine routes on behalf of the Nemo
Consortium and concluded that there were feasible marine routes to support the
short-listed sites and that any risks to consent being granted should be manageable
within project timescales. Metoc confirmed that the shortest marine route for the
project was between Richborough and West Zeebrugge and it was noted that the
costs of addressing marine risks were likely to be insignificant in relation to the
capital expenditure of the project.
3.16
Taking the short listed sites forward, in 2007 the Nemo Consortium wrote to
relevant local planning authorities, the Environment Agency, Natural England and
Kent Wildlife Trust specifically regarding the potential sites at Kemsley,
Richborough and Canterbury.
Considerations Leading to Preferred Site – Richborough
3.17
In 2006, the vicinity of Kemsley offered distinct advantages to the Nemo Link in that
there seemed to be useable land suitable for a converter station site close to the
Kemsley NGET 400kV substation, making the AC connection short subject to
detailed routeing. Sites in this area also had good access to the highway and there
were some large industrial buildings in the vicinity. However, the local planning
authority advised that it would find it difficult to support an application for permission
for a converter station in this area because of its anticipated adverse effects on
areas designated for nature conservation and for employment. Additionally, there
are particular challenges to the landing or onshore routeing of DC cables at
Kemsley because of the extensive areas of wetlands designated for nature
conservation value, where installation would be difficult and could cause
disturbance. Land ownership was investigated in 2007, and it was concluded that
there appeared to be no obvious land parcel suitable for the converter station in the
Kemsley vicinity.
3.18
In contrast, in late 2007, the former Richborough power station site seemed to have
the most favourable planning prospects for gaining consent for a converter station
of all the 28 sites considered. It had the advantage of being a ‘brown field’ site
allocated for re-use. Land was also available at this site with a landowner willing to
sell, subject to satisfactory commercial negotiation. It was also close to a suitable
landfall (at Pegwell Bay) and it supported the most direct, least distance subsea
cables connection to West Zeebrugge within acceptable risk parameters. However,
43
in 2007 the former Richborough power station site presented two potential issues of
concern.
3.19
First, the landfall for DC subsea cables at Pegwell Bay is a site with similar nature
conservation designations to the Swale estuary close to Kemsley. However, there
was high confidence that there was an acceptable cable route close to the route of
the Thanet Offshore Wind Farm cables which have been successfully consented
and installed in the bay. The landfall and immediate onshore cables routes would
not be through mudflats, creeks and wetlands which pose higher risk at the Swale
estuary. A review of risks confirmed that the subsea cables route and proposed
landfall at Pegwell Bay posed relatively low risk for the project.
3.20
The second issue of potential risk was the AC connection between the converter
station at Richborough and the national electricity transmission system. The
existing 132kV overhead line between Richborough and Canterbury would not offer
sufficient capacity for the Nemo Link, so a new 400kV connection would be
required.
3.21
If the Richborough site was selected, NGET would undertake a full appraisal of all
potential routes and technology options for the connection in accordance with its
approach to the design and routeing of new electricity transmission lines. However,
as part of its options assessment for the converter station site, the Nemo
Consortium considered the potential for a connection between the Richborough site
and NGET’s 400kV substation at Canterbury and whether there appeared to be any
technical or environmental constraints to indicate that such a connection would not
be feasible.
3.22
There are a number of ecological constraints in the area which would have to be
taken into account by NGET in developing a new connection. In particular, a new
connection could potentially affect a number of designated nature conservation
areas between Richborough and Canterbury including the Stodmarsh Special
Protection Area (SPA), Special Area of Conservation (SAC) and Ramsar, and East
and West Blean Woods SSSI and Thorndon Woods SSSI. Effects on landscape
and views would also have to be considered carefully as there are a number of
settlements and sensitive areas between Richborough and Canterbury including the
Kent Downs AONB, the North Kent Plain National Character Area and the North
Downs National Character Area. There is the potential for an overhead line to be
viewed from within the AONB; however, the OHL would not be routed directly
through it and would be unlikely to affect its wider setting.
3.23
A connection by overhead line could have impacts on the setting of important
heritage assets including the World Heritage Site of Canterbury and the Scheduled
Monument of Richborough Castle, and these impacts would have to be considered
by NGET when developing its connection options. An underground connection
could also have effects on important heritage assets which would require
consideration when developing connection options.
3.24
The Nemo Consortium also noted the presence of residential and business
development and sensitive woodland in the vicinity of the Canterbury North
substation which could present difficulties for the routing of a new line.
44
3.25
Whilst recognising these potential constraints, the Nemo Consortium did not
consider that they would prevent a connection from Richborough to Canterbury
from being made. Although NGET would carry out a strategic assessment of all
options for the connection to the transmission system, the Nemo Consortium
considered that a connection to Richborough was feasible.
3.26
On the basis of this assessment of the short listed sites, the Nemo Consortium
selected Richborough as the preferred site to progress further. The Richborough
site offered suitable land availability, a proven cable landing point and onshore
route to the converter station, and a potential connection to the national electricity
transmission system. In 2008 the Nemo Consortium therefore applied to NGET for
a grid connection at Richborough (and not Canterbury North). In early 2009, NGET
responded with an offer to connect the interconnector to a new substation at
Richborough with a connection date of 2019; the connection date has since been
brought forward to 2018 following a modification application to NGET in December
2010 based on a 1000MW interconnector connection at Richborough using voltage
source conversion (VSC) technology.
Landfall Options near Richborough
3.27
A summary of the cable landfall areas that were considered near to Richborough
are illustrated at Figure 3.2 and detailed below.
1.
Service Station North: This is the area to the north of the petrol station on the
A256 at the west of Pegwell Bay. The Thanet Offshore Wind Farm (TOWF)
cables make their landfall in this area and it is expected that installation of the
Nemo Link cables is technically feasible using similar open cut trenching
methods as used by TOWF. This landfall location is less ecologically sensitive
than other areas of the bay as it would involve minimal crossing of saltmarsh.
The area to the north, Cliff End Beach is important for a population of a
protected bird species (turnstone); the area to the south west has extensive
areas of salt marsh; the area to the south of river mouth (Sandwich Flats) has
sensitivities including ancient dune pasture and is also an area where sand
lizards have been re-introduced. However, a landfall at Service Station North
would require crossing the TOWF cables both offshore and onshore which
would introduce risks to both sets of cables and risk that excavation and
disturbance during installation would be prolonged.
2.
Service Station South: This is the area to the south of the petrol station located
at the west of Pegwell Bay on the A256. This location shares the benefits of the
Service Station North landfall noted above but avoids the need to cross the
TOWF cables. The quality of saltmarsh that would be disturbed in this location
is poorer than other areas of saltmarsh within Pegwell Bay.
3.
Cliff End Beach: This area is in the northern part of Pegwell Bay. Cable
installation would require Horizontal Directional Drilling (HDD) through the cliffs
at the back of the bay which may disturb a population of turnstone, a species
for which Thanet Coast and Sandwich Bay SPA is designated. An offshore
crossing of the TOWF cables would also be required for this option and the
onshore route cables route would be longer than that required than for other
options.
45
3.28
4.
Sandwich Flats: This landfall is to the southern extent of the bay south of the
mouth of the River Stour. There are considerable disadvantages with this
landfall owing to its remoteness, difficulty in obtaining access, ecological
sensitivities including the presence of ancient dune pasture and the adjacent
sand lizard re-introduction area.
5.
Country Park: This landfall is located in the southern extent of the bay north of
the mouth of the River Stour. This area is a former landfill site for which
records are incomplete. This option would present considerable engineering
challenges to avoid opening a possible pathway for any contaminants in the
landfill to escape and would pose environmental risks.
6.
River Stour: This would involve installation of the cable in the mouth of the
River Stour, making landfall at Richborough Port. The width of the river channel
and estuarine environment present considerable risk to the environment and
the Project. In the event that there was any future development of the Port or
riverside which could involve changes to the channel including dredging, the
cables would pose a substantial obstacle or would require removal.
Based on technical and environmental assessment of the alternatives, the proposed
cable landfall is in the area of the Service Station South option. The subsea cables
would be installed beneath the inter-tidal mudflats from low water to a Transition
Joint Pit (TJP) south of the Pegwell Bay Service Station in an area of degraded
saltmarsh. The subsea cables would be connected by joints to the onshore
underground cables.
Onshore Underground Cable Route Options
3.29
The optimum onshore underground cables route from the landfall to the former
Richborough Power Station site was identified from an initial feasibility study.
Specific factors taken into account included:










3.30
Designated sites of nature conservation;
Presence of protected species;
Proximity to residential areas;
Archaeology;
Highways;
Planning proposals;
Watercourses;
Risk of encountering contamination;
Utilities and services; and
Land use.
Routeing along Sandwich Road (A256) offered the shortest route and would avoid
potential direct effects on Pegwell Bay nature designations including Sandwich Bay
Special Area of Conservation (SAC), Sandwich Bay Special Protection Area (SPA)
and Ramsar site, Sandwich Bay to Hacklinge Marshes Site of Special Scientific
Interest (SSSI) and Sandwich and Pegwell Bay National Nature Reserve (NNR).
The road also comprises made ground, so trenching would be unlikely to impact
upon archaeological features as these would previously have been unearthed. A
utilities search demonstrated that the ground beneath the road is already congested
46
with electricity and telecommunications cables and foul water and drinking water
pipelines. Thanet Offshore Wind Farm cables have also recently been routed
beneath Sandwich Road from its landfall north of Pegwell Bay Service Station to
where it connects to a substation on the former Richborough Power Station site.
There is insufficient space to accommodate the two HVDC cables along the A256.
3.31
The verge on the landward side of the A256 within St Augustine’s Golf Course
offered an alternative routeing option. Potential direct effects on designated sites of
nature conservation would be avoided. However installation would cause disruption
to the use of land for golf. Future development plans to raise and remodel the golf
course with an unknown overburden also make this option unsuitable for the burial
of the HVDC cables. The onshore underground cables for each project are
designed to function efficiently within a series of parameters including the known
depth of burial. Where land above the cables would change substantially, this
would affect the capacity or rating of the cables, limiting the effectiveness of the
Nemo Link. If the cables are buried deep below ground it can be very difficult to
repair them in the event of failure.
3.32
Routeing further inland, directly across the Golf Course to Cottington Road and
around Ebbsfleet Lane would mean a longer route but would result in fewer direct
effects on the present golf course. However, this area is also planned for
improvement including an, as yet, undefined overburden. There are also ‘pinch
points’ around which it would be difficult to route at St Augustine’s Golf Course Club
House, Weatherlees Hill Wastewater Treatment Works and the East Kent Access
Road.
3.33
The preferred route of the HVDC onshore underground cables will run from the TJP
on the coastal side of the existing cycle track which runs parallel to the A256
Sandwich Road, through Pegwell Bay Country Park, then into Stonelees Nature
Reserve and BayPoint sports complex. From the sports complex, the cables will be
routed by horizontal directional drilling (HDD) beneath the A256, Minster Stream,
and a compartment of Sandwich Bay to Hacklinge Marshes SSSI terminating in the
converter station. The overall length of the onshore cable route from the TJP to
converter station site is approximately 2.3km. This route offers a short, technically
and environmentally acceptable route which minimises disturbance to local
residents, landowners and environmental features.
Technology Options
3.34
There are a number of technology options for the design and principal components
of the Nemo Link and these are outlined in brief below with reasons for the selection
of the technology chosen.
HVAC or HVDC
3.35
In order to connect the national high voltage grid systems of Belgium to that of the
UK, a subsea cables connection is required. The only method of efficiently
transferring electricity over the distance between the two countries is HVDC
technology (as opposed to HVAC technology). For HVAC cable lengths in excess
of a few tens of kilometres, the charging current creates a reactive power
component that reduces the capability of the system to transmit power. In the
terrestrial environment intermediate shunt compensation reactors (SCRs) can be
47
stalled in HVAC cable systems to compensate for the reactive power and restore
the power transfer efficiency. SCRs contain assemblies of electrical components of
considerable physical size which would be impractical to install in the subsea
environment.
3.36
HVDC does not suffer from reactive power losses and, by optimising the operating
voltage and copper conductor cross-sectional area, system losses can be
minimised and the link made highly efficient.
3.37
The higher cost of an HVAC connection also makes HVDC transmission the most
appropriate option to economically exchange power flows between the UK and
Belgium.
HVAC-HVDC Conversion Technologies
3.38
There are two HVAC-HVDC conversion technologies available that could meet the
power rating required for the Nemo Link. These are self-commutated voltage source
conversion (VSC) and line-commutated current source conversion (CSC). The
Nemo Link will use VSC technology in a symmetrical monopole configuration. The
main benefit of VSC technology is that less reinforcement work is necessary on the
UK and Belgian transmission networks in order to provide assurance of a
connection date in 2018.
Monopole or Bipole Configuration
3.39
HVDC Interconnectors can be configured either as monopole or bipole systems.
The configuration dictates the number of HVAC/HVDC converter valves in the
converter station and also the type of return path used to complete the electric
circuit.
3.40
Bipole systems transmit power via a closed circuit of two high-voltage conductors of
opposite polarity connected to four HVAC/HVDC converter valves.
3.41
Monopole systems have a single high-voltage conductor, at either negative or
positive polarity connected to a single converter at each end. The return path
maybe through the earth (and sea) or via a second cable. Using an earth return
requires large copper electrodes to be placed near each end of the link to feed the
return current into the earth and sea. Although monopole interconnectors with earth
returns operate successfully in a number of locations without adverse effects on
local environments, concern has sometimes been expressed in respect of recent
possible similar installations. These concerns generally relate to the effects on the
marine environment of electrolysis products from the electrodes and the possible
effects on metallic structures (such as pipelines) of stray currents.
3.42
If a return conductor, known as a metallic return cable is used this is usually a cable
with a lower voltage rating, although it carries the same current as the pole cable.
Monopole systems may also use a metallic sheath around the main conductor as
the return path (known as an integrated return conductor or IRC). Monopole
systems with an IRC metallic return cable are often confused with bipolar systems.
Monopole systems with metallic return presently available do not have the
necessary power rating required for the Nemo Link.
48
3.43
HVDC means the most efficient link can be constructed. The use of HVDC
technology for the link means that a converter station is required at each end of the
link to convert between HVDC power and HVAC power, as used in the national grid
transmission system.
HVDC Overhead or Underground
3.44
The HVDC transmission between the subsea cables landfall and the converter
station could be achieved by overhead transmission (overhead lines suspended
from lattice steel towers (pylons) or other supports) or by underground cables. The
key factors in considering whether underground or overhead transmission is used
are cost, both capital and operational, and environmental effects. Underground
transmission is generally more expensive than overhead transmission.
3.45
Operational costs relate to the risk of the link being unavailable, due to the repair of
damage or maintenance requirements, and the costs of the repairs and
maintenance required. Once the connection point was identified, an assessment
was made of the most appropriate means of transmission from the landfall to the
converter station.
3.46
When considering whether underground or overhead transmission is appropriate,
technical reasons are explored why one means is preferred to the other and also
whether there are environmental reasons which justify the additional costs incurred
in installing and maintaining underground rather than overhead transmission
equipment.
3.47
Experience of operating outdoor above-ground HVDC electrical equipment in
coastal locations indicates a relatively high level of faults due to the combinations of
salt-laden air and pollution causing insulation problems. Underground transmission
would be technically advantageous, reducing the need for maintenance and the
risks of faults, for routes up to 3km inland from the landfall.
3.48
Changing from underground cables (as will be present at the landfall) to overhead
transmission is costly. The high costs are due to the sealing-end compounds
required where the cable is brought to the surface and connected to conductors
suspended from overhead line supports. A sealing end compound would also be
required to allow a cable connection from an overhead line at the converter station
site. The costs of the sealing end compounds, and land for tower footprints, are
generally offset by the lower costs of the subsequent overhead line as compared to
underground cables over the same route. This cost saving is not apparent where
there is only a very short distance of overhead line between sealing end
compounds. There is, therefore, relatively little cost benefit in transferring from
underground to overhead transmission for a short distance.
3.49
As the converter station site is less than 3km from the coast at the former
Richborough Power Station site, the connection from the landfall to converter
station site will be by underground cables.
49
Conclusions
3.50
Alternative converter station sites, underground cable routes, landfalls and subsea
cable routes were considered as part of the development of the Nemo Link. This
established that a converter station site at Richborough and an underground cables
route to a landfall at Pegwell Bay was the preferred option as this best meets the
project objective relating to technically feasibility, economic viability, deliverability
and the least disturbance to the environment and people.
3.51
Following selection of the preferred option, further detailed environmental and
technical studies as well as consultation have been used to refine the preferred
option and further reduce the potential environmental effects of the Nemo Link
project including the substation which the convertor station is required to connect to.
This included considering emerging results from environmental assessments with
initial technical designs and results of consultation with stakeholders, land owners
and local communities.
3.52
The following chapters provide a detailed assessment of the effects of the preferred
option on the environment and identify mitigation measures which will minimise
effects of installing the proposed onshore underground cables and constructing and
operating the proposed converter station and substation.
50
51
52
4.0
PLANNING POLICY REVIEW
Introduction
4.1
An application for the Proposed Development will be made under the Town and
Country Planning Act (TCPA) 1990. Planning applications must be determined in
accordance with the development plan unless material considerations indicate
otherwise
4.2
This chapter presents an assessment of the national, regional and local planning
policies that are relevant to the Proposed Development.
National Planning Policy
National Policy Statement for Energy (EN-1)
4.3
The National Policy Statements, approved by Parliament in July 2011, set out the
most recent Government policy for the delivery of major energy infrastructure.
These will be a material consideration in England and Wales, including those which
fall under the Town and Country Planning Act 1990 (as amended).
4.4
The Overarching National Policy Statement for Energy (EN-1) notes that it is critical
that the UK continues to have secure and reliable supplies of electricity as we make
the transition to a low carbon economy. This means ensuring that:




4.5
There is sufficient capacity (including a greater proportion of low carbon
generation) to meet demand at all times, including a safety margin of spare
capacity to accommodate fluctuations in supply or demand;
This capacity is reliable enough to meet demands as it arises;
There is a diverse mix of technologies and fuels (including primary fuels
imported from a wide range of countries); and
There are effective price signals, so that the market can react in a timely way to
minimise imbalances between supply and demand.
The Government’s objectives for energy and climate change will require further
diversification of the UK’s energy sources and much greater use of renewable and
other low carbon forms of generation. It recognises the important role that
interconnection can play in compensating for the intermittency of renewable
generation. The NPS notes that ‘existing transmission and distribution networks will
have to evolve and adapt in various ways to handle increases in demand’ and the
fact that generation is now occurring in a greater diversity of locations.
National Policy Statement for Electricity Networks Infrastructure (EN-5)
4.6
The National Policy Statement for Electricity Networks Infrastructure (EN-5)
highlights that the new electricity generating infrastructure that the UK needs to
move to a low carbon economy, while maintaining security of supply, will be heavily
dependent on the availability of a fit for purpose and robust electricity network. That
network will need to be able to support a more complex system of supply and
demand and cope with generation occurring in locations of greater diversity.
53
4.7
The NPS sets out the basis for assessing proposals. It advises for a variety of topic
areas (including many of those normally covered in an Environmental Impact
Assessment) that the applicant's own assessment should address. It also advises
on the weight to be given to certain issues and on the treatment of mitigation
measures, particularly how these may be enforced through conditions or
obligations. Any assessment will also need to cover those issues raised in the
Overarching NPS for Energy (EN-1). The Environmental Statement (ES) submitted
with this hybrid planning application addresses the issues raised in the NPS.
National Planning Policy Framework
4.8
The Government published the National Planning Policy Framework (NPPF) in
March 2012. The NPPF sets out the Government’s planning policies for England
and replaces the majority of planning policy guidance notes including Planning
Policy Guidance (PPG) and Planning Policy Statements (PPS).Some PPSs remain
in place such as PPS 10 (Planning for Sustainable Waste Management) which was
recently published. Guidance contained in many other PPSs and PPGs is no longer
relevant and development must now be considered in relation to the NPPF (along
with any retained PPSs and PPGs).
4.9
The NPPF is a material consideration in planning decisions and guides the
development of Local Plans. Policies from the NPPF relating to the Proposed
Development are outlined below.
4.10
The NPPF emphasises the importance of delivering and planning for sustainable
development and is based on 12 principles that should under-pin plan making and
decision taking. The following four principles are particularly relevant to the
Proposed Development:




4.11
‘seek to secure high quality design and a good standard of amenity for all
existing and future occupants of land and buildings.’;
‘support the transition to a low carbon future in a changing climate....and
encourage the reuse of existing resources including conversions of existing
buildings…’
‘contribute to conserving and enhancing the natural environment…prefer[ing]
land of lesser environmental value where consistent with other policies in this
framework.’
‘encourage the effective use of land by reusing land that has been previously
developed (brownfield land), provided that it is not of high environmental value.’
The NPPF sets out 13 sub-topics beneath the goal of Delivering Sustainable
Development. The most relevant of these to the Proposed Development are set out
below.
Building a Strong, Competitive Economy
4.12
The Government is committed to ‘meeting the twin challenges of global competition
and of a low carbon future’ using the planning system to support economic growth.
Delivery of the Project would support the move towards a low carbon future as the
benefits of interconnectors between countries include supporting the use of
renewable power generation such as wind power. The ability to trade electricity
between countries allows better use of renewable energy when resources are
54
available and support increased security of supply which sustains the economic
growth of the nation.
4.13
The proposed converter station and substation would be built on the site of the
former Richborough Power Station which is derelict brownfield land. The Proposed
Development is consistent with and reinforces plans for the future development of
the Richborough Energy Park. The construction work will create jobs and increase
economic activity in the area. The agglomeration of energy industries on the former
Power Station site will create a cluster of high technology energy industry.
Requiring Good Design
4.14
The NPPF establishes the importance of achieving high quality design that has a
positive effect on the environment. It states that permission should be refused for
development of poor design that fails to take the opportunities available for
improving the character and quality of an area and the way it functions. Local
planning authorities should not refuse planning permission for building or
infrastructure that promotes high levels of sustainability because of concerns about
incompatibility with an existing townscape.
4.15
The Proposed Development demonstrates good design through the location of the
converter station and substation on derelict brownfield land. As part of the design
process, assessments of the impact of the Proposed Development on landscape
and views and on archaeology and cultural heritage have been undertaken to
ensure the effects of the development are as low as possible. The siting of the
substation and convertor station seeks to use the existing turbine hall and has also
been considered in accordance with National Grid’s guidelines for substation
location, the Horlock Rules which are presented in Appendix 4.1. The external
appearance of the buildings located with convertor station and substation will be
similar in colour and style.
4.16
The converter station and substation will be adjacent to the proposed Richborough
Energy Park and will create a hub of energy infrastructure. The buildings at the
converter station and substation will be similar to those already in the local area and
those of the proposed Energy Park. The site will be subject to a landscaping
scheme proposed for the Richborough Energy Park (pending planning application
submitted by Richborough A Limited); a Section 106 agreement will ensure the
delivery of a scheme separate from that development if required.
Meeting the Challenge of Climate Change, Flooding and Coastal Change
4.17
The NPPF sets out the importance of the planning system in securing reductions in
greenhouse gas emissions, minimising vulnerability and providing resilience to the
impacts of climate change. Decision making can also support the delivery of
renewable and low carbon energy, and associated infrastructure, which is central to
the economic, social and environmental dimensions of sustainable development.
4.18
The Project helps to meet the challenge of climate change by supporting the use of
renewable energy as described in paragraph 3.7 above.
4.19
The converter station and substation will be constructed on the former Richborough
Power Station site. The site is not in an area at risk of flooding. Sections of the
55
cable route travel through Flood Zones 2 and 3. A Flood Risk Assessment has
been carried out to ensure the risk of flooding in the local area or elsewhere would
not increase as a result of the development.
Conserving and Enhancing the Natural Environment
4.20
The planning system has a role to contribute to and enhance the natural and local
environment. Valued landscapes and ecosystems should be protected, with
development prevented from adversely affecting soil, air or water, or from causing
noise pollution and land instability. Effective use of land by re-using land that has
been previously developed should be encouraged.
4.21
The potential effects on the natural environment as a result of the Project have
been assessed within this EIA particularly in Chapter 8 (Ecology), Chapter 10
(Landscape and Views) and Appendix 8.9 (Information for Habitats Regulations
Assessment).
4.22
The subsea cables will fall to land and connect with the onshore underground
cables in Pegwell Bay which is part of a larger designated site comprising:





Thanet Coast and Sandwich Bay Special Protection Area (SPA) and Ramsar
Site;
Thanet Coast SAC;
Sandwich Bay Special Area of Conservation (SAC);
Sandwich Bay and Hacklinge Marshes Site of Special Scientific Interest (SSSI);
and
Sandwich and Pegwell Bay National Nature Reserve (NNR).
4.23
There is a Local Wildlife Site immediately southwest of the power station site, and a
Roadside Nature Reserve east of the A256 Sandwich Road, adjacent to Pegwell
Bay Country Park, designated for its botanical interest.
4.24
There is also a Regionally Important Geological Site (RIGS) in the National Nature
Reserve, close to Cliffs End. The site is an infilled dry valley and is one of only two
sites where a section through a filled dry valley is available for study. The site
demonstrates the effects of Ice Age periglacial processes on the chalklands of
Britain.
4.25
Where any impacts have been identified during ecological assessments,
appropriate mitigation measures have been included to reduce the adverse effect of
the Project and, where appropriate such as in Pegwell Bay Country Park, to provide
enhancement of existing conditions.
Localism Act 2011
4.26
The Localism Act contains provisions to alter the planning system and allow the
Secretary of State to make orders revoking Regional Spatial Strategies (RSS).
Orders have not yet been made for the revocation however the Government is
currently carrying out sustainability appraisals for the revocation of RSSs in due
course.
56
Regional Planning Policy
The South East Plan (2009)
4.27
At the time of writing, the South East Plan continues to be a material consideration
in the planning process, although relatively little weight should be given to the
policies it contains. The following policies are noted from this plan as relevant to
the Proposed Development.
CC1: Sustainable Development
4.28
Based on the guiding principles of the UK Sustainable Development Strategy 2005,
this policy states that local development documents should ensure development
meet obligations in relation to greenhouse gas emissions and take a precautionary
approach to climate change. Development should relate to environmental limits
and ensure that physical and natural environment is conserved. The Project
supports renewable energy which is important in delivering sustainable
development.
CC2: Climate Change
4.29
This policy states that measures to mitigate and adapt to current and forecasted
effects of climate change will be implemented through application of local planning
policy and other mechanisms. The policy establishes levels for a reduction of the
emission of carbon dioxide for the region to 2050. The Project supports renewable
energy which is likely to displace less-efficient carbon-based generation.
CC4: Sustainable Design and Construction
4.30
The design and construction of all new development, and the redevelopment and
refurbishment of existing building stock will be expected to adopt and incorporate
sustainable construction standards and techniques. This will include high standards
of sustainable development including aspects such as energy, water efficiency,
biodiversity gain and securing increased recycling of construction and demolition
waste.
4.31
The Proposed Development is on a brownfield site re-using an area previously used
for power generation. The steel frame of the former turbine hall of Richborough
Power Station has been incorporated into the design, seeking re-use of the
structure. There will be biodiversity gain along the cables route from new chalk
grassland.
CC6: Sustainable Communities and Character of the Environment
4.32
Policy CC6 states that actions and decisions associated with the development and
use of land will actively promote the creation of sustainable and distinctive
communities. This will be achieved by developing and implementing a local shared
vision which respects, and where appropriate enhances, the character and
distinctiveness of settlements and landscapes throughout the region, and uses
innovative design processes to create a high quality built environment which
promotes a sense of place. This will include consideration of accessibility, social
inclusion, the need for environmentally sensitive development and crime reduction.
57
C4: Landscape and Countryside Management
4.33
This policy places a responsibility on local authorities to recognise and protect and
enhance diversity and local distinctiveness of the countryside character. In
exceptional circumstances where damage to the landscape character is
unavoidable, mitigation should be included as part of development. The siting of
the proposed converter station and substation would avoid damage to landscape
character.
NRM1: Sustainable Water Resources and Groundwater Quality
4.34
Policy NRM1 ensures that water supply and groundwater will be maintained and
enhanced through avoiding adverse effects of development on the water
environment. The ES demonstrates no adverse effects on water supply and
groundwater.
NRM4: Sustainable Flood Risk Management
4.35
Coastal and river flooding is a significant risk in parts of the South East of England.
The priorities are to defend existing properties from flooding and locate new
development where there is little or no risk of flooding. The assessment of flood
risk presented in the ES demonstrates that the siting of the converter station and
substation would not present a risk of flooding. The underground cables would not
pose risks of flooding.
NRM5: Conservation and Improvement of Biodiversity
4.36
Local authorities should ensure that internationally and nationally designated sites
are given the strongest level of protection to avoid development that has adverse
effects on the integrity of sites of European or international importance for nature
conservation. The Project’s subsea cables fall to land in designated site. Careful
design and assessment of potential effects has ensured that there would be no
adverse effects on the integrity of the Pegwell Bay site which is of European and
national importance.
NRM15: Location of Renewable Energy Development
4.37
Local development documents should encourage the development of renewable
energy in order to achieve the regional and sub-regional targets. Renewable energy
development, particularly wind and biomass, should be located and designed to
minimise adverse impacts on landscape, wildlife, heritage assets and amenity.
Priority should be given to development in less sensitive parts of countryside and
coast, including on previously developed land and in major transport areas.
BE6: Management of the Historic Environment
4.38
Planning authorities should identify, protect, conserve, and where appropriate,
enhance the historic environment of the region and its historic assets which
contribute to the local and regional distinctiveness of the South East of England.
There would be views of the proposed converter station and substation from the
Scheduled Monument of Richborough Fort although no significant adverse effects
are forecast.
58
Local Planning Policy
4.39
The majority of the Proposed Development falls within the administrative boundary
of Thanet District Council (TDC). Approximately 720m of the onshore HVDC cable
and a small area at the south east corner of the proposed converter station
compound (outdoor hard landscaping and security perimeter fencing) is within the
administrative boundary of Dover District Council.
4.40
Development control decisions in Thanet District are based on saved policies from
the 2006 Thanet Local Plan. Thanet District Council is in the process of preparing a
Core Strategy, which will establish policies for the future development of the Thanet
District. The Thanet Core Strategy – Preferred Options Consultation Document
although not yet adopted, is a material consideration in determining planning
applications. Saved planning policies from the Thanet Local Plan and the Core
Strategy Preferred Options Consultation Document have been assessed against
the Proposed Development in Tables 4.1 and 4.2 respectively.
Table 4.1: Relevant Policies from the Thanet District Local Plan Adopted 2006
Thanet District Local Plan Adopted 2006 – Saved Policies
Policy
Policy Summary
Assessment of Policy
TR4: New Road
and Highway
Improvements
The Council will seek
the implementation of
improvements to dual
carriageway standard to
the A256 and A299
between Richborough,
Lord of the Manor and
Mount Pleasant known
as Phases 1 and 2 of
East Kent Access.
TR8: Rail Link
Safeguarding
Direction
Safeguarding direction
for development
affecting the route
corridor for the Channel
Tunnel Rail Link (CTRL)
and any additional land
required for associated
works.
TR12: Cycling
The Council wishes to
promote the use of
cycling through
implementing a network
of cycle routes.
59
Phase 2 of the East Kent Access is
complete and this route will be included in
the Transport Plan for construction traffic.
The use of a major road network will
reduce the risk of adverse effects of
construction traffic on the local road
network.
Access for the construction of the
converter station and substation site will
be from the site access off the A256.
The cable route will cross beneath the
A256 using HDD so that the new bypass
and other land uses nearby are not
disturbed.
Land at the former Richborough Power
Station was safeguarded because it
provides access to sidings which were
needed for storage of ballast during the
construction of the CTRL. The Directions
have not yet been withdrawn although the
CTRL is complete; the Proposed
Development is not anticipated to cause
any substantial harm to Policy TR8.
The converter station and substation will
require a maximum of 6 personnel on site
per day. The site is adjacent to the Viking
Coastal Trail (Sustrans Route 15) suitable
for access on foot or by bicycle. Cycle
parking is proposed on site.
Thanet District Local Plan Adopted 2006 – Saved Policies
Policy
Policy Summary
Assessment of Policy
TR16: Parking
Provision
Proposals for
development will be
required to make
satisfactory provision for
the parking of vehicles
(including, where
appropriate, service
vehicles).
HE11:
Archaeological
Assessment
The Council may require
the applicant to provide
an assessment of
archaeological or
historic importance of
the site in question and
the likely impact of
development.
Archaeological sites will
be preserved and
protected. On those
sites where permanent
preservation is not
warranted, planning
permission will only be
granted if arrangements
have been made by the
Developer to ensure that
time and resources are
available to allow
satisfactory
archaeological
investigation and
recording by an
approved archaeological
body to take place in
advance of and during
development.
Development which
would result in the loss
or obstruction of
geological features of
importance for study
and research purposes
will not be permitted.
HE12:
Archaeological
Sites and
Preservation
NC6: RIG
(Regionally
Important
Geological) Sites
60
Car parking on site needs to consider
occasional operational requirements
which mean that there needs to be
sufficient space for workers attending for
refurbishment or emergency works to
equipment. 18 parking spaces are
proposed for the converter station
(including 2 disabled spaces); 13 parking
spaces are proposed for the substation
(including 1 disabled space).
An archaeological assessment has been
provided at Chapter 9 of the ES. No
significant adverse effects are anticipated.
An archaeological assessment is provided
at Chapter 9 of the ES. No significant
adverse effects are anticipated.
The development is distant from and will
not affect any RIGS.
A geological assessment has been
carried out and details are presented in
Chapter 6 of the ES.
Thanet District Local Plan Adopted 2006 – Saved Policies
Policy
Policy Summary
Assessment of Policy
EP5: Local Air
Quality
EP9: Light
Pollution
Policy SR10:
Public Open
Space
Permission will not be
granted for new
development proposals
that exceed the National
Air Quality objectives.
Development proposals
that might lead to such
an exceedance resulting
in unacceptable effects
on human health, local
amenity or the natural
environment will require
the submission of an Air
Quality Assessment.
Development that
includes the
provision of new
outdoor lighting
should be designed
to minimise light
glare, light trespass,
spillage and sky glow
so as to preserve
residential amenity,
the character of the
surroundings and
prevent disturbance
to identified wildlife
areas.
Development will only
be permitted on public
open space in very
exceptional
circumstances and only
if the proposed use is of
a temporary or seasonal
nature and cannot be
accommodated
elsewhere without
conflict with areas of
nature conservation or
other development plan
policies. The land shall
be reinstated as public
open spaces
immediately after the
temporary or seasonal
use is ceased.
61
There will be no effects on air quality
following the implementation of mitigation
measures during the construction of the
Proposed Development. No operational
air quality effects are anticipated.
An air quality assessment is provided at
Chapter 13 of the ES.
Outdoor lighting at the converter station
and substation site will be used for
security and emergency use only.
Lighting will not impact on designated
wildlife areas. Lighting will be designed
and installed in accordance with the
Institute or Lighting Engineers Guidance
Reduction on Obtrusive Light.
The onshore underground cable route
includes areas of Public Open Space
including Pegwell Bay Country Park.
There will be a temporary diversion of the
Thanet Coastal Path and the Viking
Coastal Trail during installation of the
cables and land will be reinstated to its
former use.
Thanet District Local Plan Adopted 2006 – Saved Policies
Policy
Policy Summary
Assessment of Policy
SR20:
Undeveloped
Beaches
On or adjacent to
beaches identified as
undeveloped, priority will
be given to the
maintenance and
enhancement of their
natural and
undeveloped character.
The intertidal underground cables will
cross an undeveloped beach. During
construction there will be a visual impact
on the undeveloped beach however,
following reinstatement and during
operation there will be no visible impact of
the cable affecting the character of the
area.
An assessment of Landscape and Views
is presented in Chapter 10 of the ES.
62
Thanet District Local Plan Adopted 2006 – Saved Policies
Policy
Policy Summary
Assessment of Policy
D1: Design
Principles
All new development is
required to provide high
quality and inclusive
design, sustainability,
layout and materials.
New development will
only be permitted if it:
 Respects or enhances
the character or
appearance of the
surrounding area,
particularly in scale,
massing, rhythm and
use of materials
appropriate to the
locality;
 Is compatible with
neighbouring buildings
and spaces and does
not lead to
unacceptable loss of
amenity though
overlooking noise or
vibration, light
pollution,
overshadowing, loss
of natural light, or
sense of enclosure;
 Incorporates provision
for disables access;
 Incorporates new
landscape as an
integral part;
 Incorporates measure
to prevent crime and
disorder, promotes the
perception of public
safety and security;
 Provides safe and
satisfactory means of
pedestrian and, where
provided, vehicle
access; and
 Incorporates
sustainable drainage
systems.
63
As part of the design process,
assessments of the impact of the
Proposed Development on landscape and
views and on archaeology and cultural
heritage have been undertaken to ensure
the effects of the Proposed Development
are as low as possible and avoid severe
adverse effects.
Part of the proposed converter station will
re-use the existing frame of the old turbine
hall. The scale of the converter station
buildings will be broken up by treatment to
the cladding so that there is a gradual
fading of colour from the bottom to the
top. A recessive green colour is
proposed, lightening gradually to off-white
on the upper elevations which will be seen
against the sky. This will reduce the
apparent bulk of each converter station
building in general views. The substation,
lower in height than the converter station
will be finished in a recessive green
cladding to match the lower sections of
the converter station.
The converter station and substation
buildings will be similar to those already in
the local area and those of the proposed
Energy Park. The site will be subject to a
landscaping scheme proposed for the
Richborough Energy Park with provision
for its implementation separate from the
proposed Energy Park if necessary.
Additional native landscaping is proposed
at the south western elevation as part of
this planning application.
Sustainable Drainage System (SUDS)
has been designed for the converter
station and substation site.
A security fence will be installed
surrounding the converter station and
substation site to prevent unauthorised
access to the converter station and
substation. Appropriate access and
parking provision (including provision for
disabled access and parking) is included
with the proposals.
Thanet District Local Plan Adopted 2006 – Saved Policies
Policy
Policy Summary
Assessment of Policy
D2: Landscaping
The following elements
will be required as part
of landscaping
proposals for any new
development:
 The enhancement of
the development site
in the setting;
 The retention and
protection of as many
of the existing trees
and hedges and other
habitat features as
possible on sites of
one hectare of more
the setting aside of
10% of the
development site for
the planting of native
tree species either
within or at the
boundary of the
development site; and
 The maximising of
nature conservation
opportunities where
development is
proposed in proximity
to existing open space
or wildlife habitats and
where both
appropriate and
possible the provision
of landscaping in
advance of new
development to
facilitate the
assimilation of new
development into the
landscape.
64
The effects of the Proposed Development
on landscape and views and ecology
have been assessed and are presented at
Chapters 10 and 8 of the ES respectively.
The converter station and substation will
benefit from a landscape scheme
presented as part of the Richborough
Energy Park proposal and will be
implemented in the event that the Energy
Park is not built. The Proposed
Development includes landscape works
with cables reinstatement to increase the
area of calcareous grassland which is a
priority habitat for the Kent region.
Additional native landscaping is proposed
at the south western elevation as part of
this planning application.
Thanet District Local Plan Adopted 2006 – Saved Policies
Policy
Policy Summary
Assessment of Policy
CC1:
Development in
the Countryside
CC2: Landscape
Character Areas
The Thanet
countryside is
defined as those
areas of the district
outside the identified
urban and village
confines.
Within the
countryside new
development will not
be permitted unless
there is a need for
the development that
overrides the need to
protect the
countryside.
Within the following
landscape character
areas the following
principles will apply
unless development is
essential for the
economic or social wellbeing of the area:
 Pegwell Bay (east of
power station) –
priority is given to
conservation and
enhancement of the
natural beauty of the
landscape;
 Former Wantsum
Channel Area
(covering power
station) – new
development will not
normally be permitted;
 Wantsum Channel
Northshore Area
(north of Former
Wantsum Channel
Area) – development
will only be permitted
that would not
damage the setting of
the Wantsum
Channel, and long
views of Pegwell Bay,
the Wantsum
Channel, the adjacent
marshes and the sea.
65
Although outside the defined urban area,
the converter station and substation will
be built on derelict brownfield land located
adjacent to the proposed Richborough
Energy Park and will not impact on
unspoilt countryside. There is a national
need for investment in electricity
infrastructure.
The converter station and substation will
be on the site of the former power station
in a locale where there are existing
commercial and industrial buildings along
the A256. The converter station and
substation buildings and associated
outdoor equipment will be adjacent to the
proposed Richborough Energy Park which
will be of similar character.
An assessment of the effects of the
Proposed Development on landscape and
views is presented at Chapter 10 of the
ES.
Thanet District Local Plan Adopted 2006 – Saved Policies
Policy
Policy Summary
Assessment of Policy
CC7: Rural Lanes
Development that would
adversely affect the
landscape, amenity,
nature conservation,
historical or
archaeological interest
of the rural lanes
identified will not be
permitted:
 Way Hill, Minster;
 Wayborough Hill,
Minster;
 Grinsell Hill, Minster;
 Marsh Farm Road,
Minster;
 Chambers Wall, St.
Nicholas; and
 Shuart Lane, St.
Nicholas.
66
The converter station and substation site
at the former Richborough Power Station
is to the south of the allocated Rural
Lanes.
An assessment of the effects of the
Proposed Development on landscape and
views is presented at Chapter 10 of the
ES.
Table 4.2: Relevant Policies from Thanet District Council Core Strategy
Preferred Options Consultation Document
Thanet Core Strategy – Preferred Options Consultation Document
Policy
Policy Summary
Assessment of Policy
DCS19
DCS20:
DCS22:
The Council will seek to strengthen
Thanet’s economic employment
base and promote access for
residents to a good range of
community facilities while safe
guarding:
 The distinctiveness and attractive
character, townscape and setting
of Thanet towns and villages;
 The health, economic well-being
and safety of the community;
 The character and quality of the
coast, the beaches, local
landscape, the wider countryside
and biodiversity;
 The quality of natural resources
including water supply and
drainage, air and soil;
 Against the effects of climate
change and flood risk;
 Historic and cultural features of
acknowledged importance; and
 Provision of essential services to
the public.
Development outside urban and
village confines and not otherwise
allocated for development will not be
permitted.
New development will be of a high
quality inclusive design and employ
sustainable construction methods
and layout. It should:
• Relate to the surrounding
development form and layout and
strengthen links to the adjacent
areas
• Be well-designed, respect and
where possible enhance the
character, context and identity of its
location: particularly in scale,
massing, rhythm, and use of
materials appropriate to the locality;
• Be compatible with neighbouring
buildings and spaces and not lead to
unacceptable loss of amenity
through overlooking, noise or
vibration, light pollution,
overshadowing, loss of natural light,
or sense of enclosure;
67
The converter station and substation
site at the former Richborough Power
Station is to the north west of
Richborough and the south west of
Ramsgate and will not affect the
character of either of these towns. The
Proposed Development will strengthen
the employment base and promote an
energy hub around the Energy Park.
A drainage strategy for the site has
been developed which includes
measures to ensure that the Proposed
Development will not increase flood
risk and can operate safely in the
event of a flood. Surface water run-off
will be no greater than currently
experienced by the vacant site.
Assessments of the effects of the
Proposed Development on a number
of environmental topic areas are
presented in Chapters 5-15 of the ES.
Although outside the urban and village
confines, the converter station and
substation site at the former
Richborough Power Station is an
allocated brownfield site adjacent to
the proposed Richborough Energy
Park.
The proposed converter station and
substation will be similar in scale and
nature to surrounding development
including the Thanet Offshore Wind
Farm Substation.
The scale of the converter station
buildings will be broken up by
treatment to the cladding so that there
is a gradual fading of colour from the
bottom to the top. A recessive green
colour is proposed, lightening gradually
to off-white on the upper elevations
which will be seen against the sky.
This will reduce the apparent bulk of
each converter station building in
general views. The substation, lower
in height than the converter station will
be finished in a recessive green
cladding to match the lower sections of
the converter station.
Thanet Core Strategy – Preferred Options Consultation Document
Policy
Policy Summary
Assessment of Policy
DCS23:
• Incorporate where practical a high
degree of permeability for
pedestrians and cyclists and also
consider access for public transport
and provide safe and satisfactory
means of pedestrian and vehicle
access including provision for
disabled access;
• Retain and enhance features that
contribute to biodiversity and the
quality of the local environment
including open spaces, gaps in
development, mature trees, and
other vegetation
• Incorporate new landscaping as an
integral element, including, where
appropriate, wildlife habitats, wildlife
corridors and initiatives for their long
term management;
• Incorporate measures to prevent
crime and disorder, promote public
safety and security and the
perception of public safety and
security;
• Incorporate, where practical and
appropriate, high quality integrated
public art which is relevant to the
site and locality;
• Provide for discreetly located
service areas for development
including cycle stores, clothes drying
facilities and refuse disposal/dustbin
storage;
• Incorporate sustainable drainage
systems.
• Incorporate challenging
sustainable design and construction
standards contributing towards
achieving zero carbon emissions,
improving water efficiency and
minimizing waste.
Proposals to improve energy
efficiency including decentralised
and renewable or low carbon energy
developments will be supported
unless they result in unacceptable
environmental impact.
68
The site will be subject to a
landscaping scheme proposed for the
Richborough Energy Park with
provision for its implementation
separate from the proposed Energy
Park if necessary.
Additional native landscaping is
proposed at the south western
elevation as part of this planning
application.
The converter station and substation
will require a maximum of 6 personnel
on site per day. The site is adjacent to
the Viking Coastal Trail (Sustrans
Route 15) suitable for access on foot
or by bicycle. Cycle parking is
proposed on site. There will be 6
spaces for bicycles included within the
converter station and substation site.
A security fence will be installed
surrounding the converter station and
substation site to prevent unauthorised
access to the converter station and
substation.
Sustainable Drainage System (SUDS)
has been designed for the converter
station and substation site.
Sustainable design and construction
standards have been considered at a
high level and are detailed in the
accompanying BREEAM assessment.
Details with regards sustainable design
and construction will be considered
further (should planning permission be
granted) when a contractor is
appointed.
The Project will allow electricity
exchange between Belgium and the
UK which will support energy efficiency
and low carbon generation from
renewable sources by helping to
manage fluctuations in generation and
demand.
4.41
The cables route from the BayPoint sports complex to the proposed converter
station and substation site and the southern corner of the site falls within the
planning control of Dover District Council. Development control decisions in
Dover District are based on saved policies from the 2002 Dover District Local Plan
and the 2010 Dover District Core Strategy. Saved planning policies from the
Dover District Local Plan and the Dover District Core Strategy have been
assessed against the Proposed Development in Tables 4.3 and 4.4 respectively.
Table 4.3: Relevant Saved Policies from Dover District Local Plan
Dover District Local Plan Adopted 2002 - Saved Policies
Policy
Policy Summary
Assessment of Policy
AS14:
Area
Specific
Policy
Within the Ramsgate Road area,
shown on Sheet 2 and the
Sandwich Inset of the Proposals
Map, the Council will permit
B1/B2/B8 employment uses on
the proposals map:
 All development provides
for the visual upgrading of
the A256/Ramsgate Road,
including structural
landscaping at the main
site boundaries and a 10m
landscape buffer zone
fronting the
A256/Ramsgate Road;
 Any new buildings or
extensions along the A256
are low rise;
 A survey and evaluation is
carried out to determine
the extent of contamination
and remedial measures
proposed to ensure that
the development of any
site does note post a risk to
human health or adjacent
nature conservation
interests;
 Development does not
increase the risk of
flooding; and
 Provision is made for an
archaeological evaluation
in advance of any planning
decision and for the
consequent appropriate
level of archaeological
mitigation in accordance
with the Historic
Environment policies of this
plan.
69
This policy provides criteria to enable, in
principle, the development of land for B1,
B2 and B8 uses. The criteria do not apply
to other proposed land uses, nor does the
policy preclude other such land uses from
being granted planning permission in
principle.
However, notwithstanding the above, the
Proposed Development is in accordance
with this policy for the following reasons:
The proposed converter station and
substation site is not immediately along
the A256 or within the 10m landscape
buffer zone.
The proposed onshore underground cable
will be installed using HDD which will not
sterilise the 10m landscape buffer zone.
The site will be subject to a landscaping
scheme proposed for the Richborough
Energy Park with provision for its
implementation separate from the
proposed Energy Park if necessary.
Additional native landscaping is proposed
at the south western elevation as part of
this planning application
An assessment of ground conditions and
hydrological, ecological and
archaeological effects of the Proposed
Development is detailed at Chapters 7, 8
and 9 of the ES respectively. No
significant adverse effects are anticipated.
Dover District Local Plan Adopted 2002 - Saved Policies
Policy
Policy Summary
Assessment of Policy
Policy
TR12:
Land safeguarded at
Richborough Power Station for
CTRL (Channel Tunnel Rail
Link) development
Land at the former Richborough Power
Station was safeguarded because it
provides access to sidings which were
needed for storage of ballast during the
construction of the CTRL. The Directions
have not yet been withdrawn although the
CTRL is complete; the Proposed
Development is not anticipated to cause
any substantial harm to Policy TR12.
Table 4.4: Relevant Policies from Dover District Core Strategy
Dover District Core Strategy Adopted 2010
Policy
Policy Summary
Assessment of Policy
Policy CP 7:
Green
Infrastructure
Network
(relevant to
part of the
underground
cable
connection)
During construction, the Viking Trail
Sustrans Route, the Thanet Coastal
Path Long Distance Route (part of
the Green Infrastructure Network)
and some minor informal paths will
need to be temporarily diverted.
Following completion of the works
all routes will be reinstated and
reopened for use.
Policy DM
15:
Countryside
Protection
The integrity of the existing
network of green infrastructure will
be protected and enhanced
through the lifetime of the Core
Strategy. Planning permission for
development that would harm the
network will only be granted if it
can incorporate measures that
avoid the harm arising or
sufficiently mitigate its effects.
Proposals that would introduce
additional pressure on the existing
and proposed Green
Infrastructure Network will only be
permitted if they incorporate
quantitative and qualitative
measures, as appropriate,
sufficient to address that pressure.
Development that would result in
the loss of, or adversely affect the
character or appearance of the
countryside will only be permitted
if it is:
 In accordance with
allocations made in
Development Plan
Documents, or
 Justified by the needs of
agriculture; or
 Justified by a need to sustain
the rural economy or a rural
community;
 It cannot be accommodated
elsewhere; and
 It does not result in the loss
of ecological habitats.
Provided that measures are
70
Although outside the defined urban
area, the converter station and
substation will be built on derelict
brownfield land located adjacent to
the proposed Richborough Energy
Park and will not impact on unspoilt
countryside.
The layout of electrical equipment
is designed for optimum efficiency
and requires a large site. As the
converter station will allow the
exchange of electricity between the
UK and Belgium, the site is
required to be located close to the
coast.
Potential effects on ecology and
landscape character are discussed
at Chapters 8 and 10 of the ES
respectively. No significant
Dover District Core Strategy Adopted 2010
Policy
Policy Summary
Policy DM16:
Landscape
Character
Policy DM
25: Open
Space
incorporated to reduce, as far as
practicable, any harmful effects on
countryside character.
Development that would harm the
character of the landscape, as
identified through the process of
landscape character assessment
will only be permitted if:
 It is in accordance with
allocations made in
Development Plan Documents
and incorporates any
necessary avoidance and
mitigation measures; or
 It can be sited to avoid or
reduce the harm and/or
incorporate design measures
to mitigate the impacts to an
acceptable level.
Proposals for development that
would result in the loss of open
space will not be permitted unless:
i. there is no identified qualitative
or quantitative deficiency in public
open space in terms of outdoor
sports sites, children's play space
or informal open space; or
ii. where there is such a deficiency
the site is incapable of
contributing to making it good; or
iii. where there is such a
deficiency the site is capable of
contributing to making it good, a
replacement area with at least the
same qualities and equivalent
community benefit, including ease
of access, can be made available;
or
iv. in the case of a school site the
development is for educational
purposes; or
v. in the case of small-scale
development it is ancillary to the
enjoyment of the open space; and
vi. in all cases except point 2, the
site has no overriding visual
amenity interest, environmental
role, cultural importance or nature
conservation value.
Assessment of Policy
adverse effects are anticipated.
The substation and converter
station development will be
consistent with the character of
nearby development and with the
proposed Richborough Energy Park
and its landscape scheme. An
assessment of the Proposed
Development on landscape and
views is presented at Chapter 10 of
the ES.
The onshore underground cable
route in Dover District crosses the
BayPoint sports complex which is
allocated in the 2002 Local Plan as
Open Space.
Effects would be temporary and the
installation of the onshore
underground cables will not result
in the long term loss of open space.
An assessment of the impacts of
the Proposed Development on land
use is detailed at Chapter 5 of the
ES.
Kent Minerals and Waste Plan 1998 Saved Policies
4.42
Kent County Council produces Minerals and Waste Plans which set out policies for
managing minerals and waste in the County. Policies from the Kent Minerals and
Waste Plan that relate to the Proposed Development are set out in Table 4.5 below.
71
Table 4.5: Kent Waste Local Plan 1998 Saved Policies
Kent Waste Local Plan 1998 – Saved Policies
Policy
Policy Summary
Assessment of Policy
W7 –
Reuse
W9 –
Waste
separation
and transfer
W11 –
Waste to
Energy
4.43
The following locations are
considered to be suitable in
principle for proposals to
prepare Category A waste
for re-use:
For permanent
development - Richborough
The following locations are
considered to be suitable in
principle for proposals for
waste separation and
transfer:
xviii Richborough (N)
The following locations are
considered to be suitable in
principle for proposals for a
waste to energy plant:
iv The Stour at
Richborough.
The former Richborough Power Station site
was identified as a site which could be used
for the reuse of demolition waste, was one of
a number of sites considered suitable in
principle, but was not reserved exclusively for
this type of development.
Land is rarely allocated in development plans
for electricity infrastructure. The Proposed
Development is similar in type and scale to
waste uses and is comfortably located on the
site and in the context of its surroundings.
The Proposed Development is not in full
accordance with these policies, comprising a
particularly bespoke sui generis form of
development. However, it is not considered
to cause substantial harm to Policies W7, W9
and W11.
Kent County Council is in the process of preparing a Core Strategy, which will
establish policies for the future development of Minerals and Waste sites in the Kent
County. The Strategy and Policy Directions Consultation, although not yet adopted,
is a material consideration in determining planning applications although will carry
less weighting than adopted development plan documents and saved policies.
Planning policies from the Strategy and Policy Directions consultation have been
assessed in Table 4.6 below.
72
Table 4.6: Kent County Council Minerals and Waste Core Strategy: Strategy
and Policy Directions 2011
Kent County Council Minerals and Waste Core Strategy – Strategy and
Policy Directions Consultation, May 2011
Option
Policy Summary
Assessment of Policy
11B – Possible
Options for
Strategic Waste
Sites
The former Richborough
Power Station has been
identified as a site that
could accommodate a
large scale Mechanical
Biological Treatment
(MBT) plant which could
receive household and
non-household waste for
treatment by rail or
water.
The former Richborough Power Station site
was one of a number of sites considered
suitable in principle, but was not reserved
exclusively for this type of development.
A Waste biomass fuel
can also be delivered to
a power/Combined Heat
and Power (CHP)
station from the site by
rail or water.
The Proposed Development is not in full
accordance with these policies, comprising
a particularly bespoke sui generis form of
development. However, it is not considered
to cause substantial harm to Policy 11B.
Land is rarely allocated in development
plans for electricity infrastructure. The
Proposed Development is similar in type
and scale to waste uses and is comfortably
located on the site and in the context of its
surroundings.
Conclusions
4.44
The Proposed Development will allow the transfer of electrical power between the
high voltage grid systems of Belgium and the United Kingdom. The power would be
able to flow in either direction at different times, depending on the supply and
demand in each country. The Project contributes to a low carbon future by allowing
better use of renewable energy when resources are available and the ability to
trade electricity over the link will contribute to a downward pressure on wholesale
electrcity prices. The Project is consistent with EU and UK policy.
4.45
The site of the proposed converter station and substation is at the former
Richborough Power Station adjacent to Thanet Offshore Wind Farm substation and
the proposed Richborough Energy Park. The proposed converter station and
substation site is located on derelict brownfield land part of which is currently
occupied by the frame of the former turbine hall of the defunct Richborough Power
Station. Development plans seldom make allocations for electricity infrastructure
such as converter stations or substations and these infrastructure assets are
classified as sui-generis development.
4.46
In considering where developments of this nature could be located, developers
typically seek locations where the existing character shows similarity with those of
the development, such as where there are existing industrial uses which are
unlikely to be adversely affected by such development. The location of the
proposed converter station and substation in part of the former Richborough Power
Station site is consistent with this approach and consistent with proposals for the
development of the Richborough Energy Park.
4.47
The site is off the A256 which offers excellent access to the trunk road network and
the M2 motorway for construction traffic and deliveries. The operational site can be
73
accessed from sustainable transport routes such as the Viking Coastal Trail
(Sustrans Route 15). The levels of traffic generated during the construction phase
of the development are unlikely to have any significant adverse effects on the local
highway network especially with the increased carrying capacity following the
completion of the East Kent Access Phase 2.
4.48
The subsea and onshore underground cables can be installed without causing long
term disturbance or harm to land and would result in benefits to habitats from the
creation of new chalk grassland. No significant adverse environmental effects are
anticipated regarding contaminated land, the generation of noise or from electric
and magnetic fields. The ES provides an assessment of likely environmental
effects together with proposed mitigation measures to avoid or reduce potential
effects.
4.49
The proposed substation and converter station on the former Richborough Power
Station site are within 1km of a number of internationally and nationally designated
nature conservation areas.
An ecological assessment of the Proposed
Development has been completed and the findings are presented in Chapter 8 of
the ES and ES Appendix 8.9. No significant adverse effects are predicted.
4.50
Although the development is not in full accordance with the development plan,
comprising a particularly bespoke sui generis form of development, it does not
conflict with the policies and aims of the development plan.
74
75
76
5.0
LAND USE
Introduction
5.1
This chapter describes the existing land use at the proposed converter station and
substation site and along the onshore underground cables route and adjacent
areas. It considers the potential permanent and temporary effects that the
Proposed Development (i.e. the UK onshore infrastructure of the Nemo Link - see
Chapter 2, Project Description) may have on existing and future land use and
identifies mitigation measures that will be incorporated into the construction and
operation of the development to avoid, reduce or offset potential adverse effects or
enhance potential beneficial effects on land use.
5.2
Potential effects on land use are interrelated with Archaeology and Cultural
Heritage (Chapter 9), Landscape and Views (Chapter 10), Traffic and Transport
(Chapter 11), Noise and Vibration (Chapter 12) and Air Quality (Chapter 13).
5.3
Consideration of land use planning policies relevant to this planning application is
presented in Chapter 4 (Planning Context).
Method
5.4
The geographic scope of the assessment is based on the boundary of the converter
station and substation site and the route of the onshore underground cables to
which this planning application relates.
5.5
Baseline conditions were established by a desk-based assessment (DBA) of
published information and a site walkover survey. The DBA included the following:



Review of Ordnance Survey Mapping and aerial photography to establish
existing land use within the boundary of the proposed converter station and
substation site and the onshore underground cables route;
Review of land use planning policy to identify future development and planning
allocations in or close to the development area; and
Review of planning policy to identify walking and cycling routes and other
Rights of Way within the development area.
5.6
The findings of the DBA were supplemented by a walkover survey undertaken in
September 2011 which focused on the converter station and substation site, the
route of the onshore underground cables and land immediately adjacent. The
walkover survey was used to verify and supplement the findings of the DBA.
Further observations have been made from subsequent site visits to the converter
station and substation site and the cable route. Discussions have also been held
with owners of land which would be affected by the Proposed Development.
5.7
Potential effects on land use resulting from the installation and operation of the
onshore underground cables and construction and operation of the proposed
converter station and substation broadly fall into two categories:

Land-take: Temporary or permanent requirement for land currently used for
other purposes; and
77

Disturbance: Disturbance to existing or future land uses or activities including
reduced access.
5.8
There is no existing guidance directly applicable to the assessment of the effects of
electrical infrastructure on land use. A qualitative approach to the assessment has
been taken based on professional judgement and discussion with landowners. The
assessment evaluates relative importance of other effects on land use related to the
value of existing uses and whether or not these can continue.
5.9
Effects were assessed by predicting changes in baseline conditions that would be
caused by the construction and operation of the converter station and substation
and the installation and operation of the onshore underground cables.
5.10
Effects have been assessed as significant or not significant, adverse or beneficial in
relation to whether they are temporary or permanent. Minor effects are those of
very small magnitude and those considered to be temporary, short-term, reversible
effects which would not affect an on-going land use. Minor effects are manageable
and are not significant. An effect which disrupts a land use permanently or for a
long period of time may be judged to be a major or moderate effect, depending on
the scale of effect and the extent of disruption. Moderate and major effects would
be significant.
Existing Environment
Proposed Converter Station and Substation Site and its Surrounds
5.11
The converter station and substation are proposed to be constructed on the site of
the former Richborough power station which is approximately 4 kilometres (km)
southwest of Ramsgate, 3.5km north of the town of Sandwich and 1.6km inland
from the east Kent coastline. The power Station was constructed in the late 1950s
and early 1960s and it began production in 1962 as a 342 megawatt (MW) coal
fired station, using coal from the Kent coalfields. It subsequently burnt Orimulsion
as a fuel before its closure. In 1989 a 1MW wind turbine was constructed on the site
to aid the research and development of wind energy technology. Thanet Offshore
Wind Farm is connected to a substation which is also present on site.
5.12
The power station closed in 1996 and the decommissioning, which included a
programme of asbestos removal and partial demolition process, was completed in
2000, leaving the largest structures including the cooling towers and stack. In 2012,
Thanet District Council (TDC) and Dover District Council (DDC) approved a
planning application for the demolition of the remaining above ground buildings with
the exception of the frame of the former turbine hall. Demolition took place in
March 2012. The site is now derelict brownfield land and is part of wider future
proposals for the development of Richborough Energy Park. The steel frame of the
turbine hall has been left in situ and it is proposed that this would be used as part of
the converter station building.
5.13
The River Stour runs along the south west boundary of the power station site. To
the west of the river, the land is predominantly agricultural and is currently used as
grazing pasture. Immediately north of the power station site is a compartment of
Sandwich Bay to Hacklinge Marshes SSSI and beyond this, a recently constructed
78
solar farm, Weatherlees Hill Wastewater Treatment Works, an anaerobic digester
currently under construction and further agricultural land.
5.14
The A256 (Ramsgate Road), southeast of the former power station, separates the
proposed converter station and substation site from the Kent coast and Pegwell
Bay. Pegwell Bay is part of the larger Sandwich Bay which is of international nature
conservation interest. The section of A256 which runs past the entrance to the
former power station site has recently been widened to create a dual carriageway
as part of the East Kent Phase 2 Access Scheme.
5.15
The road improvement scheme has involved constructing a new bypass which
connects to the widened A256 at a new roundabout approximately 200m northeast
of the Power Station site. The bypass bisects arable farmland as it passes north to
connect to the A299 and it separates the Power Station site from Stonelees Golf
Course and St. Augustine’s Golf Course to the north of the site. Stonelees Golf
Course has a driving range and three courses and is open to the general public
whilst St. Augustine’s Golf Course is an 18 hole members only course. The A256
Sandwich Road forms the eastern boundary to Stonelees and St Augustine’s Golf
Courses and separates these areas from the coast.
5.16
In addition to the golf courses, BayPoint sports complex and Pegwell Bay Country
Park also provide recreational areas. These are on the coastal side of the A256
and the onshore underground cables route will pass through these sites. The sports
complex, approximately 190m northeast of the power station site provides corporate
and private events facilities and a range of sports facilities including football pitches,
tennis courts, gymnasium, squash courts and exercise studios. Pegwell Bay
Country Park is recorded on the Environment Agency website as an historic landfill.
The site was licensed for inert material although there have been anecdotal
comments that there may potentially be contaminated waste, possibly from the
former Richborough power station, or putrescible wastes.
5.17
Pegwell Bay is used by visitors including dog walkers, wildlife enthusiasts and bait
diggers. Facilities within the Country Park include a large car park, a picnic area
and a toilet block. The main path through the Country Park is close to the verge of
the A256 Sandwich Road and this is also part of a long distance cycle track called
‘the Viking Trail’. The Thanet Coastal Path long distance footpath also runs through
the Country Park.
5.18
Further tracks on the salt marsh between the Country Park and Pegwell Bay
Service Station have been created by walkers, bait diggers and other recreational
users of the mudflats.
5.19
Stonelees Nature Reserve, currently grazed by cattle, separates the sports complex
from Pegwell Bay Country Park. The Reserve is owned and managed by Kent
Wildlife Trust and is used for walking and enjoying scenery and nature.
5.20
The nearest residential dwellings to the former power station site are four detached
properties on Ebbsfleet Lane approximately 350m to the north. Cliffs End village is
the closest settlement to the proposed converter station and substation site,
approximately 2.5km north east.
79
Onshore Underground Cable Route
5.21
The HVDC onshore underground cables will run from the landfall on the coastal
side of the existing cycle track which runs parallel to the A256 Sandwich Road,
through Pegwell Bay Country Park, then into Stonelees Nature Reserve and
BayPoint sports complex. From the sports complex, the cables will be routed by
horizontal directional drilling (HDD) beneath the A256, Minster Stream, and a
compartment of Sandwich Bay to Hacklinge Marshes SSSI (which is designated for
the botanical interest of its ditches). The cables will have no direct or indirect
effects on any of these features and will surface and terminate within the former
power station site adjacent to the converter station (Figure 2.1). The overall length
of the cable route is approximately 2.3km.
5.22
The landfall site, close to Pegwell Bay Service Station, is within Sandwich Bay
Special Area of Conservation (SAC), Sandwich Bay Special Protection Area (SPA)
and Ramsar site, Sandwich Bay to Hacklinge Marshes Site of Special Scientific
Interest (SSSI) and Sandwich and Pegwell Bay National Nature Reserve (NNR).
The majority of the cable route is in the administrative district of Thanet District
Council. A small part of the cables route and the entrance to the former power
station site is in Dover District Council’s administrative boundary.
Land Use Allocations
5.23
Kent Waste Local Plan 1998 has a number of saved policies that allocate the
former Richborough power station site as being suitable in principle for waste
proposals. Policy W7 identifies it as a site which can be used for the reuse of
demolition waste; Policy W9 names the site as suitable in principle for waste
separation and transfer and Policy W11 states that the site is suitable for a waste to
energy plant.
5.24
Parts of the former Richborough power station site are to be developed as energyrelated infrastructure as part of the wider Richborough Energy Park development.
Two planning applications were submitted by Richborough A Ltd in December
2012: the first is for a gas-fired ‘peaking’ plant immediately south of the proposed
converter station and substation site; the second is for a road system around the
perimeter of the proposed Energy Park off the A256 roundabout - this will serve as
the access from the local highway network to the proposed converter station and
substation forming this planning application. Both the external road and the
peaking plant are expected to be operational by 2014 prior to the commencement of
site enabling works for the proposed converter station and substation site.
Additional energy-related proposals may come forward for other parts of the
Richborough Energy Park; however, at present, such proposals are unknown and
as such sufficient details cannot be provided.
80
Prediction and Assessment of Potential Impacts
Construction
5.25
Construction of the proposed converter station and substation and installation of the
onshore underground cables would result in temporary effects as described below.
5.26
Land will be used during construction for compounds, the laydown area, temporary
access roads, and for the installation of onshore underground cables and
associated joint pits. A working width will be required for cables installation of
between 5m and 10m.
HDD between BayPoint sports complex and the
Richborough power station site will require a temporary launch pit working area
where the main driving of the drilling equipment will be undertaken and a temporary
receptor pit working area which will receive the drill driven from the launch pit.
5.27
The launch pit will be on the former Richborough power station site and will
comprise of a working area approximately of 30m x 50m. The receptor pit on land at
BayPoint sports complex will be approximately 30m x 50m. Access to the launch
pit and the receptor pit working areas will be from the existing entrances along the
A256.
5.28
HDD from the sports complex will avoid surface disturbance of a newly constructed
roundabout on the A256, Minster Stream and a compartment of Hacklinge Marshes
to Sandwich Bay SSSI.
5.29
Effects on land use during construction will be highly localised and temporary so will
be of minor significance. Where open space and land which is available for
recreation and walking is disturbed, there will be alternative routes available and the
absence of any facility will be short term and reversed after reinstatement of land.
5.30
An increase in traffic from workers and materials arriving on site will result in some
disruption to road users, which is addressed in Chapter 11 Traffic and Transport.
5.31
Grazing within Stonelees Nature Reserve may also be temporarily restricted.
5.32
During construction of the TJP and installation of marine cables to low water, part of
the foreshore will have to be closed to ensure public safety making a small area
used for bait digging and walking temporarily unavailable.
5.33
Effects on disturbance during construction will be within highly localised areas and
temporary, so will be of minor significance.
Operation
5.34
The converter station and substation will result in the permanent loss of
approximately 8 hectares of derelict brownfield land. The converter station will
occupy the footprint of the existing turbine hall and adjacent land. However, there is
no defined on-going land use; the site and the surrounding land is part of the
Richborough Energy Park proposals. The Proposed Development would make a
positive contribution as it would result in the re-use of derelict land contributing to
national and local policy sustainability objectives. There would be no adverse
effects from the loss of the derelict land to the Proposed Development.
81
5.35
On completion of the cables installation, the present land uses above the cables will
resume as previously. A permanent 5m cable easement will be required and this
also will not affect current land use; however, there may be temporary effects on
land use associated any required onshore cable repairs or maintenance. The
onshore underground cables have been routed so that they will not prevent any
future development proposals within Pegwell Bay Country Park related to recreation
and education. However, there will be restrictions on planting above the cables
route.
5.36
No significant adverse effects on land use on and around the cable route are
anticipated.
Mitigation
5.37
The absence of potentially significant effects indicates that no specific mitigation is
required. The following measures will be put in place as part of the overall working
methods to ensure that effects on land use are acceptable:











The working width associated with cables installation will be kept to a minimum
to reduce disturbance to adjacent land;
Temporary working areas and access roads will be fully reinstated following
construction;
The laydown area will be reinstated to its current standard and it will be made
available for future use by the developers of Richborough Energy Park;
Access to the Viking Trail and Thanet Coastal Path will be retained where
possible during the construction period. Where there is a Health and Safety
requirement to prevent or reduce access, appropriately signed diversions will
be agreed and put in place;
Any public access restrictions will be minimised as much as possible and
limited only to periods of major construction activity such as earthworks;
Temporary signage advising visitors of construction activities will be erected.
This will include signs within the car park of Pegwell Bay Country Park to
ensure that visitors are aware of construction activities being undertaken;
Contractors will prepare a Construction Environmental Management Plan
(CEMP) prior to the commencement of construction. This will include measures
to ensure good construction practices are adopted on site;
Measures to ensure construction activities do not result in any disturbance to
land users surrounding the former power station site will be developed in
consultation with the site owners and operators. This will include on-going
communication and liaison, measures to address site access and movement
and working hours;
A Transport Management Plan (TMP) will be prepared and implemented prior
to the commencement of construction activities;
In order to minimise construction disturbance, working hours during periods
where recreational activity is greatest (i.e. evenings and weekends) will be
limited as much as possible; and
Measures to control dust and noise will be adopted during the construction
period in order to reduce the potential for disturbance and indirect effects on
land use.
82
Residual Impacts
5.38
The assessment of effects considered the above measures to be in place and there
is no change to the assessment.
Cumulative Impacts
5.39
Potential cumulative effects on land use from the onshore elements of the Nemo
Link in combination with other components of the Project (i.e. UK, French and
Belgian subsea cables and Belgian onshore infrastructure) are described in Chapter
16.
5.40
Potential cumulative effects of the Nemo Link UK onshore infrastructure in
combination with the grid connection required to facilitate the operation of the Nemo
Link are described in Chapter 17.
5.41
There is little scope for cumulative operational effects on land use arising from the
UK onshore elements of the Nemo Link in combination with unrelated planned
developments described in Table 1.2, Chapter 1. The proposed use and change of
use of land for other development detailed in Table 1.2 is not considered to result in
any significant cumulative effects in terms of overall land use.
5.42
There is the potential for temporary cumulative effects on land use should the
construction of the Proposed Development overlap with the proposed external
access road and the peaking plant. Such effects would be restricted to the land at
the former Richborough power station site through the establishment and use of
working compounds and would be highly unlikely to result in disturbance to publicly
accessible land.
5.43
An increase in traffic from workers and materials arriving on site will result in some
disruption to road users, which is addressed in Chapter 11 Traffic and Transport.
5.44
Any potential effects on land use and disturbance during construction will be highly
localised and temporary so will be of minor significance.
83
84
6.0
GROUND CONDITIONS AND CONTAMINATION
Introduction
6.1
This chapter reviews the potential impacts of the Proposed Development i.e. the UK
onshore elements of the Nemo Link (see Chapter 2 – Project Description) with
reference to soils, geology and hydrogeology. The assessment is made primarily on
the effect of disturbance on the ground by construction activities and potential
contamination that may arise as a result of cables installation and construction of the
converter station and substation. Potential sources of ground contamination within
the development site are examined to determine the likelihood of significant levels of
contamination affecting the development.
6.2
The chapter provides a review of historical studies and includes information
collected from the following elements:



6.3
Visual findings from a walkover survey;
Desk study, including site history, geology, hydrogeology and hydrology; and
Search of environmental information using Landmark Envirocheck.
Best practice techniques to minimise the environmental impacts of construction on
contamination risk to humans and the environment are well developed and are
outlined within the chapter. In addition, site specific mitigation measures are
described where generic, best practice mitigation measures are not suitable.
Suitable mitigation techniques to minimise contamination during operation are also
proposed.
Legislation and Planning Policy Context
6.4
Relevant legislation, planning policy and guidance is summarised in Tables 6.1 to
6.3. Relevant Pollution Prevention Guidelines issued by the Environment Agency
are outlined in Table 6.4.
Table 6.1: National Legislation and Policy Context
Policy/Legislation
National Planning Policy
Framework
The Water Framework
Directive 2000/60/EC
Environmental Protection
Act:1990 Part IIA
Key Provisions
Specifies planning policies to help achieve sustainable
development, the protection and enhancement of
geological conservation interests and soils.
The 1980 Groundwater Directive 80/68/EEC and the
2006 Groundwater Daughter Directive 2006/118/EC of
the WFD are the main European legislation in place to
protect groundwater.
Requires all Local Authorities to inspect their areas for
contaminated land, and produce a strategy outlining
how they approach this task. Under s.78B(1) the
Council is required to maintain a Public Register of
Contaminated Land.
85
Table 6.2: Regional Legislation and Policy Context
Policy/Legislation
The South East Plan (May
2009) Regional Spatial
Strategy for the South East of
England
Key Provisions
To improve and conserve the region’s
environment by ensuring the protection and
enhancement of the region’s environmental
assets, including the built and historic
environment, landscape and water.
Table 6.3: Local Strategies and Guidance
Policy/Legislation
Thanet District Council
Contaminated Land
Strategy
Dover District Council
Contaminated Land
Developers Guide
Key Provisions
It is the developer’s responsibility to ensure that the
development is safe and that the Local Planning
Authority is satisfied that any risks from potential
contamination have been adequately addressed. To
this end, the developer should carry out a
satisfactory assessment of the Site, considering the
potential for contamination, including a ground
investigation, where necessary, to confirm the level
and extent of any contamination.
Where development of contaminated land, or land
suspected of being contaminated, is proposed, the
Council will require the submission of details of site
investigations and proposed remedial action.
Planning permission will be refused unless an
appropriate and acceptable level of remedial action
can be achieved.
Table 6.4: Pollution Prevention Guidelines
Guidance
Control of Water Pollution
from Construction Sites
(2001)
PPG1: General Guidance
to the Prevention of
Pollution (2001)
PPG6: Working at
Construction and
Demolition Sites (2010)
PPG21: Pollution Incident
Response Planning (2009)
Key Provisions
Provides practical help and guidance for consultants
and contractors on how to plan and manage
construction projects to control water pollution.
Provides an introduction to a series of Pollution
Prevention Guidance notes (PPGs), which provide
practical advice to help developers and contractors
avoid causing pollution, minimise waste and comply
with the law.
Provides detailed guidance on construction and
demolition activities, including requirements for
discharges of water from dewatering operations to
controlled waters and foul sewers, and the safe
discharge of silt-laden water.
Provides guidance on the development of a pollution
incident response plan and includes a template plan.
86
Method
6.5
Full details on ground conditions associated with the development area are provided
in the Phase 1 Environmental Report in Appendix 6.1. The Report contains
information from an Envirocheck Report, a site inspection carried out on 6th April
2012 and information from Thanet District Council and Dover District Council
Environmental Health Departments and the Environment Agency. The Phase 1
Report contains information on the underlying ground conditions available from
previous site investigation reports including:



A contaminated land site assessment report relating to land adjacent to the
cable landfall at the northern end of Pegwell Bay, (Royal Haskoning Ltd, June
2007);
A geoenvironmental site investigation report covering the full extent of the
former Richborough Power Station (URS Corporation Ltd, January 2009); and
A detailed quantitative risk assessment for Richborough Power Station (URS
Corporation Ltd, June 2009).
6.6
The Phase 1 study was undertaken to meet the objectives of a preliminary (Phase
1) investigation, as defined by BS 10175:2011 ’Code of Practice for the Investigation
of Potentially Contaminated Sites’. The Phase 1 report adopts the technical approach
presented in Contaminated Land Report 11 ’Model Procedures for the Management
of Land Contamination’ (Environment Agency 2004) for applying a risk management
process when dealing with land affected by contamination.
6.7
The desk study has included the development of a Conceptual Site Model (CSM)
providing a depiction of likely sources of contamination, pathways and receptors,
resulting in the identification of potential pollutant linkages.
6.8
The potential effects in relation to land quality and geology were assessed using
guidelines given in CIRIA document 552 ‘Contaminated Land Risk Assessment, A
Guide to Good Practice’. CIRIA is the construction industry research and information
association.
6.9
This chapter summarises information in the Phase 1 Environmental Report included
in Appendix 6.1. No intrusive investigations of land within the application site have
been undertaken as part of the assessment. These will be undertaken prior to
construction.
Assessment of Significance
6.10
Effects were assessed by predicting changes in baseline conditions that would be
caused by the construction and operation of the converter station and substation site
and the installation of the onshore underground cables and subsea cables between
low water and the Transition Joint Pit (TJP). A qualitative approach to the
assessment has been taken which is based on professional judgement and
experience from similar developments on sites with comparable environmental
sensitivity.
6.11
The sensitivity of receptors has been determined using criteria in Table 6.5.
87
Table 6.5: Method for Determining Sensitivity/Importance of the Environment
Receptor
Sensitivity
Description
High
Designated sites, such as geological and groundwater SSSIs.
Regionally important geological and geomorphological sites
(RIGS) and geological conservation review sites (GCRs)
Areas of critical topography, including steep slopes and historic
landslip locations
Areas of existing mineral extraction and areas designated in
Local Authority Plans as preferred areas for mineral extraction
Inner groundwater source protection zones (SPZ 1)
Areas of high groundwater vulnerability
Principal aquifers
Areas of known/confirmed contaminated land/groundwater
Rivers with a Grade A water classification
Areas of flood risk
Neighbouring properties and residents
Medium
Low
6.12
Typical rural topography
Areas of search for minerals
Outer groundwater source protection zones and total
catchment areas (SPZ 2 and SPZ 3)
Secondary aquifers
Areas with intermediate groundwater vulnerability
Intertidal marine environment
Rivers with a Grade B water classification.
Industrial site topography
Areas without known mineral resources
Rivers with a Grade C or D water classification
Unproductive strata
Areas with low groundwater vulnerability.
The generic criteria for determining levels of magnitude of change on the physical
environment are indicated in Table 6.6. A major magnitude of change would be one
that is likely to cause a direct adverse permanent or long-term effect on the integrity
or value of the receptor, whereas a small change would be one that is likely to have
a minor adverse effect on a receptor, but from which a recovery is expected in the
short term.
88
Table 6.6: Magnitude of Effect
Magnitude
Definition
Major
Total loss or substantial alteration to key elements or features of
the baseline (pre-development) conditions such that the postdevelopment character, composition or attributes will be
fundamentally changed.
Moderate
Minor
Negligible
6.13
Loss or alteration to one or more key elements/features of the
baseline conditions such that post development character,
composition or attributes of the baseline will be materially
changed.
A minor shift away from baseline conditions. Change arising from
the loss or alteration will be discernible but not material. The
underlying character, composition or attributes of the baseline
condition will be similar to the pre-development circumstances or
situation.
Very little change from baseline conditions. Change barely
distinguishable, approximating to a 'no change' situation.
The categories used when classifying the overall significance of potential effects by
considering sensitivity of receptor and magnitude of effect are shown in Table 6.7.
Table 6.7: Effect Significance Matrix
Magnitude
6.14
High
Medium
Low
Major
Major
Moderate
Minor
Moderate
Moderate
Moderate
Minor
Minor
Minor
Minor
Negligible
Negligible
Minor
Negligible
Negligible/None
The significance of effect can be described as follows:



6.15
Sensitivity of Receptor
Minor: Slight, very short or highly localised;
Moderate: Limited effect in terms of extent, duration or magnitude; or
Major: Considerable effect in terms of extent, duration or magnitude or more
than local significant or in breach of recognised acceptability, legislation or
policy or standards.
The nature of an effect can be classified as adverse, negligible (or no effect), or
beneficial:

Adverse: Classifications of significance indicate disadvantageous or negative
effects to an environmental receptor, which may be of Minor, Moderate, or
Major significance;
89
6.16

Negligible/None: Classifications of significance indicate imperceptible effects to
an environmental receptor;

Beneficial: Classifications of significance indicate advantageous or positive
effects to an environmental receptor, which may be of Minor, Moderate or
Major significance.
Timescales associated with effects are categorised as follows:

Short to Medium Term: Timescales where the effect is temporary and last for
the period of the construction works or less; and

Long Term: Timescales where the effect remains for a substantial time,
perhaps permanently, after construction even though the activity that created it
may be ceased some time ago.
Existing Environment
Site Description
6.17
From low water to the TJP the subsea cables route runs across tidal mudflats. From
close to the TJP, the onshore underground cables route runs parallel to the seaward
side of the Sandwich Road, initially through reclaimed land associated with Pegwell
Bay foreshore and then through an area of historical landfilling comprising Pegwell
Bay Country Park. In the Country Park there are a number of gas monitoring wells
which indicate the presence of underlying landfill materials. The onshore
underground cables route then runs through Stonelees Nature Reserve and into
BayPoint sports complex from where the cables will be installed by horizontal
directional drilling (HDD) beneath the A256, Minster Stream, and a compartment of
Sandwich Bay to Hacklinge Marshes SSSI. The cables will terminate in the
converter station site (Figure 2.2). Habitats along the cable route and at the
proposed converter station and substation site are described in Chapter 7 (Ecology)
which gives a description of present ground surfaces.
6.18
The proposed converter station and substation will be constructed on part of the site
of the former Richborough Power Station which is currently a derelict brownfield site.
6.19
The topography of the development area is predominantly flat and shows very
limited variation. Ground levels are generally 2-3m above ordnance datum (AOD)
across the Pegwell Bay foreshore, 3-6m AOD across the remainder of the cables
route and 2-4m AOD across the site of the former Richborough power station.
6.20
A number of sensitive land uses are present in the vicinity of the application
boundary including:





Thanet Coast and Sandwich Bay Special Protection Area (SPA)/Ramsar Site;
Sandwich Bay Special Area of Conservation(SAC);
Thanet Coast SAC;
Sandwich Bay to Hacklinge Marshes Site of Special Scientific Interest; (SSSI);
and
Sandwich and Pegwell Bay National Nature Reserve (NNR).
90
6.21
Further details on the above sites are contained in Chapter 8, Ecology.
6.22
The nearest residential dwellings to the former power station site are four detached
properties on Ebbsfleet Lane, approximately 340m to the north. Cliffs End village is
the closest settlement to the proposed converter station and substation site,
approximately 2km to the northeast.
6.23
The A256 (Ramsgate Road), southeast of the power station, separates the
proposed converter and substation site from the Kent coast and Pegwell Bay and
Sandwich Bay. The section of A256 which runs past the entrance to the former
power station site, has been widened to create a dual carriageway as part of the
East Kent Phase 2 Access Scheme. The road improvement scheme has also
involved constructing a new bypass which connects to the widened A256 at a new
roundabout approximately 200m northeast of the former Richborough Power Station
site. The bypass bisects arable farmland as it passes north to connect to the A299
and it separates the former power station site from Stonelees Golf Course and
St.Augustine’s Golf Course to the north of the Site.
6.24
A number of industrial features are present within the immediate surroundings of the
converter station and substation application boundary, most notably to the south, in
the vicinity of Richborough Port, on the northern bank of the River Stour. Three
petrol filling stations are present within 100m of the application boundary,
comprising Pegwell Bay Service Station 20m north of the TJP and TCS
Richborough and Richborough Service Station, 55m south and 60m south of the
proposed HDD section of the cable route respectively.
Previous Land Use
6.25
Pegwell Bay Country Park was established on an area of landfill created during the
1960s and early 1970s. A number of large excavations were present through this
area during the early 1960s, initially through southern and central areas of the
present day Country Park and later spreading through the full extent of the Park.
Associated with the staging of these excavations, different phases of landfilling are
understood to have taken place, resulting in southern areas of the park being
capped to a greater degree than the northern half of the park. Chalk has been used
to cap the southern area. Further information on the landfill activity is detailed in the
Phase 1 Report (Appendix 6.1).
6.25
The former Richborough Power Station was originally commissioned in 1962 as a
coal-fired facility and subsequently converted to burn oil in 1971. The power station
was modified for a second time in 1989, this time to burn a proprietary oil and water
emulsion known as Orimulsion. During the power station’s operational phase,
significant infrastructure was present, including numerous unspecified storage tanks,
which have subsequently been removed.
6.26
Richborough Power Station closed in 1996 and the decommissioning, which
included a programme of asbestos removal and partial demolition process, was
completed in 2000, leaving the largest structures including the cooling towers and
stack. In 2012, Thanet District Council (TDC) and Dover District Council (DDC)
approved a planning application for demolition of the majority of above ground
buildings most notably three cooling towers and a chimney. Demolition took place in
March 2012, although some of the debris from the demolition currently remains on
91
site. The steel frame of the turbine hall has been left in situ and it is proposed that
this will be used as part of the converter station building.
6.27
Richborough Port, south of the former Power Station Site, has reduced in size and
activity, having been a major industrial hub during the Second World War when
numerous warehouse and railway sidings were present. More recently, fuel oil was
imported and transferred to the power station via a pipeline, which passed beneath
Ramsgate Road and into the power station site.
Geology
6.28
The published geological map of the area indicates that the northern two-thirds of
the onshore cable route are underlain by Marine Beach Deposits whilst southern
areas are predominantly underlain by Marine and Estuarine Alluvium. Through the
BayPoint sports complex area, Storm Beach Deposits are present overlying the
boundary between the strata detailed above.
The superficial deposits are
anticipated to attain a thickness of between 2.5m and 4.0m at the northern end of
the cable route, but potentially increasing in depth towards the south as the cables
route moves inland.
6.29
Beneath the superficial deposits, geological records indicate the solid geology to
comprise the basal Thanet Sand Formation with the White Chalk Sub-group at
depth. Previous site investigation works at the northern end of the cable route did
not encounter the Thanet Sand Formation, instead encountering White Chalk
directly beneath shallow drift deposits. At the southern end of the cable route, from
Stonelees Nature Reserve, the Thanet Sand Formation is anticipated to extend to a
depth of 30 metres below ground level (mbgl).
6.30
To the east of the former power station, in the vicinity of Sandwich Bay to Hacklinge
Marshes SSSI, superficial deposits are absent and the Thanet Sand Formation
outcrops at the surface.
6.31
Made ground is anticipated to be present along the cable route where historical
development has taken place. In addition, landfill materials are anticipated to be
present throughout the full extent of Pegwell Bay Country Park.
6.32
Beneath the proposed converter station and substation site, previous investigations
(undertaken by URS in 2009) have encountered a ground profile comprising made
ground to a depth of between 1.5mbgl and 6.3mbgl overlying Marine and Estuarine
Alluvium to a depth of between 9.4mbgl and >11.0mbgl. These strata were found to
overly the Thanet Sand Formation, which extended to the full depth of investigation
at 20mbgl.
6.33
Extensive deposits of made ground are present associated with the site’s historical
development and the presence of numerous sub-surface structures and basements.
Hydrogeology
6.34
The Marine Beach Deposits underlying approximately the northern two-thirds of the
cables route, between the TJP and Stonelees Nature Reserve, are designated as a
Secondary (undifferentiated) aquifer whilst the Marine and Estuarine Alluvium
underlying the southern section of the cables route and the proposed converter
station and substation site are designated as Unproductive Strata. Where Storm
92
Beach Deposits are present (beneath BayPoint sports complex) these have been
classified as a Secondary A aquifer. Further information on the aquifer classification
is detailed in the Phase 1 Report (Appendix 6.1).
6.35
The underlying Thanet Sand Formation (which outcrops to the east of the former
Power Station site in the vicinity of Hacklinge Marshes) is classified as a Secondary
A aquifer whilst the underlying White Chalk Sub-group has been classified as a
Principal aquifer.
6.36
The shallow aquifer associated with the superficial deposits extending across the
application area, with the exception in the vicinity of Hacklinge Marshes, has been
classified with a High vulnerability rating (i.e. they readily transmit liquid discharges
and a wide range of pollutants) whilst the outcrop of the Thanet Sand Formation has
been classified with an Intermediate vulnerability rating (i.e. soils which can possibly
transmit liquid discharges and a wide range of pollutants).
6.37
The application site is located within a sensitive area with respect to groundwater.
However, in the immediate vicinity of the cables route and converter station and
substation site, shallow groundwater is unlikely to form an important resource owing
to natural saline intrusion. The published hydrogeological map for the area indicates
that chloride concentrations within the White Chalk aquifer are four times greater
than the limit specified within the UK Drinking Water Standards associated with
natural saline intrusion.
6.38
There are no groundwater abstractions for potable water supply within a 2km radius
of the application boundary. The proposed development area is not located within a
currently designated groundwater Source Protection Zone.
6.39
In the vicinity of the proposed converter station and substation site, previous
investigation works, undertaken by URS in 2009, have encountered perched water
through the made ground at depths ranging between 0.061mbgl and 1.008mbgl with
groundwater encountered between 0.657mbgl and 3.472mbgl. Along the cable
route groundwater is anticipated to be present at depths of between 2-3mbgl with
the notable exception of the Pegwell Bay foreshore.
6.40
Across the proposed converter station and substation site, groundwater flow is
anticipated to be in a southerly or easterly direction dependent upon the proximity of
the River Stour and Pegwell Bay. Groundwater flow is also likely to be influenced by
tidal variation, which is expected to be active at either end of the application site (i.e.
beneath the converter station and substation site and in the vicinity of the TJP).
6.41
Information available on the Environment Agency website indicates that the full
extent of the application site does not lie within a groundwater source protection
zone.
Surface Waters
6.42
Between the landfall and the proposed HDD works, the cable route is on the
seaward side of the Sandwich Road, just above the mean high water level of
Pegwell Bay. A large tidal lagoon is present 10m south of the cable route between
the TJP and Pegwell Bay Country Park.
93
6.43
The tidal River Stour is present 10m west of the proposed substation footprint,
flowing in a southerly direction along the western edge of the former power station
site. To the south of the proposed converter station and substation site, the River
Stour flows in a large loop around Great Stonar (extending for 3.4km south) before
heading north again and passing within 400m of the cable route, close to the river’s
confluence with Pegwell Bay.
6.44
Several small watercourses are present in the vicinity of the development area.
These are described in detail in Chapter 7, Hydrology and Flood Risk. The largest of
these is the Minster Stream, which flows in a linear drainage channel to the west of
the new A256 bypass. HDD will be used to route the cable beneath this
watercourse. An unnamed drainage channel follows the cable route through the
southern areas of Pegwell Bay Country Park and Stonelees Nature Reserve, before
discharging into a small pond at the northwestern corner of BayPoint sports
complex.
6.45
The River Stour is monitored under the Environment Agency’s General Quality
Assessment Scheme. The EA classification of the water quality at the closest
compliance point, 3km downstream of the application site’s most southerly point, is
Grade B (good).
6.46
There are eighteen surface water abstractions within a 1km radius of the application
boundary comprising the cables route from low water and the converter station and
substation site. None of these abstractions are for potable purposes.
6.47
The indicative floodplain map for the area, published by the EA, shows that the
northern two-thirds of the cables route between the TJP and Stonelees Nature
Reserve are within the footprint of an extreme flood event from the sea. In addition,
a thin strip of land susceptible to an extreme flood event is present at the southern
end of the cable route along the banks of Minster Stream. The proposed converter
station and substation within the former Richborough Power Station site are within
an area at low risk of flooding. Detailed information on flood risk is presented in
Chapter 8, Hydrology and Flood Risk.
Sources of Contamination beneath the Former Power Station
6.48
Previous site investigations have indicated that, whilst low level contamination is
present beneath the former power station, including heavy metals, sulphates,
polycyclic aromatic hydrocarbons and polychlorinated biphenyls, this does not
present a risk to end users of the site or nearby controlled waters. As such, the
principal pollutant linkage within this area is considered to relate to potential
accumulations of ground gases within excavations during the construction phase
and within the proposed structures.
6.49
Pollutant linkages are also considered to exist in relation to construction materials,
particularly concrete placed in the ground where elevated concentrations of sulphate
have been encountered.
Potential Sources of Contamination along Cable Route
6.50
Along the proposed cable route, on-site sources of potential contamination have
been identified. These include:
94


The presence of landfill materials beneath Pegwell Bay Country Park with the
potential to generate landfill gases and leachate; and
The possible presence of made ground through areas of historical development,
most notably at BayPoint sports complex and the adjoining A256 bypass,
resulting in the potential for elevated concentrations of heavy metals, sulphates,
polycyclic aromatic hydrocarbons and ground gases to be present.
6.51
In the immediate vicinity of the cables route, sources of potential contamination have
been identified which may pose a risk to the environment. The most relevant of
these sources relates to evidence of free-phase hydrocarbon products in the ground
20m north of the cable landfall, together with dissolved phase hydrocarbon
contamination in the groundwater indicative of diesel and petrol contamination.
Information supplied by the Environment Agency makes reference to remedial works
having been undertaken, including small scale pumping trials and passive removal
of free-phase hydrocarbon products. Whilst the works are acknowledged to have
addressed any significant risk to the wider environment, the Environment Agency is
yet to receive a final verification report to detail the full extent of works undertaken
and effectiveness of the remediation.
6.52
An additional source of potential contamination relates to a pollution incident to
controlled waters associated with the rupture of a below ground fuel pipe beneath
BayPoint sports complex, which resulted in the release of diesel or fuel oil into the
ground. Information supplied by the Environment Agency has suggested that whilst
the bulk of the contamination was removed, subsequent monitoring to assess the
natural attenuation of hydrocarbons within groundwater did not take place.
Groundwater monitoring conducted by the former landowner in 2011 revealed the
presence of hydrocarbon contamination within groundwater beneath the BayPoint
sports complex, which is likely to be associated with the historical spill. It is
understood that there is a plan for remediation of the site in production.
6.53
The presence of three petrol filling stations within 60m of the cable route is
considered to represent a potential source of contamination, particularly given the
proximity of two of these features to the HDD section of the cables route. The
presence of these features gives rise to a potential source of various hydrocarbon
compounds together with chlorinated and non-chlorinated solvents, asbestos,
sulphuric acid and heavy metals.
Assumptions and Uncertainties
6.54
Intrusive works undertaken across the footprint of the converter station and
substation site were carried out as a general assessment of the wider power station
site and were not targeted to assess the proposed features or cable trench through
the power station site specifically.
6.55
Potential sources of contamination have been identified along the cables route
associated with hydrocarbon spills from a petrol station adjacent to the TJP and also
within BayPoint sports complex. Whilst the Environment Agency has supplied
information relating to remedial activities, they are not in receipt of verification
reports to confirm the extent of the works undertaken and the completion of
subsequent monitoring to confirm the adequacy of the works. The Environment
Agency has alluded to an assessment of BayPoint sports complex in 2011, which
95
confirmed that groundwater contamination is still present, presumably associated
with the historical spill. However, more detailed information was not available.
6.56
Across the remainder of the site, no intrusive investigation works have been
undertaken to date to determine the baseline conditions with respect to shallow soil
contamination, groundwater or surface water quality along the cable route.
Prediction and Assessment of Significance of Potential Impacts
Receptors at Risk
6.57
The assessment has identified potential receptors within four categories:




End users of the site, who may have an acute exposure to sources of
contamination on a regular and predictable basis;
Controlled water, being defined as all surface water, groundwater or perched
water;
Construction materials placed in the ground, including concrete used in the joint
transition pits; and
Other targets such as the “environment”, including any flora and fauna on or
near the construction corridor and construction and maintenance workers who
will have chronic but potentially higher levels of exposure than end users.
Pathways for Migration
6.58
Based on the current land uses along the cables route and at the former Power
Station site, and the anticipated ground conditions through the area, the following
contaminant pathways are considered potentially viable:





Ingestion, inhalation of soil/dust particulates or contaminant vapours, dermal
contact (absorption through skin);
Mobile/leachable contaminants will generally migrate vertically downward
through the superficial drift deposits until meeting the water table, after which
free/dissolved phases would be expected to migrate towards Pegwell Bay or the
River Stour, dependent upon the location within the site;
Buried concrete and other construction materials placed into the ground will be
susceptible to attack via contact with aggressive/contaminated ground,
especially if mobile groundwater is present;
Pathways for gas migration are considered to exist through superficial drift
deposits and sources of gas generation; and
Vegetation and other ecological targets may be affected by contact with
contaminated soils via plant uptake routes.
Pre-Construction Investigation Works
6.59
Prior to construction works commencing, investigation works will be undertaken to
confirm the ground conditions and extent of potential contamination along the route
of the proposed HDD, including the HDD receptor pit within the sports complex and
the launch pit on the former Power Station site. Investigation works will also be
undertaken within the footprint of the TJP at the cable landfall.
96
6.60
Through Pegwell Bay Country Park, investigation works will determine the depth,
nature and extent of the chalk-capping layer overlying historical landfill materials.
6.61
Within the footprint of the convertor station and substation targeted investigation
works should be undertaken to assess the ground conditions in the area of the cable
trench and associated structures.
6.62
No adverse effects on ground conditions or contamination will arise from the above
investigations given the localised and short-lived nature of the work.
Construction Phase
6.63
Heavy plant will be used during construction works on the converter station and
substation site and on the cables route. Temporary fuel storage and refuelling
facilities will be required.
6.64
A TJP will be constructed where the marine cables are joined to the onshore cables.
A chamber will be constructed below ground to allow for future access to inspect the
joints, with the access cover buried to allow natural colonisation with vegetation.
6.65
The general method of construction will involve the placement of cables through
open trenches measuring 1m deep by 1m wide at the base and battered back to
1.5m wide at the surface. Following placement of the cables at 0.5m centres the
trench will be backfilled with a minimum of 0.6m of cement bound sand (CBS)
followed by excavated topsoil.
6.66
Through Pegwell Bay Country Park, construction methods will be modified given the
anticipated presence of landfill materials. Through the northern half of the park,
where capping is unproven, the cable will be laid upon the existing ground surface
(following removal of vegetation and minor undulations) with a 1.0m thick capping
layer placed over the cables. The capping layer will be constructed to taper at a 1:5
slope with a 1.0m wide flat section at the top and will include a cellular confinement
system to prevent slippage and exposure of the cables. A minimum of 0.6m of CBS
will be used within the capping layer. Through the southern half of the park a hybrid
method of trenching and capping will be used, dependent upon the depth of chalk
capping present over landfill materials.
6.67
Horizontal directional drilling (HDD) will be used to place the cables between
BayPoint sports complex and the former power station to avoid disturbance of the
A256 bypass, Minster Stream and Hacklinge Marshes. The installation of conduits
will involve the drilling of pilot holes, reaming (to make the holes larger) and pulling
the cable conduits through the reamed holes. This process will involve the
construction of a launch pit within the former power station site and a receptor pit
within BayPoint sports complex. During the drilling of the pilot holes and reaming
process, a drilling fluid or ‘mud’ is used to loosen the materials in front of the drill
and carry it back to the entry point suspended in the mud. Ultimately the drilling fluid
will ‘break-out’ into the receptor pit. At the end of the drilling operation drilling fluids
and any wastes will be cleared from the site to a suitably licensed facility and the
excavations backfilled.
6.68
Along the cable route, jointing pits will be required in Pegwell Bay Country Park and
also in BayPoint sports complex to connect the HDD and trenched underground
cables sections.
97
6.69
Temporary access roads will be required along much of the route and through
BayPoint sports complex to provide access for the necessary plant and equipment.
The working width along the cable route will be between 15m and 25m with the
working area of the HDD launch and receptor pits taking up a maximum area of 25m
by 40m.
6.70
On land adjacent to the converter station and substation within the former power
station site, a contractor’s compound and laydown area will be established. This will
require any loose materials and vegetation to be stripped out.
6.71
Within the convertor station and substation site a construction platform will be
required for switchgear equipment, transformers and buildings and will contain oil
spill containment facilities in line with National Grid’s standard specifications. It is
anticipated that the construction platform will utilise piled foundations placed into the
natural strata or compacted fill, where suitably competent ground is present. The
finished construction platform will require the importation of crushed natural stone
for use through areas of hardstanding. The completed site will be surfaced partially
with stone chippings.
6.72
During creation of the construction platform, the bases of the former cooling towers
and any remaining underground pipe-work will be removed and the basement
located beneath the former turbine hall will be backfilled with suitably competent
imported materials.
6.73
Works that could potentially affect ground conditions or create contamination effects
during the construction phase of the development include:






Disturbance of contaminants exposing these to sensitive environments and
receptors from trenching and installation of the cables and excavation of the
TJP and joint pit within Pegwell Bay Country Park;
Excavation of the receptor and launch pits associated with HDD works and the
use of drilling fluids;
Creation of temporary access roads and construction compounds;
Disturbance of contaminants within the footprint of the convertor station and
substation associated with the demolition and removal of former below ground
structures and excavation and piling activities associated with construction of
new infrastructure.
Importation of contaminated materials from off-site; and
Spillage from fuelling and other operations.
6.74
The potential effects of the above works on the outlined receptors are assessed
below.
6.75
With respect to the underlying unconfined aquifer within the Marine Beach deposits,
Storm Beach deposits and Thanet Sand Formation, the following effects could
potentially occur from construction activities:


Creation of preferential pathways for the migration of contaminants;
Risk of contamination from mobile contaminants associated with imported
materials such as crushed stone for access roadways and construction
compounds, sub-base materials placed beneath hardstanding, capping
98

materials for use in Pegwell Bay Country Park and cement bound sand for
cable protection; and
Risk of pollution to groundwater from fuel, oil and chemical spills.
6.76
The sensitivity of the underlying aquifers is considered to be of Medium importance
and the magnitude of effects associated with the release of contaminants into
groundwater is considered to be Minor. The overall significance of the above effects
on aquifers and groundwater will be Negligible.
6.77
With respect to the surface water quality of the River Stour, Minster Stream and
smaller drainage channels, together with the marine environment, the following
effects could occur from construction activities:



Creation of preferential pathways for the migration of contaminants into water
bodies;
Risk of pollution to surface water from spills of fuels, oils, chemicals and siltcontaminated water; and
Potential discharge of silt-contaminated water, from surface water run-off and
dewatering activities.
6.78
The sensitivity of water bodies, is considered to be of Medium importance and the
magnitude of effects associated with the release of contaminants to surface water is
considered to be Moderate. The overall significance of effects on surface water is
categorised as Minor Adverse.
6.79
With respect to neighbouring properties and residents, the following effect could
arise as a result of construction activities:

Risk of release of contaminated dust during the movement of construction
vehicles.
6.80
The sensitivity of neighbouring properties and residents is considered to be of High
importance and the magnitude of effects associated with the release of airborne
contaminants is considered to be Minor. The significance of the above effect is
categorised as Negligible.
6.81
With respect to areas of flood risk, the following risks of contamination could
potentially arise through construction activities:


6.82
The potential risk of flooding of fuel or chemical storage areas, resulting in the
migration of contaminants to the surface water bodies and groundwater; and
The potential risk of flooding excavations where contaminated groundwater may
be present.
Using the significance criteria outlined earlier in the chapter, the sensitivity of flood
risk areas is considered to be of High importance and the magnitude of effects
associated with the release of contaminants into the controlled waters is considered
to be Minor. The significance of these potential effects is categorised as Minor
Adverse.
99
Operational Phase
6.83
During the operation of the onshore underground cables and subsea cables, no
effects are anticipated related to contaminated land. However, inspection of joint
pits along the cable route may be required if a fault occurs. This would involve
temporary excavation of soils at joint pits and subsequent reinstatement.
6.84
Occasional maintenance works may be required through Pegwell Bay Country Park
should the capping layer placed over the cables become eroded. If necessary, these
works would involve the importation and placement of fresh capping materials in
accordance with the original specification.
6.85
The converter station and substation will have back-up generators to provide an
electrical supply in the event of mains failure. Oil and diesel to power the generators
will be stored on site so there is a potential for leakage of these contaminants into
surface water and groundwater. Spillage or leakage of oil from transformers could
also occur during operation. The operation of the converter station and substation
will require minimal maintenance works
6.86
The following impacts are potentially associated with the operation of the proposed
development, with respect to human health:


The potential risk of site users and maintenance workers coming into contact
with contaminated ground or groundwater in the vicinity of the converter station
and substation site.
The potential risk of explosive of harmful ground gases, including landfill gases,
entering small buildings and confined spaces such as entry into the launch and
receptor pits of the TJP.
6.87
The sensitivity of human health is considered to be of High importance and the
magnitude of effects associated with the direct contact with contaminated ground or
groundwater is considered to be Moderate. Therefore, the significance of these
potential effects is categorised as Moderate Adverse.
6.88
With respect to routine inspection and maintenance works, the potential effects are
considered to replicate those associated with the operational phase (see above)
given that the works will be of a similar nature, albeit on a much smaller and
localised scale.
Mitigation
6.89
Within the footprint of the convertor station and substation targeted investigation
works will be undertaken to assess the ground conditions in the area of the cable
trench and associated structures.
6.90
Prior to construction works commencing, targeted investigation works will be
undertaken in agreement with an Environmental Health Officer to assess the nature
and extent of potential groundwater contamination associated with the historic
pollution incidents at the northern and southern ends of the cable route. Where
pollutant linkages are identified, a robust remediation method statement will be
compiled to detail the necessary mitigation measures.
100
6.91
Within Pegwell Bay Country Park, investigation works will be undertaken to assess
the nature and depth of capping materials overlying the landfill area. Should
investigation works identify a need for the construction phase to penetrate the
landfill materials (i.e. in the vicinity of the proposed joint pit) then a robust
remediation method statement will be compiled to detail the necessary mitigation
measures.
6.92
Fuels, lubricants, and chemicals required during construction and operation will be
stored in secure bunded areas at appropriate distances from watercourses with
refuelling restricted to these areas. Spill kits will be available on site in case of
emergency and drip trays will be used for static plant and refuelling areas.
6.93
Some of the components (e.g. transformers) within the substation and converter
station site will contain oils and lubricants as well as other potentially contaminated
materials. Standard design criteria will ensure such components are contained
within bunded areas.
6.94
Pollution prevention measures will be adopted to prevent contamination including
measures to intercept and treat run-off prior to leaving site including the use of cutoff ditches and filtration systems.
6.95
A Construction Environmental Management Plan (CEMP) will be prepared which will
set out methods which contractors will be required to undertake as a minimum to
ensure pollution control throughout the construction works.
6.96
The CEMP will include quality control procedures to be employed by contractors for
the import and export of materials to and from site. Methods for controlling surface
water run-off and dust and measures to remove contaminated materials off site to
licensed treatment or disposal sites will also be detailed. Refer to Chapter 7
(Hydrology and Flood Risk for further details of pollution prevention measures).
6.97
The CEMP will also include a Silt Management Strategy to address programming
and management of silt generating activities.
6.98
Should apparently contaminated material be found during excavation works, where
this has previously not been identified, work will cease until the material has been
characterised and appropriate measures to dispose of contaminated materials have
been identified. Contaminated materials will be characterised both chemically and
physically in line with BS EN 14899:2005 –‘Characterization of Waste - Sampling of
Waste Materials - Framework for the Preparation and Application of a Sampling
Plan’. Registered waste carriers will only be used to convey any contaminated waste
materials off site to suitably permitted facilities. All relevant documentation will be
completed and kept in line with regulations.
6.99
Laying cables over the surface of the ground within Pegwell Bay Country Park will
prevent potential contamination pathways being opened and prevent migration of
landfill gas and leachate if these are present within the landfilled area.
6.100
Measures will be undertaken to reduce the amount of water entering excavations so
as to minimise dewatering activities. Should de-watering be required, the
Environment Agency will be consulted and appropriate abstraction and discharge
licences will be obtained if necessary. Prior to disposal to surface water bodies,
water will be treated to ensure it meets appropriate water quality standards. Further
101
details on water management techniques are discussed within Chapter 6 Hydrology
and Flood Risk.
6.101
Soils excavated through areas of open trenching will be monitored to ensure they
are free from contamination and suitable for re-use.
6.102
Upon completion of the HDD works, surplus-drilling fluids will be pumped out of the
launch and receptor pits by vacuum tanker and removed from site to a suitable
registered waste disposal facility by a registered waste carrier.
6.103
Where elevated concentrations of sulphates have been identified through the area
of the proposed converter station and substation, resistance to potential sulphate
attack can be mitigated by the selection of an appropriate class of concrete.
Residual Impacts
6.104
Potential adverse effects will be eliminated through the application of the mitigation
measures identified above. Consequently, there will be no residual effects
associated with the development proposals on ground conditions and
contamination.
Cumulative Impacts
6.105
Potential cumulative effects on ground conditions and contamination from the
onshore elements of the Nemo Link in combination with other components of the
Project (i.e. UK, French and Belgian subsea cables and Belgian onshore
infrastructure) are described in Chapter 16.
6.106
Potential cumulative effects of the Proposed Development in combination with the
connection required to facilitate the operation of the Nemo Link are described in
Chapter 17.
6.107
There is little scope for cumulative effects relating to ground conditions and
contaminated land arising from the Proposed Development in combination with the
other unrelated development as detailed in Table 1.2 at Chapter 1. All unrelated
development is programmed to have been completed before work commences on
the proposed onshore elements of the Nemo Link subject to this planning
application. Any contamination found during construction of the other unrelated
development will have been addressed before the work commences on the
proposed onshore elements of the Nemo Link. Industry standard pollution control
measures in accordance with statutory guidelines (typically monitored and controlled
through a site construction management plan) are likely to be implemented
throughout construction works for all unrelated development. No significant
cumulative effects relating to ground conditions and contamination are anticipated to
arise.
102
References

Contaminated Land Developers Guide, Dover District Council.

Contaminated Land Risk Assessment: A Guide to Good Practice, CIRIA C552,
2001.

Contaminated Land Strategy, Thanet District Council.

Control of Water Pollution From Construction Sites - Guidance for Consultant
and Contractors, CIRIA C352, 2001.

Environmental Protection Act, Part IIA Contaminated Land, Parliament of the
United Kingdom, 1990.

Investigation of Potentially Contaminated Sites: Code of Practice, British
Standards Institution, BS10175, 2011.

Model Procedures for the Management of Land Contamination. Environment
Agency, Contaminated Land Report 11, 2004.

National Planning Policy Framework, Department for Communities and Local
Government, March 2012

Planning Policy Guidance 1: General Guidance to the Prevention of Pollution,
Environment Agency 2001.

Planning Policy Guidance 6: Working at Construction and Demolition Sites,
Environment Agency 2010

Planning Policy Guidance 21: Pollution Incident Response Planning,
Environment Agency 2009.

The South East Plan, Regional and Spatial Strategy for the South East of
England, Government Office for the South East, May 2009.

Water Protection and Management (The Water Framework Directive), Directive
2000/60/EC, European Parliament and Council of 23rd October 2000.
103
104
7.0
HYDROLOGY AND FLOOD RISK
Introduction
7.1
This chapter describes the existing water environment and identifies and assesses
the potential effects of the proposed UK onshore elements (the Proposed
Development) of the UK-Belgium Interconnector (the Project) on surface and ground
water resources. It describes the mitigation measures that will be incorporated into
the construction and operational phases of the Proposed Development to avoid,
reduce or offset potential adverse effects or enhances potential beneficial effects.
Legislation and Policy Context
7.2
Relevant national legislation and policy is outlined in Table 7.1, regional policy in
Table 7.2 and local policy in Table 7.3.
Table 7.1: National Legislation and Policy
Policy/Legislation Key Provisions
National Planning
Policy Framework
(NPPF) and
supporting
technical guidance
Flood and Water
Management Act
(2010)
The NPPF supersedes the previous applicable Planning
Policy Statement 25: ‘Development and Flood Risk’ and its
accompanying practice guide. Section 10 of the NPPF
discusses ‘meeting the challenge of climate change, flooding
and coastal change’.
In particular, under paragraph 99 – 104, the NPPF mentions
that inappropriate development should be avoided in areas at
risk of flooding. Where development is necessary, it is
essential to make it safe without increasing flood risk
elsewhere.
It also states that advice should be sought from the
Environment Agency (EA) and other relevant flood risk
management bodies, including lead local flood authorities and
internal drainage boards and stresses that a sequential test
should be applied to avoid development in areas at possible
risk to people and property.
The Act responds to the findings of the Pitt Review (2008)
into flooding and sets out measures to co-ordinate control of
drainage and flood issues. There are a number of increased
responsibilities for developers, Lead Local Flood Authorities
and the EA within the Act that affect adoption of SuDS
(Sustainable Drainage Systems) features including the
establishment of SuDS Approving Bodies (SAB’s) to review
and consent surface water drainage works. The role of the
EA is also to expand on the mapping data they provide both
in terms of sources of flooding and condition of flood
protection assets. Much of the Act is to come into force over
the next few years.
105
Policy/Legislation Key Provisions
The EU Water
Framework
Directive and River
Basin
Management
Plans
The WFD (2000) requires all inland and coastal waters to
reach ‘Good’ chemical and biological status by 2015. Flood
risk management is unlikely to have a significant effect on
chemical water quality except where maintenance works
disturb sediment (such as de-silting) or where pollutants are
mobilised from contaminated land by floodwaters. The main
effect of the WFD on flood risk management, both now and in
the future, relates to the ecological quality of water bodies.
The principal issues relating to fisheries and development
addressed in the Directive are:
 Water quality problems caused by industrial and
agricultural discharges and diffuse run-off;
 Land management practices that cause siltation to
waterways, destroying fish spawning areas and the food
sources and habitat on which fish depend;
 Acidification due to inappropriate tree planting, and;
 Water quantity and flow problems caused by, for example,
abstractions.
Water Resources
Act (1991) as
amended by The
Water Act (2003)
and Flood and
Water
Management Act
(2010)
The Act requires consent to be obtained for any discharges to
controlled waters. The Act further states that works in, over,
under or adjacent to main rivers will need the consent of the
EA.
From April 2012 in England and Wales, responsibility for
consents and enforcement in respect of Ordinary
Watercourse (i.e. not Main Rivers) passed from the EA to
Local Authorities, in the most part, except where there is an
Internal Drainage Board. Consent is required before carrying
out any work that will, or could, block the waterway, including
all work on culverts so as to reduce flood risk.
The Freshwater
Fish Directive
The EC Directive on Freshwater Fish is designed to protect
and improve the quality of rivers and lakes to encourage
healthy fish populations. It sets water quality standards and
monitoring requirements for areas of water, which are
chosen, or 'designated' by the Department for Environment,
Food and Rural Affairs (Defra). These designated areas of
water are selected because they are significant bodies of
water, which are capable of supporting fish populations. In
the UK the directive is implemented through the Surface
Waters Regulations 1997.
The Shellfish Water Directive (adopted in 1979) outlines the
requirements for the quality of designated waters, which
support shellfish (defined as bivalve and gastropod molluscs)
and aims to protect these shellfish populations from the
harmful consequences resulting from the discharge of
polluting substances into the sea. This Directive has been
transcribed into UK legislation under the Surface Waters
(Shellfish) (Classification) Regulations 1997 and The Surface
Waters (Shellfish) Directions 1997.
106
Policy/Legislation Key Provisions
The Groundwater
Directive
Groundwater
Regulations (1998)
Environmental
Permitting
Regulations 2010
The Groundwater Directive (80/68/EEC) aims to protect
groundwater from pollution by controlling discharges and
disposals of certain dangerous substances to groundwater. In
the UK, the directive is implemented through the
Environmental Permitting Regulations (EPR) 2010. The EA
protects groundwater under these regulations by preventing
or limiting the inputs of polluting substances into groundwater.
Substances controlled under these regulations fall into two
categories:
 Hazardous substances are the most toxic and must be
prevented from entering groundwater. Substances in this
list may be disposed of to the ground, under a permit, but
must not reach groundwater. They include pesticides,
sheep dip, solvents, hydrocarbons, mercury, cadmium and
cyanide. Hazardous substances replace the previous List 1
substances, which came under the 1998 Groundwater
Regulations (GWR).
 Non-hazardous pollutants are less dangerous, and can be
discharged to groundwater under a permit, but must not
cause pollution. Examples include sewage, trade effluent
and most wastes. Non-hazardous pollutants include any
substance capable of causing pollution and the list is much
wider than the previous List 2 substances. For example,
nitrate is included as a pollutant but it was excluded from
List 2 in the 1998 GWR.
107
Table 7.2: Regional Policy
Policy/Legislation Key Provisions
Regional Spatial
Strategy for the
South East (The
South East Plan)
 Policy NRM1: Sustainable Water Resources and
Groundwater Quality – water supply and groundwater will
be maintained and enhanced through avoiding adverse
effects of development on the water environment.
 Policy NRM4: Sustainable Flood Risk Management – The
Sequential approach to development in flood risk areas set
out in PPS25 (updated to the NPPF) will be followed.
 The flood zones as defined within the NPPF Technical
Guidance are the starting point for this sequential
approach. Zones 2 and 3 are shown on the EA published
flood map with Flood Zone 1 (low probability) being all the
land falling outside Zones 2 (medium probability) and 3 (3a
– high probability and 3b – functional floodplain). These
flood zones refer to the probability of sea and river flooding
only, ignoring the presence of existing defences.
 Inappropriate development should not be allocated or
permitted in Flood Zone 2 and 3, areas at risk of surface
water flooding (critical drainage areas) or areas with a
history of groundwater flooding, or where it would increase
flood risk elsewhere, unless there is over-riding need and
absence of suitable alternatives.
 Policy CC2: Climate Change – measures to mitigate and
adapt to current and forecast effects of climate change will
be implemented through application of local planning policy
and other mechanisms.
108
Table 7.3: Local Policy
Policy/Legislation
Key Provisions
Thanet Local Plan
The Thanet District Adopted Local Plan 2006 shows that the
former Richborough Power Station site is under the policy of
Wantsum Flood Risk Area (EP10) and Former Wantsum
Channel (CC2). EP10 has not been saved and expired in
June 2009. Policies related to Flood Risk and Surface Water
Run-off have not been saved beyond June 2009.
The Dover District
Council Core
Strategy 2010
Policy DM 17: Groundwater Source Protection –
 Within Groundwater Source Protection Zones, shown on
the Proposals Map, the following will not be permitted in
Zones 1 and 2 unless adequate safeguards against
possible contamination are provided:
i. Septic tanks, storage tanks containing hydrocarbons or
any chemicals, or underground storage tanks;
ii. Proposals for development which may include
activities which would pose a high risk of contamination
unless surface water, foul or treated sewage effluent, or
trade effluent can be directed out of the source
protection zone;
iii. Proposals for the manufacture and use of organic
chemicals, particularly chlorinated solvents;
iv. Oil pipelines;
v. Storm water overflows;
vi. Activities which involve the disposal of liquid waste to
land; and
vii. Sustainable urban drainage systems.
Method
7.3
Hydrology has been assessed in terms of the natural drainage patterns, base flows
and volumes, run-off rates, geomorphology and water quality. Potential effects
resulting from the Proposed Development on surface water, groundwater and flood
risk both during construction and operation have been assessed having regard to
the mitigation measures already integrated into the design.
7.4
The assessment has been carried out in consultation with the EA and it follows best
practice guidelines as listed below:







EA Pollution Prevention Guidelines;
Sewer for Adoption (6th edition) and interim technical addendum, 2011;
British Standard BS 8533:2011 Assessing and managing flood risk in
development Code of practice;
The SuDS Manual (CIRIA C697);
Catchment Flood Management Plans;
Thanet District Strategic Flood Risk Assessment; and
Kent Preliminary Flood Risk Assessment.
109
7.5
In accordance with EA policy regarding scale of development and site location in
respect of flood zones, a Flood Risk Assessment (FRA) has also been undertaken.
The FRA establishes the risk associated with the Proposed Development and
proposes suitable mitigation (where required) to eliminate or reduce the risk to a
more acceptable level. The FRA is contained in Appendix 7.1. Results from the
FRA are summarised in this chapter.
7.6
The FRA has been prepared in accordance with the requirements of the NPPF and
considers flood risk on-site and flood risk elsewhere as a result of the Proposed
Development. The FRA has also been prepared in accordance with the Interim
Code of Practice for Sustainable Drainage, BS 8533 and accompanying guidance
published by the Communities and Local Government Office. The guidance advises
the following steps:






Obtain information on the hydrology, hydrological and hydrogeological regime in
and around the site;
Obtain the view of the EA including scope, location and impacts;
Determine the extent of change to flooding provisions and the influence on the
site;
Review all potential sources of flooding and identify risk;
Review the surface water drainage based upon the proposed layouts, and
determine the extent of the infrastructure required; and
Assess the impact on the site from climate change and anticipated increases in
rainfall over the lifetime of the development.
7.7
During consultation, the EA provided details of flood modelling contained in the
‘Lower Stour Areas Benefiting from this Defence (ABD) and Hazard Mapping Study
Updates’ (undertaken by JBA Consulting in April 2012) and confirmed that the
Thanet District Strategic Flood Risk Assessment (SFRA, 2008) should be used for
the assessment.
7.8
The River Stour (Kent) Internal Drainage Board confirmed that ‘the Board does not
hold records of any flooding at this location, as all details are kept by the EA’.
Assessment of Significance
7.9
The evaluation and determination of significance has been carried out using
identified criteria, including published EA standards and flood risk assessment
guidelines.
7.10
The assessment of significance of potential effects of the Proposed Development
has taken into account:


7.11
The sensitivity of the receiving environment; and
The potential magnitude of effect.
A further consideration regarding sensitivity which has been taken into account for
the Proposed Development is that of ‘Critical Infrastructure’ as defined by the
Cabinet Office. CIRIA document C688 ‘Flood Resilience and Resistance for Critical
Infrastructure’ contains recommendations for the standard of flood protection for
different asset categories. These are defined in Tables 7.4 and 7.5 below.
110
Table 7.4: Concise Definition of Asset Categories (Courtesy of Cabinet Office)
Asset
Category
Concise Definition
5
Assets, the loss of which would have catastrophic impact on the
UK
4
Assets, the loss of which would affect millions of people
3
Assets, the loss of which would affect hundreds of thousands of
people
2
Assets, the loss of which would affect tens of thousands of people
1
Assets, the loss of which would affect thousands of people
Table 7.5: Examples of Resistance/Resilience Standards and Performance
Levels that may be Appropriate for Critical Infrastructure Assets in some
Sectors
Indicative
Design
Standard
Events
Target Asset Performance Level
Restricted
Unaffected Operation
(resistant) (resilient)
Safe but
Not
Operational
(resilient)
Near Failure
1 in 10 - 1 in
75 year
CAT 1
1 in 75 - 1 in
100 year
CAT 2
CAT 1
1 in 100 - 1
in 200 year
CAT 3
CAT 2
CAT 1
1 in 200 - 1
in 1,000
year
CAT 4
CAT 3
CAT 2
CAT 1
> 1 in 1,000
year
CAT 5
CAT 4
CAT 3
CAT 2
7.12
This criterion suggests that a CAT 1 asset should be unaffected for all flood events
up to a 1 in 75 year event but could operate at a restricted level for more extreme
events and may not need to be designed to be operational for events beyond a 1 in
200 year flood. A CAT 5 installation however, is to be unaffected for all events up to
and including the 1 in 1,000 year event and beyond.
7.13
Sensitivity, in terms of quality, value and rarity is defined in Table 7.6. Magnitudes
of effect are set out in Table 7.7 and have been determined by consideration of the
scale and extent of impact in terms of duration, the likelihood of occurrence and
reversibility.
111
7.14
The overall significance of potential effects considering sensitivity of receptor and
magnitude of effect is shown in Table 7.8.
Table 7.6 Sensitivity of the Water Environment
Receptor
Description
Sensitivity
High
 Area of international designations i.e. Ramsar site, Special
Protection Areas (SPAs) and Special Areas of Conservation
(SACs)
 EA designated main river i.e. River Stour and Minster Stream
 EA water quality Class A and B
 EA groundwater Source Protection Zone 1 – Inner protection zone
 EA defined Principal Aquifers
 Flood Zone 3
 Water sensitive and highly vulnerable development in the area
 Local flood defences/embankments for major rivers
 CAT 3, 4 and 5 Critical Infrastructure Asset
Medium
 Area of national and regional importance i.e. Site of Special
Scientific Interest (SSSI) and National Nature Reserves (NNR) and
Marine Nature Reserves (MNR)
 Local drains i.e. ordinary watercourses and water bodies
 EA water quality Class C and D
 EA Groundwater Source Protection Zone 2 – Outer protection zone
 EA defined Secondary Aquifers
 Flood Zone 2
 More vulnerable development in the area (including temporary
works and workforces)
 Local flood defences/embankment for drains
 CAT 2 Critical Infrastructure Asset
Low
 Area of local importance which are not designated
 Minor local drainage network/ land drains
 EA Water Quality Class of E and F
 EA groundwater Source Protection Zone 3 – Source catchment
protection zone
 EA defined Unproductive Strata
 Flood Zone 1
 Less vulnerable and water compatible development
 Local embankments for minor drains
 CAT 1 Critical Infrastructure Asset
112
Table 7.7 Magnitude of Effect
Magnitude Definition
High
Total loss or major alternation to key elements of features of the
baseline conditions to the extent that post-development character or
composition of baseline conditions will be fundamentally changed.
Medium
Loss or alternation to one or more key elements/features of the
baseline conditions to the extent that post-development character or
composition of the baseline conditions will be materially changed.
Low
Minor shift away from baseline conditions. Changes arising will be
detectable but not material; the underlying character or composition of
the baseline conditions will be similar to the pre-development
situation.
Negligible
Very little change from baseline conditions. Change is barely
distinguishable, approximating to a ‘no change’ situation.
Table 7.8 Significance of Effect
Magnitude
7.15
High
Medium
Low
High
Major
Moderate
Minor
Medium
Moderate
Moderate
Minor
Low
Minor
Minor
Negligible
Negligible
Minor
Negligible
Negligible/None
The significance of effect can be described as follows:



7.16
Sensitivity
Minor: Slight, very short or highly localised;
Moderate: Limited effect in terms of extent, duration or magnitude; or
Major: Considerable effect in terms of extent, duration or magnitude or more
than local significant or in breach of recognised acceptability, legislation or
policy or standards.
The nature of an effect can be classified as adverse; negligible (or no effect); or
beneficial:



Adverse: Classifications of significance indicate disadvantageous or negative
effects to an environmental receptor, which may be of Minor, Moderate, or
Major significance
Negligible/None: Classifications of significance indicate imperceptible effects to
an environmental receptor;
Beneficial: Classifications of significance indicate advantageous or positive
effects to an environmental receptor, which may be of Minor, Moderate or Major
significance.
113
7.17
Timescales associated with effects are categorised as follows:


Short to Medium Term: Effects associated where the effect is temporary and
last for the period of the construction works or less; and
Long Term: Effects associated where the effect remains for a substantial time,
perhaps permanently, after construction even though the activity that created it
may be ceased some time ago.
Uncertainty and Technical Difficulties Encountered
7.18
The assessment is based on desk study conducted in May 2012 and updated in
September/October 2012 due to additional information being issued related to a
planning application for new flood defence works alongside the A256 Sandwich
Road, that included new flood modelling work carried out by Halcrow on behalf of
the EA. For completeness, although the flood defence works are scheduled for
construction in 2013, the flood risk benefits provided by the proposed works has
also been considered within the cumulative impact assessment (see end of this
Chapter) in the unlikely event the construction of the flood defence works is not
complete before construction of the Proposed Development commences.
7.19
Climate change modelling of flood events undertaken by the EA does not cover the
more extreme events of 1 in 1,000 years or above. Following discussions with the
EA, the NPPF recommendations for climate change increases in flood levels have
been applied in this assessment.
7.20
NPPF considers both sea level changes and rainfall intensity changes that are
related to potential future changes in climate. Climate change influence will include
changes to rainfall and the resultant changes to the surface water flows from the
site. As the proposed converter station and substation site is adjacent to the tidal
influenced river, there is a risk of the tidewater rising and posing an increased risk to
the site. Table 7.9 and 7.10 summarises the current NPPF recommendations.
Table 7.9: Recommended Contingency Allowances for Net Sea Level Rises
Net Sea Level Rise (mm per year) Relative to 1990
1990
to 2025
to 2055
to 2085
to
2025
2055
2085
2115
East of England, east
midland, London, south4.0
east England (south of
Flamborough Head)
South-west England
3.5
North-west
England,
north-east England (north 2.5
of Flamborough Head)
114
8.5
12.0
15.0
8.0
11.5
14.5
7.0
10.0
13.0
Table 7.10: River Flow Recommended National Precautionary Sensitivity
Ranges for Peak Rainfall Intensities, Peak River Flows, Offshore Wind Speeds
and Wave Heights
Parameter
Peak rainfall intensity
Peak River flow
Offshore wind speed
Extreme wave height
7.21
1990 to
2025
+5%
+10%
+5%
+5%
2025 to
2055
+10%
+20%
2055 to
2085
+20%
2085 to
2115
+30%
+10%
+10%
From NPPF Technical Guidance Document Table 4 (recommended contingency
allowances for net sea level rises), for the 60 years from 2010 to 2070 the following
is considered applicable for a site in South-East England:2011 – 2025 (14 years @ 4mm per year) = 56mm
2025 – 2055 (30 years @ 8.5mm per year) = 255mm
2055-2070 (15 years @ 12mm per year) = 180mm
Total = 491mm
7.22
In addition, it is possible that rainfall intensity will increase by 20% with a
corresponding 20% increase in peak river flow.
7.23
The EA supplied flood modelling data as a set of Node locations with estimated
flood levels associated with each Node where the flood model predicted that
flooding would occur.
7.24
Many of the Nodes show ‘0’ values for some or all modelled flood events. This is
due to the model outputs not producing flood levels for these locations suggesting
the modelled flood events do not reach these locations. The confidence limits of the
EA data have been stated as +/- 150mm for the modelled flood node data. This is
due to the inherent inaccuracies of topographical data used in the model together
with model limitations and assumptions regarding tidal event prediction. Reference
should be made to the EA Standard Notice regarding data (contained within the
FRA – Appendix 7.1).
Existing Environment
Topography
7.25
Existing ground levels are approximately 3.0m AOD close to the Transition Joint Pit.
The land rises to 4.0m AOD alongside the cycle track at the northernmost extent of
the cable route and rises to 4.5m AOD as the route passes to the east of the
Pegwell Bay Country Park car parking area. The southern extent of the Country
Park, reaches 5.0m AOD. Within the BayPoint sports complex, ground levels fall
slightly towards the south to a low point of 4.7m AOD. The cables route crosses
Sandwich Road, which is at a height of 4.6m AOD.
7.26
The banks of Minster Stream are at approximately 2.0m AOD and the ground level
rises towards the former Richborough Power Station site boundary to 3.0m AOD.
115
7.27
Ground levels within the converter station and substation site vary due to the former
structures and the presence of some voids on the site. The general ground level is
at approximately 3.5m AOD within the converter station site. The levels fall slightly
to just below 3.0m AOD within the substation site; the proposed laydown area is
east of and approximately 500mm below the substation and converter station site
levels.
Hydrology
7.28
The Transition Joint Pit (TJP) is located on the foreshore within approximately 40m
of the mean high water mark of Pegwell Bay. A tidal lagoon is between the TJP and
Pegwell Bay Country Park immediately south of the proposed cables route.
7.29
Main rivers are watercourses shown on the statutory main river maps held by the
EA, the Department of Environment, Food and Rural Affairs (in England) and the
Welsh Assembly Government (in Wales). They can include any structure or
appliance for controlling or regulating the flow of water into, in, or out of the channel.
The EA has permissive powers to carry out works of maintenance and improvement
on these rivers with their formal consent required for works that affect a main river.
All other watercourses are defined under the Flood and Water Management Act
2010 as ordinary watercourses.
7.30
On 6 April 2012, when a further phase of the Flood and Water Management Act
2010 was implemented, responsibility for regulating activities on ordinary
watercourses in most areas of England and Wales transferred from the EA to Lead
Local Flood Authorities (LLFA) unless the watercourse is within an Internal Drainage
District where Internal Drainage Boards (IDBs) will retain their existing powers.
7.31
Figure 7.1 is annotated with the main water features in and around the proposed
converter station and substation site and onshore cable route.
7.32
The closest ’Main River’ to the proposed converter station and substation site is the
River Stour, 10m west of the proposed substation footprint at its closest point. The
River flows in a southerly direction along the western edge of the former power
station site. To the south of the proposed converter station and substation site, the
River Stour flows in a large loop around Great Stonar (extending for 3.4km south)
before heading north again. The River passes within 400m to the east of the cable
route, close to the river’s confluence with Pegwell Bay where the River discharges in
to the North Sea. The River is tidal from the coast to Plucks Gutter some 6km west
of the former power station site.
7.33
Minster Stream, also designated as a ‘Main River’, is less than 100m to the
northeast of the converter station site. The Stream flows in a linear man-made
drainage channel westward and passes beneath the A256. The onshore cables will
be routed beneath Minster Stream by Horizontal Directional Drilling (HDD). The
topographical data (Greenhatch Group topographical survey dated 1st February
2012) shows Minster Stream to be approximately 10.0m wide from top of bank to
top of bank. The water surface is shown at around 4.0m wide with water levels
recorded at a level of 0.25m AOD on the topographic survey.
7.34
There are a number of ‘ordinary watercourses’ consisting of interlinked drains in the
area located immediately to the west of Sandwich Road and the cable route. An
unnamed drainage channel (highways drainage) follows the cable route through the
116
southern areas of Pegwell Bay Country Park and Stonelees Nature Reserve, before
discharging into a small pond at the northwestern corner of the BayPoint sports
complex. The proposed onshore cables will be horizontally drilled beneath an
ordinary watercourse (unnamed) identified by the IDB alongside the northeast
boundary of the former Richborough Power Station at OS Grid Reference TR3341
6220.
7.35
Kent County Council Highways were contacted regarding existing highways
drainage within and around Sandwich Road and the proposed cables route however
at the time of preparing this assessment, no details have been provided.
7.36
The new A256 bypass (Phase 2 of the East Kent Access) was opened in May 2012
and includes a new section of road close to the application site between
Richborough Power Station (A256), Minster Roundabout (A299) and Lord of the
Manor Junction at Cliffsend. This highway link includes a new culverted crossing of
the Minster Stream to the east of the former Richborough Power Station site. In
addition, the road scheme includes a number of surface water balancing ponds
(attenuation ponds). The attenuation pond closest to the Proposed Development is
immediately to the west of the new Ebbsfleet Roundabout, approximately 150m
north of the converter station site. A second attenuation pond is Weatherlees Pond
on land to the northeast of the Weatherlees Hill Wastewater Treatment Works.
Discharges from both ponds will be into the local minor ditches that flow to the
Minster Stream that runs parallel to the new road scheme.
7.37
A further small pond is located within the northwest corner of the BayPoint sports
complex immediately west of the onshore cable route.
Drainage
Public Sewers – Southern Water
7.38
Details of the sewers from the sewer record plan are contained within the FRA
(Appendix 7.1).
Surface Water
7.39
Information provided by Southern Water does not show any public surface water
sewers in the locality. The nearest surface water sewers are within the residential
settlement in Cliffs End to the north of the proposed Transition Joint Pit. None of
these sewers are crossed by the cable proposals.
Foul Water
7.40
Weatherlees Hill Wastewater Treatment Works lies immediately north of the
converter station and substation site and off Ebbsfleet Lane (TR330628)
(Figure 7.1). The treatment works is owned by Southern Water and receives foul
water flows from the north via two large diameter rising mains; one receiving
partially treated wastewater from Broadstairs and Margate (incoming from the north)
and the second from Cliffs End and Ramsgate via Sandwich Road.
7.41
Southern Water plans indicate that there is currently a pair of 500mm diameter cast
iron rising mains within the A256 carriageway to the east of the former Power
Station site. These then run to the north of the former Power Station site and for part
117
of their length, parallel to Minster Stream. These foul sewers continue north until
reaching the southern corner of Weatherlees Hill Wastewater Treatment Works.
This is the foul flow inlet feed from the urban areas of Sandwich to the south.
Private Drainage
7.42
The former Richborough Power Station site does not connect surface water to a
public network. The area is drained via a private on-site drainage network with direct
discharges into the surrounding land drains and the River Stour to the south and
west.
7.43
A 1,200mm diameter outfall from the existing concrete apron area to the west of the
power station site is approximately 220m west of the Laydown Area on the northern
bank of the River Stour. It is unlikely that all existing site drainage will be directed to
this point due to the site levels. This outfall is indicated as having an invert level of –
0.33m AOD suggesting it would be tide locked on a regular basis.
7.44
The Laydown area is within the eastern portion of a wider concrete apron that has a
fall westward to a 400mm outfall approximately 80m west of the southwest corner of
the proposed access road around the Laydown Area. This outfall is shown leading
to a pump house and tank.
7.45
Outfalls to the north and east of the power station site will discharge into the minor
unclassified watercourses that lead to Minster Stream.
7.46
There are five discharge consents from the former power station site as identified in
the Envirocheck Data contained as part of a Phase 1 Environmental Study
(Appendix 6.1). These are shown at Table 7.11 below:
Table 7.11: Discharge Consents from the Former Richborough Power Station
NGR
Issued
Date
633200,1 June
62100
1985
633160,1 July 1993
62060
Revoked
Date
August 1999
633050,1
62150
633050,1
62150
633050,1
62150
August 1999
Trade Effluent
August 1999
Sewage Discharges –
Final/ Treated Effluent
Trade Discharges –
Cooling Water
June
1985
June
1985
June
1985
March 1997
August 1999
118
Discharge Type
Trade Discharges –
Cooling Water
Trade Discharges –
Cooling Water
Discharge
Into
Saline
Estuary
Freshwater
Stream/
River
Saline
Estuary
Saline
Estuary
Saline
Estuary
7.47
The Envirocheck Data also contains details of surface water abstractions within 1km
of the site. These are listed in Table 7.12 below. Each of these permitted abstraction
locations are for agricultural supplies and are located along the Minster Stream
upstream (northwest) of the cable route, substation and converter station sites. The
nearest abstraction point to the Proposed Development is located approximately
100m northwest of the proposed horizontally drilled section of the onshore cable
route and 125m north of the converter station site.
Table 7.12: Surface Water Abstraction Consents
NGR
Issued
Date
633430, 16-03-11
162330
20-10-06
633270, 16-03-11
162750
20-10-06
633150, 13-02-09
163000 01-12-06
01-12-06
01-12-06
17-05-89
632700, 20-10-06
163000
Operator
Abstraction For
St Nicholas
Court Farms
Ltd
Dyas Farms
1988 Ltd
St Nicholas
Court Farms
Ltd
Dyas Farms
1988 Ltd
Mr T Robertson
Messrs
Robertsons
Mr Sg
Robertson
Mr P.E. Dyas
Mrs B.E.
Young
Mr Sg
Robertson
General Agriculture:
Spray Irrigation
Abstraction
From
Point A,
Watercourse At
Ebbsfleet.
General Agriculture:
Spray Irrigation
Point B,
Watercourse At
Ebbsfleet.
General Agriculture:
Spray Irrigation
Point R,
Watercourse At
Ebbsfleet.
General Agriculture:
Spray Irrigation and
Storage
Points A-C,
Minster Stream &
Tributaries At
Minster Marshes
Surface Water Quality
7.48
The nearest historic water quality monitoring records available on the EA web based
database are for the River Stour at Plucks Gutter approximately 6km west of the
former power station site. This is within the non-tidal section of the river and not
representative of the tidally influenced section in the vicinity of the former power
station site. The EA classification of the water quality at the closest compliance
point, 3km downstream of the former Power Station site, is Grade B (good).
7.49
Three Local Authority Pollution Prevention and Controls are noted within the
Envirocheck Report (Appendix 6.1). Of these licences, two are shown to be
associated with petrol filling stations within a 100m radius of the site.
7.50
Within a 500m radius of the site, there are nine records of Pollution Incidents to
Controlled Waters, as detailed in Table 7.13 below:
119
Table 7.13: Summary of Pollution Incidents to Controlled Waters
Incident
Date
Nov 1995
Dec 1999
Oct1994
Dec 1999
Feb 1997
June 1992
Sep 1999
May 1997
April 1993
7.51
Distance
From Site
(Approximate
Direction)
14m
(Southwest)
Car Park
38m (South)
Behind Texaco
Garage
132m (South)
BP Service
Station
176m (South)
Pfizer Sports
Ground
(BayPoint
sports
complex)
317m (West)
349m (South)
Shipyard
398m (South)
420m (South)
428 m (East)
Water
Company
Sewage
Outfall
Receiving
Water
Incident
Severity
Not given
Minor
Incident
Not given
Minor
Incident
Crude Sewage
Not given
Minor
Incident
Organic Chemicals –
Diesel Fuels (Pipe
failure below ground
Potential
River
Significant
Incident
Unknown Sewage
Not given
Minor
Incident
Not given
Minor
Incident
Pollutant
Tip Leachate (Culvert
discharging orange
liquid into stream)
Organic Chemicals –
Mixed / Unidentified /
Waste Mineral and
Synthetic Oils
Rubble Litter or Solids
– Building Debris
Deposited on Saltings
Organic Chemicals –
Paints / Varnishes
Potential
River
Chemicals Unknown
Not given
Oils
Not given
Minor
Incident
Minor
Incident
Minor
Incident
Of these incidents, the most pertinent relates to the emergence of leachate
materials 14m from the onshore cable route which is associated with a landfill within
Pegwell Bay Country Park and a significant pollution incident within the former Pfizer
Sports Ground (Baypoint sports complex) associated with the failure of an
underground pipe releasing diesel.
Flood Risk
7.52
EA online flood maps show the proposed converter station and substation within the
former Richborough Power Station site are within an EA Flood Zone 1 area (low risk
of flooding). The River Stour (Kent) IDB confirmed that it is not aware of any recent
history of flooding in the area.
120
7.53
From the proposed Transition Joint Pit southward to the northern extent of the
Pegwell Bay Country Park as well as the section of route following the Thanet
Coastal Path are shown to be within the tidally influenced Flood Zone 3 (High Risk)
– see Appendix 7.1, FRA Figure 8. The section from the Coastal Path to the
proposed joint position (Location C) is within Flood Zone 2 (Medium Risk). From
Location C southwards to Stonelees Cottage and Location D (within the Baypoint
sports complex sports fields), the route is shown to be within Flood Zone 3. The
remaining section of the cable route is within Flood Zone 1 (low risk) with the
exception of the section immediately adjacent to the Minster Stream that is indicated
as lying within Flood Zone 2 (based on historic flood event mapping).
7.54
The Flood Risk Assessment (Appendix 7.1) clarifies the extent of the flood risk
zones and assesses the risk of flooding on the development as well as the potential
effect of the development on flood risk. The EA flood map is provided in Figure 7.2.
7.55
The FRA considered the following flood risk elements as defined as the ‘Forms of
Flooding’ by BS 8533. These are:






Flooding from Rivers (fluvial flood risk);
Flooding from the Sea (tidal flood risk);
Flooding from Land;
Flooding from Groundwater;
Flooding from Sewers (sewer and drain exceedance, pumping station failure
etc); and
Flooding from Reservoirs, Canals and other Artificial Structures.
7.56
The FRA concluded that the principal flood mechanism for the area within and
surrounding the application boundary (cable route as well as converter station and
substation locations) is that of tidal flooding both directly from the coast and from the
upstream tidal sections of the River Stour.
7.57
Table 7.14 outlines EA flood level data for the ‘defended’ (predicted flood levels
considering the influence of flood defence structures). The EA Node locations are
shown on Figure 7.3.
7.58
In general, the ground levels along the cable route are below predicted extreme tidal
flood levels at the northern end of the cable route and at the TJP. This is indicated
by positive values in Table 7.14. Ground levels rise above flood levels (negative
values in Table 7.14) for the main section of the cables route, except for a small
section close to the power station that will dip below flood levels. This area is the
section that will be horizontally directional drilled (HDD) beneath Minster Stream.
7.59
The A256 bypass is considered to partially mitigate the direct coastal flood risk to
the converter station site and substation site for current events and predicted
extreme events up to the 1 in 1,000 year tidal flood event with climate change to
2070. Following the implementation of the proposed coastal flood defence schemes
in tandem with the A256 works now in place, the coastal flood risk to the converter
station and substation site will be mitigated for current events and predicted events
up to the 1 in 1,000 year tidal flood event with climate change to 2070.
7.60
However, given that the proposed flood defence works do not form part of the
current baseline situation, the FRA considers the potential impact to the site of two
121
locations where it is considered likely that overtopping of the A256 could result in the
inundation of the land to the west and potentially the converter station and
substations site.
7.61
The nearest tidal flood level to the site is EA Node 29. Based on the current 1 in
1000 year flood level of 4.366mAOD, the impact of climate change, as defined
within the NPPF Technical Guidance, would result in an increase in the current tidal
flood level to 4.857mAOD (+491mm, refer to Section 7.22).
7.62
The first ‘overtopping location’ is along Sandwich Road close to Node 29 as
predicted by the EA modelling for the 1 in 200 and 1 in 1,000 year tidal events.
Floodwaters would cross the road and flow west to the Stonelees golf course. The
LiDAR information suggests a low point close to the access to the existing sewage
treatment works that could direct the flood flows south towards Minster Stream and
the site. With the construction of the bypass partly as an elevated structure and
incorporating a raised bund along the eastern side, the low point is effectively closed
at this point with the exception of land drainage and culverts beneath the new road
that link drainage to the Minster Stream.
Floodwaters would, as a result, be
contained within areas to the north and east of the bypass (including the golf
course).
7.63
The second ‘overtopping location’ is the Kingfisher Sluice to the east of the former
power station site. The topography suggests that a flood surge at a level
4.857mAOD would just overtop (by around 50-100mm) the ground around and
above the sluice and be conveyed west upstream along Minster Stream and also
the lower ground to the immediate south of the stream( as indicated as occurring
during the 2000 and 2001 flood events). Any overland flood flow that does not enter
and is contained by the stream would flow west towards the A256 roundabout at the
access to the former power station site. The flood depths would be very shallow as
the hard standing levels are flat and any floodwater would be spread across a wider
area. In a similar way to surface water flooding caused by extreme rainfall
exceeding pipe and gully capacities that may lead to shallow flooding close to the
Richborough Roundabout, the tidal event flooding would be much more rapid but
likely to be contained within the highway by the kerbs. This is not viewed as a
significant flood pathway and at the most leads to only shallow localised flooding
around the Port Richborough site and roundabout.
7.64
There are a number of EA modelled flood levels alongside the southern boundary of
the site associated with the River Stour. As with the other levels, the increased risk
for the extreme event due to climate change has not been modelled by the EA. The
appropriate EA data Nodes (Figure 7.3) with identified flood levels are Nodes 8, 20,
21, 22 and 23 as detailed in Table 7.15; climate change effects are also shown in
this table. When considering the application of climate change effects on these flood
levels the following predicted flood levels above Ordnance Datum (AOD) could be
inferred from the NPPF calculation.
122
Table 7.14: Predicted Flood Levels
Location
Location A –
Transition Joint Pit
(Figure 7.3 - EA
Node 45)
Location B – To
north of Country
Park where cycle
track meets
Sandwich Road
(TR34356363)
(Figure 7.3 - EA
Node 39)
Location C – Joint
Pit to west of
Country Park car
park and access
(TR34256348)
(Figure 7.3 - EA
Node 36 – nearest
with level data)
Location D – South
of Country Park in
northern corner of
Stonelees Nature
Reserve
(Figure 7.3 - EA
Node 29)
Location E – Joint
Pit within Sports
Ground for HDD
(Figure 7.3 - EA
Node 29 – nearest
with level data)
Location F – Exit of
HDD within former
power station site
(Figure 7.3 - EA
Node 29 – nearest
with level data)
Laydown Area –
within concrete
apron
(Figure 7.3 - EA
Node 8)
River Stour –
Southwest of
Converter Station
(Figure 7.3 - EA
Node 20)
Predicted Tide Flood Levels –
Defended
(m AOD)
1 in
1 in 200
1 in
200
(2070)
1,000
(2010)
Existing
Ground
Level
(m AOD)
Water to Ground
Level Difference
1 in 1,000 year
event
(max. m + / -)
4.540
5.035
5.040
3.000
+2.040
4.544
5.030
5.037
5.000
+0.037
2.183
3.703
3.710
4.800
-1.090
4.152
4.355
4.366
4.700
-0.334
4.152
4.355
4.366
4.700
-0.334
4.152
4.355
4.366
3.500
0.866
None
2.772
2.654
2.070
-0.702
2.438
2.846
2.866
3.210
-0.344
123
River Stour – South
of boundary of
Converter Station
and Substation
sites
(Figure 7.3 - EA
Node 21)
River Stour – South
of boundary of
Substation site and
Laydown area
(Figure 7.3 - EA
Node 22)
River Stour – West
of Laydown area
(Figure 7.3 - EA
Node 23)
2.400
2.826
2.846
3.010
-0.164
2.401
2.823
2.842
2.650
0.192
2.402
2.829
2.849
2.750
0.099
Table 7.15: Predicted Flood Levels (Tidal River Stour)
EA
NODE
Ref.
8
20
21
22
23
0.5% Flood
Level
(1 in 200 year
event – EA
model) (m)
2.438
2.400
2.401
2.402
0.5% Flood Level +
CC
(1 in 200 year event
with climate
change - EA) (m)
2.772
2.866
2.846
2.842
2.849
0.1% Flood Level
(1 in 1,000 year
event – EA
model) (m)
2.654
2.846
2.826
2.823
2.829
0.1% Flood Level +
CC
(1 in 1,000 year
event with climate
change - NPPF) (m)
3.145
3.337
3.317
3.314
3.320
NB all levels quoted in the above table will be subject to +/- 150mm EA model tolerances.
7.65
Although much of the main former power station site (including the converter station
and substation sites) is bounded to the south by a concrete wall approximately 1m in
height, the wall does not extend the full length of the area adjacent to the river and
in particular the laydown area. The anticipated extreme flood would overtop the
southern boundary at this location and inundate the existing concrete apron area
and floodwaters would flow north and east across parts of the areas within the
substation site (based on the topographical levels supplied). Figure 7.4 shows the
topographical survey overlain with the proposed site layout and annotated with the
predicted extent of the extreme event flooding.
Groundwater
7.66
Groundwater is considered in detail in Chapter 6, Ground Conditions and
Contamination and is summarised in this chapter.
7.67
The EA online groundwater map (Figure 7.5), which is based on the British
Geological Survey Aquifer data, illustrates that the application site (cable route and
proposed converter station and substation site) is not located within an EA
Groundwater Source Protection Zone (SPZ). This was confirmed by the EA within
Thanet District Council’s EIA Scoping Opinion.
124
7.68
The Marine Beach Deposits underlying approximately the northern two-thirds of the
cable route are designated as a Secondary (undifferentiated) aquifer whilst the
Marine and Estuarine Alluvium underlying the southern section of the cable route
and the proposed converter station and substation site are designated as
Unproductive Strata. Where Storm Beach Deposits are present (beneath BayPoint
sport complex) these have been classified as a Secondary A aquifer.
7.69
The underlying Thanet Sand Formation (which outcrops to the east of the former
power station site in the vicinity of Sandwich Bay to Hacklinge Marshes SSSI) is
classified as a Secondary A aquifer whilst the underlying White Chalk Sub-group
has been classified as a Principal aquifer.
7.70
Secondary A aquifers are identified on the EA website as ‘permeable layers capable
of supporting water supplies at a local rather than strategic scale, and in some
cases forming an important source of base flow to rivers’. These are generally
aquifers formerly classified as minor aquifers.
7.71
The shallow aquifer within the superficial deposits (predominately the cable route)
has been classified with a High vulnerability rating whilst the outcrop of the Thanet
Sand Formation (former Power Station site) has been classified with an Intermediate
vulnerability rating.
7.72
Whilst the cable route crosses a sensitive area with respect to groundwater, in the
vicinity of the cable route, substation and converter station sites, shallow
groundwater is unlikely to form an important resource for potable supply owing to
saline intrusion. The published hydrogeological map for the area (Institute of
Geological Sciences, ‘hydrogeological Map of the Chalk and Lower Greensand of
Kent) indicates Chloride concentrations within the White Chalk aquifer to be
approximately four times greater than the limit specified within the UK’s Drinking
Water Standards.
7.73
The Envirocheck Data contained as part of a Phase 1 Environmental Study
(Appendix 6.1) includes details of the two permitted groundwater abstraction
consents at a single location within 1km of the site. Both consents are for a single
location for general farming use and domestic supplies. These are listed in Table
7.16 below. The location of this well is approximately 815m due north of the former
Power Station site and 660m from the closest part of the on-shore cable route (at
the southern tip of the Pegwell Bay Country Park).
Table 7.16: Groundwater Abstraction Consents
NGR
Issued
Date
633240, 01-04-08
163090
18-02-93
Operator
Abstraction For
Abstraction
From
Mr J R S Tapp
General Farming
And Domestic
Borehole At
Ebbsfleet Farm
Chardon
Developments
Ltd
125
Prediction and Assessment of Significance of the Potential Impacts
7.74
The key components of the development are detailed in Chapter 2, Project
Description. The greatest risks of potential effects to the water environment would
occur during the construction phase. The main construction activities that may give
rise to effects on the water environment include; temporary access roads,
transportation of construction materials to both the onshore cable works as well as
the works within the former Power Station site (substation and converter station
sites); excavation of cables trench, HDD and associated excavation of launch and
receptor pits and construction traffic.
Construction Effects – General
7.75
The following potential effects on the water environment have been identified:






7.76
Hydrological change, including potential disturbance and modification of
watercourses, existing drainage patterns, overland flow routes and groundwater
recharge and flows;
An increase in surface water overflow as a result of changes in impermeable
area;
Sediment or chemical pollution of watercourses and land drains during
construction;
Interruption or disturbance of public or private water supplies;
Effects on aquatic ecology due to pollution, obstruction of land drains and
watercourses or change in hydrological regime; and
Disturbance and alterations to existing flood defences and floodplain.
The construction of impermeable surfaces will have a number of potential effects to
the water environment. The main effects would relate to:





Site drainage;
Surface water flow route;
Increased surface water discharge volume into nearby drains, the River Stour
and Minster Stream;
Possible contamination of nearby drains and watercourses due to runoff from
impermeable surfaces during construction; and
Mobilisation of silt and materials during sudden rainfall events, if not controlled,
will be conveyed to the surrounding ditch network.
Construction Effects – Surface Water
7.77
The use of HDD is proposed for the section of cable between the sports fields (at
BayPoint sports complex) and the converter station site. This is proposed to avoid
surface disturbance of a newly constructed roundabout on the A256, avoid
disturbance to Minster Stream and also avoid disturbance to a compartment of the
Sandwich Bay to Hacklinge Marshes Site of Special Scientific Interest (SSSI). The
embedded mitigation in terms of hydrology is that the cable route is to pass beneath
the Minster Stream and the flood risk zone associated with the low lying ground
immediately adjacent to the watercourse. The installation of the cables will not
require modifications (temporary or permanent) to the stream or interruptions in its
flow. The HDD will also pass beneath the minor watercourse identified by the IDB.
As a result, the magnitude of impact related to blockage or disturbance to the
126
watercourses and their hydrology is low. The sensitivity of the watercourses is high,
therefore the overall impact is minor adverse.
7.78
Impermeable areas associated with the cable route will be created as a result of
construction compounds and other associated infrastructure. As a result, less rainfall
is able to infiltrate into the ground, which will lead to an increase in surface water
runoff. As the construction compounds will only be temporary during the
construction phase and will be limited in footprint, the magnitude of effect is
therefore classed as low. The sensitivity of the River Stour, Minster Stream, local
ditches, SSSI, tidal ponds and BayPoint sports complex pond are classed as high in
terms of flood risk. The overall significance of effect is classed as minor adverse.
7.79
Impermeable areas associated with the works within the former Power Station will
be dependent on the method of construction and extent of new hard standing,
roadways and buildings. The areas within the former Power Station site (predemolition of the cooling towers) to be occupied by the laydown, converter station
and substation sites, based on the topographical survey, have a high existing
proportion of hard standing (buildings, towers, roadways and hard surfaces)
accounting for approximately 82% of the total area.
7.80
The levels on the converter station and substation sites and infilling of voids and
other structures are to be provided by the import of materials (achieving a 6F2
grading). It is considered that the filling material, once compacted, will represent a
reasonably impermeable surface and thus generate a high proportion of surface
water runoff during rainfall events. Table 7.17 identifies the anticipated changes in
permeable surfaces.
7.81
The resultant impermeable areas associated with the substation and converter
station works will have varying degrees of magnitude dependent on the existing
ground conditions. Table 7.17 has been annotated to include an assessment of the
magnitude of change. The magnitudes of the effect are therefore classed as
between negligible and medium. The sensitivity of the River Stour, Minster Stream,
local ditches, SSSI, tidal ponds and BayPoint sports complex pond are classed as
high in terms of flood risk. The overall significance of the effect is classed as
between minor to moderate adverse.
7.82
Four surface water abstraction locations have been identified along Minster Stream
upstream of the cable route, laydown area, converter station and substation sites.
These abstractions are classed as high sensitivity receptors. The magnitude of
effect due to discharges from or change to the drainage of any part of the works is
negligible. The overall significance of the effect is classed as minor adverse.
127
Table 7.17: Impermeable Areas
Site
Laydown
Site
Substatio
n Site
(main
area)
Substatio
n Site
(North
eastern
area)
Converte
r Station
Site
Total
Area
(Ha)
1.62
Impermeable
Area (Ha)
2.64
2.16 (access
roads, cooling
towers,
buildings)
0.27 (buildings
and access
roads)
82
3.65 (access
roads, cooling
towers,
buildings –
assumed as
topographical
survey does
not fully
identify
surfaces)
75
0.30
4.85
1.62 (concrete
apron)
%
Impermeable
Area
100
90
Proposed
Impermeable
Area (Ha)*
1.62 (access
and retained
apron areas)
2.64 (in-filled
towers,
realigned
accesses etc)
0.3 (access
road, car park,
buildings etc)
Proposed %
Impermeable
Area
100
Magnitude
of Impact
100 (assumed
subject to
detail design)
Low
100 (possible
landscaped
area could be
introduced)
Low
4.85 (assumed
whole site raised
by DoT Type 2
or 6F2 fill)
100
Medium
Negligible
NB Proposed values in the table above assume ‘impermeable’ characteristics of fill material based on Mott MacDonald DoT
Type 2 specification
7.83
There is a potential effect on the overland flow routes being disturbed due to
construction compounds, materials storage and open trench work. Diverted flows
can interrupt the existing drainage pattern and result in surface water draining to
other areas. The potential effects are likely to be short-term and the magnitude of
effect is classed as medium. The local receiving catchments and downstream
environment is principally the Country Park, SSSI and the areas immediately around
the substation and converter station sites. Therefore; the receptor sensitivity is
classified as high related to changes in surface water flow rates. The overall
significance is classed as moderate adverse.
Construction Effects – Water Quality
7.84
There is a potential risk of contamination of the local drains and watercourses with
silt-laden run-off. Silt-laden run-off can be generated during the construction phase
from a variety of sources including excavation works, dewatering activities, washing
plant and equipment and runoff from material stockpiles. Run-off can be
exacerbated by compacted and bare earth and is generally instigated by rainfall.
Surface-water run-off with high silt content can flow overland or via existing drainage
pathways into watercourses and water bodies where adverse effects may occur
including into the River Stour, Minster Stream and Pegwell Bay. When runoff enters
watercourses, the elevated levels of suspended solids may cause siltation within
aquatic ecosystems, resulting in the removal of oxygen from the water column and
have indirect impacts on fish, invertebrates and plants. Although the potential effects
are likely to be localised and short-term, the magnitude of effect is classed as
medium. The tidally influenced River Stour, Minster Stream, Pegwell Bay and other
ditches are classed as high sensitivity receptors. The overall significance of potential
effects is classed as moderate adverse.
128
7.85
To a lesser degree, the potential risk of accidental spillages of construction
materials, drilling fluids, oils and fuel will be present. Cement, in particular, if leached
into a watercourse or water body, will potentially have detrimental effects by drawing
oxygen from the water which could have a significant knock-on effect on aquatic
ecosystems by causing deterioration to the local water quality. In addition, there is
the potential for historic contaminates to be exposed and potentially released
(washed out) by shallow groundwater or rainfall events. The magnitude of effect is
considered to be low. The nearest water quality information available is for the River
Stour (which is tidal and saline); this information indicates a ‘good’ water quality
class and is therefore a receptor of high sensitivity. In the absence of quality data for
the local ditches and Minster Stream, these are also classed as having high receptor
sensitivity. The overall significance of the effect is minor adverse.
7.86
The surface water bodies close to the cable route include the balancing pond for the
bypass, which will be a low sensitivity body (as it is designed to accommodate
potentially contaminated runoff from highways), two salt-water tidal ponds and the
pond within the BayPoint sports complex. With the exception of the balancing
ponds, these water bodies are classed as medium sensitivity receptors based
primarily on ecological value and their establishment over a number of years. The
magnitude of either pollution or accidental spillage from any works associated with
the cable route, which passes close to the BayPoint sports complex pond, and tidal
ponds will be medium due to their close proximity and potential direct surface water
runoff linkage between the cable works and the ponds. The overall significance of
effect is moderate adverse.
7.87
The magnitude of either pollution or accidental spillage from works associated with
the converter station and substation construction will be low due to the separation of
these works from the ponds and interception of surface waters by the local ditch
networks. The overall significance of this effect is negligible.
Construction Effects – Groundwater
7.88
Similar to the potential effects identified for surface water, spills or leaks of fuels, oil
and building materials may have the potential to contaminate groundwater if a
pathway is present.
7.89
As there will be foundation construction works required for the TJP and excavations
for the HDD sections, vertical migration pathways through the superficial geology
may be introduced allowing surface contamination to affect the deeper groundwater
regime during excavation. The excavation will however be limited in depth
(maximum around 3m with the main trench works between 1-2m), with foundations
restricted to the bases of the structures (including the substation and converter
station). The potential effect on groundwater quality is therefore considered to be
low. The site is not located within the EA designated Source Protection Zone nor
within major aquifers; the receptor sensitivity is therefore also classed as low. The
overall significance of effect is negligible.
7.90
Works within the converter station and substation sites will include foundations for
new buildings as well as new drainage and utility trenches. In addition, fill operations
will be undertaken to provide suitable construction platform levels. Groundwater is
anticipated to be shallow and could be exposed during works on these sites. The
potential effect on groundwater quality is considered to be low. The site is not
129
located within the EA designated Source Protection Zone nor within major aquifers,
the receptor sensitivity is also classed as low. The overall significance of effect is
negligible.
7.91
One groundwater abstraction point has been identified approximately 815m due
north of the former Power Station site and 660m from the closest part of the onshore cable route. As discussed above, the potential effect on groundwater quality is
considered to be low. The abstraction is classed as a high sensitivity receptor. The
overall significance of effect is minor adverse.
Construction Effects – Flood Risk
7.92
Trench excavation works close to the TJP will be within Flood Zone 3 (high flood
risk, tidally influenced) with other sections of the cable works within Flood Zone 2
(medium risk). The potential effect of any stockpiling of excavated materials or
storage will be short-term with a low magnitude in terms of water displacement and
unlikely to alter the extent of the tidal flooding by any perceptible amount. The
receptor in this case is the Flood Zones 2 and 3 and can be classified as medium as
works are short-term and can be re-programmed to take account of weather and
tide conditions. The overall significance of effect is considered to be minor adverse.
7.93
The laydown area will be within Flood Zone 2 (medium flood risk, tidally influenced).
The potential effect of any stockpiling of excavated materials or storage will be
short-term with a low magnitude in terms of water displacement and is unlikely to
alter the extent of the tidal flooding by any perceptible amount. The receptor in this
case is the flood zone and can be classified as medium as works are short-term.
The overall significance of effect is considered to be minor adverse.
7.94
For the main converter station and substation sites, the flood risk is classed as low.
The potential effect of any stockpiling of excavated materials or storage will be
short-term with negligible magnitude in terms of water displacement and unlikely to
alter the extent of the tidal flooding by any perceptible amount. The receptor in this
case is the workforce and the trenching work during construction and can be
classified as medium as works are short-term and can be re-programmed to take
account of weather and tide conditions. The overall significance of effect is
considered to be negligible.
Operational Effects
7.95
Activities following construction will be limited to a small operational presence on the
converter station and substation sites, with the exception of occasional maintenance
and site inspection. However, there are some activities, which could pose a potential
risk to the local water environment; these are discussed below.
Operational Effects – Surface Water
7.96
There is a potential risk of increased surface water runoff from the substation and
converter station site into the local watercourses and drains during storm events.
This has the potential to cause localised flooding and increase the risk of flooding
downstream.
7.97
The magnitude of this effect for the cable route is considered to be negligible with
very small development footprint associated with the Transition Joint Pit. The
130
sensitivity of the receptors, Pegwell Bay is considered low in terms of surface water
volumes. As a result, the overall significance of effect is considered to be negligible.
7.98
The impermeable areas associated with the substation and converter station works
will have varying degrees of magnitude dependent on the existing ground
conditions. Table 7.17 has been annotated to include an assessment of the
magnitude of change in impermeable surfacing. The magnitudes of the effect are
therefore classed as between negligible (laydown area) and medium (converter
station and substation sites). The sensitivity of the River Stour, Minster Stream, local
ditches, SSSI, tidal ponds and BayPoint sports complex pond are classed as high in
terms of flood risk. The overall significance of the effect is classed as between minor
to moderate adverse.
Operational Effects – Water Quality
7.99
There is the potential for spills or leaks of fuel and oil to be deposited by vehicles
accessing the site during the maintenance operation. This accidental spillage of
fuels, oils and lubricants has the potential to cause pollution of the watercourses.
Maintenance visits will be carried out infrequently. The magnitude of effect is
considered to be low. The receptors are the River Stour, Minster Stream, local
watercourses, SSSI, tidal ponds and BayPoint sports complex pond with a high
sensitivity in terms of water quality impacts. The overall significance of effect is
minor adverse.
7.100
For the substation and converter station sites the principle influence on water quality
would be the new runoff from roadways and new access roads within the
development. Untreated runoff from these surfaces could contain a number of
pollutants deposited by vehicles (rubber from tyres, oil and fuel, metals etc.) as well
as provide a route for runoff from storage areas. As the internal operational traffic is
anticipated to be of low volumes, the magnitude of effect is considered to be low.
The receptors are the River Stour, Minster Stream, local ditches, SSSI, tidal ponds
and BayPoint sports complex pond with a high sensitivity in terms of water quality
impacts. The overall significance of effect is minor adverse.
7.101
With operational staff present on the converter station and substation sites, there is
a requirement to provide foul drainage to a number of the buildings. The proposal is
to contain the flows with septic tanks and regular off-site disposal. There will be no
direct linkages to watercourses but spillages could be mobilised by rainfall to the
surface water drainage networks within the sites and ultimately to the River Stour to
the south or local ditches and Minster Stream to the north. The quantities involved
will be low. The sensitivity of any of the receiving watercourses is high. The overall
significance of effect is minor adverse.
7.102
Some of the components (e.g. transformers) within the substation and converter
station sites contain oils and lubricants as well as other potential contaminant
materials. The transformers are likely to be plumbed to an underground dump tank;
a containment system will be adopted to ensure risk of spillage is minimised in
accordance with the Pollution Prevention Guidelines. There are no direct linkages to
watercourses but spillages due to extreme rainfall events and poor maintenance of
the containment areas could mobilise pollutants to the surface water drainage
networks within the sites and ultimately to the River Stour to the south or local
ditches and Minster Stream to the north. The quantities involved will be low and the
131
combination of events required leading to a spillage would reduce the potential for
harmful releases. The sensitivity of any of the receiving watercourses (River Stour to
the south or local ditches and Minster Stream to the north) is considered high. The
overall significance of effect is minor adverse.
Operational Effects – Groundwater
7.103
Similar to the potential effects discussed for surface water, there is a potential risk
that contaminants from spills or leaks or fuels and oils, may enter the superficial
geology and reach the groundwater. As there will be limited traffic anticipated during
the operational stage, with only maintenance works to be undertaken and small
numbers of staff movements, the magnitude of effect is considered to be negligible.
Groundwater in the area is not within any EA designated Source Protection Zones
or major aquifer zones, and is therefore classed as having a low sensitivity. The
overall significance of effect is negligible.
Operational Effects - Flood Risk
7.104
As there are no above ground structures associated with the cable route, flood risk
will not be affected by proposed cables works. The magnitude of effect is considered
to be negligible. The sensitive receptors to flood water level changes will be the
Country Park, which is classified as of high sensitivity. The overall significance of
effect is minor adverse
7.105
For the substation and the converter station sites, the new impermeable areas
would be within the former Power Station site. These works are within a low flood
risk (Flood Zone 1) area. For the current predicted flood events up to and including
the 1 in 1,000 year tidal flood, the magnitude of effect is considered to be negligible.
In accordance with CIRIA C688 - Flood Resilience and Resistance for Critical
Infrastructure (2010) the substation and convertor station are considered to be CAT
5 and CAT 3 installations respectively, which are defined as high sensitivity
receptors in accordance with the definitions set out within Table 7.6. The overall
significance of effect is minor adverse
7.106
The predicted flood risk in the longer term (climate change to 2070) increases the
area within the substation and the converter station sites potentially affected by
extreme flooding (see Figure 7.4). The predicted depths of floodwater are relatively
shallow across much of the site and as a result the magnitude of effect is considered
to be high in terms of maintaining a resistant (unaffected) site and medium in terms
of maintaining a restricted operational site. The receptors being the CAT 5 and CAT
3 installations involved on the substation (CAT 5) and the converter station (CAT 3)
sites are both considered high sensitivity receptors. The overall effect is therefore
major adverse for the substation site (CAT 5 installation) and moderate adverse for
the converter station site (CAT 3).
132
Summary of Potential Effects
Table 7.18: Potential Effects
Effects
Magnitude of
Effects
Construction Effects
Surface Water
Blockage or
Low
disturbance to
watercourses
Increase in surface
Low
water runoff from
impermeable
surfaces – Cable
Route compounds
and storage areas
Increase in surface
Negligible to
water runoff from
Medium
impermeable
surfaces –
Converter Station
and Substation sites
Construction
Medium
material stockpiles
and operations
changing overland
flood flow pathways
Impact on Surface
Negligible
Water Abstractions
Water Quality
Risk of silt-laden
Medium
water entering the
local drainage
system
Accidental spillage
Low
of construction
materials into
nearby
watercourses
Risk of silt-laden
water or accidental
spillage of
construction
materials into
nearby water bodies
– bypass balancing
pond
Low
133
Receptor Sensitivity
Overall
Significance of
Effect
High
Minor – Adverse
High
Minor – Adverse
High
Minor – Adverse
to Moderate Adverse
High
Moderate Adverse
High
Minor – Adverse
High
Moderate Adverse
High
Minor – Adverse
Low
Negligible
Effects
Risk of silt-laden
water or accidental
spillage of
construction
materials into
nearby water bodies
– Tidal Ponds and
BayPoint sports
complex pond
Groundwater
Contamination to
groundwater
through vertical
migration
Impact on
Groundwater
Abstractions
Flood Risk
Construction works
within flood risk
areas (Flood Zones
2 and 3) – Cable
Route
Construction works
within flood risk
areas (Flood Zone
2) – Laydown Area
Construction works
within flood risk
areas and impact
on works and
workers – Converter
Station and
Substation sites
Overall
Significance of
Effect
Moderate –
Adverse
Magnitude of
Effects
Receptor Sensitivity
Medium
Medium
Low
Low
Negligible
Low
High
Minor – Adverse
Low
Medium
Minor – Adverse
Low
Medium
Minor – Adverse
Negligible
Medium
Negligible
Low
Negligible/None
High
Minor – Adverse
to Moderate Adverse
Operational Effects
Surface Water
Increase in surface
Negligible
water runoff due to
new impermeable
surfaces – Cable
Route
Increase in surface
Negligible to
water runoff due to
Medium
new impermeable
surfaces –
Substation and
Converter Station
Sites
134
Effects
Water Quality
Accidental spills or
leaks of fuels from
maintenance
vehicle
Changes in
drainage network
and new surfaces
with vehicle use
Staff requirement
for foul water
drainage
Drainage of bunded
areas
Groundwater
Effects of spills and
leaks to
groundwater
Flood Risk
Introduction of cable
route structures
within identified high
risk flood zones
Introduction of
substation and
converter station
structures within
identified high risk
flood zones –
current flood zones
Introduction of
substation and
converter structures
within identified high
risk flood zones –
climate change
effects
Magnitude of
Effects
Receptor Sensitivity
Overall
Significance of
Effect
Low
High
Minor – Adverse
Low
High
Minor – Adverse
Low
High
Minor – Adverse
Low
High
Minor – Adverse
Negligible
Low
Negligible
Negligible
High
Minor – Adverse
Negligible
High
Minor – Adverse
Medium to
High
High
Moderate –
Adverse (CAT 3)
to Major Adverse
(CAT 5)
Mitigation
7.107
If not adequately controlled, construction activities may have a number of short-term
effects on the water quality of the surface water environment. Appropriate measures
will be put in place prior to and during construction works in accordance with
legislative requirements and good practice guidance,
7.108
Measures to prevent pollution of the water environment (including measures to
control and manage silt-laden run-off, control mud deposits and prevent
spillages/leaks) will be in place during the construction phase and these will be set
135
out within a Construction Environmental Management Plan (CEMP). Good practice
guidance will be based on EA Pollution Prevention Guidance:
Identified
construction and operational effects can be effectively mitigated by planning and
management of construction techniques and by incorporating mitigation measures in
the final design of the Proposed Development.
7.109
Potential environmental effects and any necessary mitigation measures have been
identified as a result of information received from data collection and knowledge of
the effects and appropriate mitigation measures from similar construction projects.
7.110
Many of the short-term effects arising from the Proposed Development can be
effectively mitigated by adopting construction techniques and practices outlined in a
CEMP based on addressing the EA Pollution Prevention Guidance (PPG) as listed
below:














7.111
PPG 1 – General guide to the prevention of pollution;
PPG 2 – Above ground oil storage tanks;
PPG 3 – Use and design of oil separators in surface water drainage systems;
PPG 4 – Treatment and disposal of sewage where no foul sewer is available;
PPG 5 – Works and maintenance in or near water;
PPG 6 – Pollution prevention guidance for working at construction and
demolition sites;
PPG 7 – Refuelling facilities;
PPG 8 – Safe storage and disposal of used oils;
PPG 13 – Vehicle washing and cleaning;
PPG 18 – Managing fire water and major spillages;
PPG 20 – Dewatering underground ducts and chambers;
PPG 21 – Pollution incident response planning;
PPG 22 – Dealing with spills; and
Managing concrete wash waters on construction sites guidance.
The CEMP will set out methods which contractors will be required to undertake as a
minimum. The following measures will be included in the CEMP:






Where feasible, suitable construction techniques will be adopted to ensure that
no migration pathways are created to jeopardise groundwater quality;
Appropriate storage and handling measures for all hydrocarbon fuels and
lubricating oils, including the use of bunded storage areas or the use of doubleskinned storage tanks;
The use of drip trays for static plant and designated refuelling areas for mobile
plant;
The implementation of appropriate spillage contingency measures to mitigate
the effect of such spillages on the surface water; and
Appropriate personnel awareness training of the potential environmental
implications of all construction work on site.
The prevention of silt-laden run-off and mud entering the surrounding surface
water drains and watercourses by:
o Timely site phasing and engineering, thus minimising un-surfaced and unvegetated areas of the site;
o The provision of measures to intercept and treat run-off prior to it leaving
site, including the use of peripheral cut-off ditches, settlement facilities,
136
o
7.112
To minimise the risk of spillages resulting in a serious pollution incident, a Storage
and Spillage Emergency Response Plan will be in place, which will include:











7.113
filtration and/or use of flocculants to effect the removal of water borne
particulates; and
The provision of wheel-cleaning equipment for site plant to prevent the
tracking of mud onto the public highway and therefore into the off-site
surface water drainage systems.
The storage and use of fuel and oils on site in accordance with the Control of
Pollution (Oil Storage) (England) Regulations 2001;
Fuel and other potentially polluting chemicals stored well away from
watercourses in a secure impermeable and bunded storage area (minimum
capacity 110% of the storage capacity of the tank);
Refuelling of plant in a designated area at the site compound only;
Maintenance of vehicles in a designated area at the site compound only;
Fixed plant will be self bunded and/or part of a controlled containment system in
accordance with EA Pollution Prevention Guidance;
Mobile plant will be in good working order, kept clean and fitted with drip trays
where appropriate;
Spillage kits and absorbent material will be carried by mobile plant;
The site will be secured to prevent vandalism that could lead to a pollution
incident;
Designated concrete wash out areas will be constructed in accordance with
good practice guidance and will be clearly identified and used;
An Emergency Response Plan will be prepared and construction workers
trained to respond to spillages; and
Construction waste or debris will be prevented from entering any waterbody.
Discussions with the EA and their response contained within the Thanet District
Council Scoping Opinion states that the River Stour and Minster Stream are
designated main rivers and are under EA jurisdiction for the purposes of its land
drainage functions. Written consent is required under the Water Resources Act 1991
and associated Byelaws prior to carrying out any works to these watercourses,
including works:




In, over, or under the channel of these watercourses;
On their banks;
Within 15m of the top of their banks; and
Within 15m of the landward toe of any flood defence (where one exists).
Surface Water
7.114
HDD is proposed for the cables between the BayPoint sports complex sports fields
and the former power station. This will avoid surface disturbance of the recently
constructed roundabout on the A256, avoid disturbance to Minster Stream and also
avoid disturbance to a compartment of Hacklinge Marshes Site of Special Scientific
Interest (SSSI). The cable route will pass beneath the Minster Stream and the flood
risk zone associated with the low lying ground immediately adjacent to the water
course. Cables installation by HDD will not require modifications (temporary or
permanent) to the stream or interruptions in its flow.
137
7.115
If suitable outfalls are not available for the drainage of areas within the former power
station site (re-use of existing outfalls), a new outfall may be required. As such a
Flood Defence Consent from the EA as described above will need to be obtained.
7.116
All utility services associated with the development, including re-use of existing
surface water outfalls from the former power station site, will be designed to ensure
their long-term fitness for the purpose, and will be appropriately tested prior to
commission to demonstrate their integrity and maintained throughout their use.
7.117
The discharge criteria for the proposed works has been adopted based on best
practice guidance and advice received from the EA. The EA has stated that they
would like to see the application of Sustainable Drainage measures where possible
and a consideration of the effects of high tides on submerged outfalls. As infiltration
is not a viable option due to existing ground conditions and proposed infilling,
storage and on-site attenuation should be considered. The overarching criterion is
not to cause an increase in flood risk off site.
7.118
The following table considers the attenuation required to match the existing
predicted runoff rates into the receiving watercourses. For the areas draining to the
north it has been assumed that discharge will be restricted to a ‘greenfield’ rate in
order to provide a worst-case estimation of the attenuation volume required.
However, the greenfield flow rate falls well below the BRE recommended lower limit
for effective and manageable flow control. As a result the areas are too small in
isolation to require control or attenuation as the total peak flows are below 5 l/sec.
Table 7.19: Discharge Rates and Attenuation (Free Discharge)
Site
Current
Free
Discharge
(l/sec)
1 in 1 1 in 30 1 in
100
Discharge
Limitations
Proposed
Discharge
(l/sec)
1 in
1 in
1
30
Laydown
Site
171
386
457
Free discharge
to tidal water
171
386
386
0
1
47
1 in
100
+CC
61
Substation
Site
(main area)
232
528
634
Free discharge
to tidal water
232
528
528
0
33
120
156
Substation
Site
(North
eastern
area)
0.8
2.1
3.0
Attenuated
discharge to
north to minor
ditches
5
5
5
0
0
0
0
Converter
311
Station Site
640
771
Free discharge
to tidal water
330
634
640
0
167
354
460
138
Free
Attenuation Volume
Existing Rates (m3)
1 in
100
1 in 1
1 in
30
1 in
100
to
Comments
Due to site
layout –
discharge
may require
pumping –
see
comments
below
Proposed
discharge
limited to
existing 1 in
30 - Storage
provided
within site
Proposed
discharge
limited to
minimum
effective
controllable
value of
5l/sec – BRE
Proposed
discharge
limited to
existing 1 in
30 - Storage
Site
Current
Free
Discharge
(l/sec)
1 in 1 1 in 30 1 in
100
Discharge
Limitations
Proposed
Discharge
(l/sec)
1 in
1 in
1
30
Free
Attenuation Volume
Existing Rates (m3)
1 in
100
1 in 1
1 in
30
1 in
100
to
Comments
1 in
100
+CC
provided
within site
7.119
For the outfalls to the south, Table 7.16 below considers the free discharge situation
with Table 7.19 considering a surcharged outfall event (such that an outfall with an
invert at 0.0m AOD is submerged by the extreme tidal flood level in the River Stour
(approximately 2.80m AOD)). This would then generate the peak on-site storage
requirements.
7.120
The proposed discharge rates listed in Table 7.20 below are the resultant flow rates
taking into account the surcharging effects. Hence, the rates are lower than the free
discharge rates and on-site attenuation will be required.
Table 7.20: Discharge Rates and Attenuation (Surcharge Discharge)
SITE
Laydown
Site
Current Free
Discharge
(l/sec)
1 in 1 1 in 1 in
30
100
171
386 457
Surcharged
discharge to
tidal flood
water (2.8m)
232
Substation
Site
(North
eastern
area)
Converter
Station Site
Not applicable - Discharge to north to minor ditches
640
771
Surcharged
discharge to
tidal flood
water (2.8m)
Tide Locked
Discharge
(l/sec)
1 in 1 in
1 in
1
30
100
147
293
304
Substation
Site
(main area)
31
1
528 634
Discharge
Limitations
Surcharged
discharge to
tidal flood
water (2.8m)
234
69
426
331
139
Tide Locked Volume(m3)
1 in 1 1 in 30
Comment
s
0
38
453
0
90
1 in 100 1 in 100
+CC
92
120
Due to site
layout –
discharge
may require
pumping –
see
comments
below
186
242
Proposed
discharge
control to
existing 1 in
30 but tide
locking
effect
reduces
discharge
Storage
provided
within site
397
274
1,278
1,778
2,311
Proposed
discharge
control to
existing 1 in
30 but tide
locking
effect
reduces
discharge
Storage
provided
within site
7.121
As can be seen from the tables above, it is the more extreme events that require
accommodation on site, primarily due to the capacity constraints resulting from
surcharging outfalls. This allowance also provides control of the peak discharge
during non-tide locked events and meets the more sustainable goals of the drainage
solution. Figure 7.6 highlights potential mitigation options.
Surface Water Mitigation - Laydown Area
7.122
The Laydown Area is the eastern extent of a wider concrete apron area that extends
further to the west and ultimately to the identified 400mm outfall that leads to a
pumping station. The western boundary of the proposed Laydown Area will be
formed by the proposed access road. In order to contain and control runoff from the
temporary laydown facility and provide pollution control, it is recommended that a
low bund be incorporated alongside the access road between the road and the
storage areas. Due to the existing falls in the concrete apron (which are westward),
an informal settlement basin would be formed. Surface water from this area can
then be pumped to a suitable outfall within the main substation site or by agreement
to an outfall further west. Pumping will necessitate the agreement to a suitable
economic discharge rate, as pumping at the calculated free discharge rate would
require large pumping equipment. The alternative would be to create a new outfall
through the southern river wall and discharge into the River Stour.
7.123
The pumping option is considered the most appropriate solution due to the
temporary nature of the Laydown Area. No attenuation will be required on the
substation site for this flow as it will be restricted to a greenfield (and manageable)
rate by the pumping operation. Calculations for this area suggest that the greenfield
discharge rates would be around 11.4 l/sec for the 1 in 30 year event. If the
discharge were to be restricted via pumping to this value then the maximum volume
of storage required to contain the 1 in 100 year event would be approximately
800m3. If existing ground levels are to be maintained then this could result in
shallow flooding at a maximum depth of around 250mm located to the south and
west of the Laydown Area (mainly within the substation Laydown Area) and covering
approximately 5,000m2. Lower volume storm events would be restricted to smaller
areas and shallower depths. It is therefore possible to contain the flood volume
within the Laydown area with careful management of the storage and handling of
materials.
Surface Water Mitigation - Substation Site
7.124
It is proposed to discharge surface water from this site to the tidal River Stour to the
south. It should be noted that any outfall would need to pass beneath the proposed
service/access road and the land between the access road and potentially require a
new outfall through the river wall. Further detailed surveying of existing drainage
networks is recommended to confirm or otherwise existing surface water outfall
locations, conditions and suitability for re-use.
7.125
The tables above show that flow could be restricted to the 1 in 30 year existing flow
rate with a nominal 156m3 of storage required on site. However, when considering
the extreme tide lock situation and the surcharging of the outfall, approximately
242m3 would be required to contain the 1 in 100 plus climate change rainfall events.
This storage could be provided in areas within the south of the site. The introduction
of filter strips and infiltration trenches alongside the proposed roads should also be
140
considered. Although infiltration to the underlying soils will be limited, the trenches
would temporarily store surface runoff before conveying flows to the main storage
area prior to discharge at the 1 in 30 year rate. Thus, a sustainable approach to
water management would be provided and the trench will also provide an additional
level of water quality treatment prior to passing through an oil interceptor at the
discharge point.
7.126
The combination of trenches alongside access roads with a potential consideration
of harvesting rainwater from roof areas for use on site would reduce the total volume
required to accommodate storm water runoff within any attenuation basin. It should
be noted however, that the water demand from this site is small and would limit such
benefits with regards to reducing total attenuation volumes.
7.127
Any attenuation basin could also serve as a reservoir for firewater storage when
combined with a permanent water storage facility with back-up mains water
supplies.
7.128
The part of the substation site located to the north of the converter station site may
require a separate drainage system, discharging to the local minor ditches adjacent
to the northern site boundary. As discussed above in Table 7.20, the rates of runoff
from this area are small and on-site attenuation for this area would not be required.
7.129
The use of permeable surfacing is to be considered for the car park area within this
part of the substation site and, if possible incorporate soft landscaping to the areas
between the access roads, car parking and buildings. This would reduce the runoff
much further and is consistent with the first principle of SuDS drainage design,
which is to minimise the volume of runoff generated at source. The use of
permeable paving will also enhance the pollution control provision by treating
highway runoff prior to discharge.
Surface Water Mitigation – Converter Station Site
7.130
In a similar way to the substation site, surface water can be attenuated by a
combination of infiltration trenches alongside the access roads and a main
attenuation basin to the south of the site with an outfall at the south-western corner
of the converter station site. Firewater storage and rainwater harvesting could also
be incorporated. The maximum total storage required, when considering tide locking
of the converter station outfall, would be 2,311m3 (also allowing for climate change
effects). Due to this larger volume requirement, consideration should be given to
providing the main storage for the 1 in 30 year storage volume (1,278m 3) using
features such as trenches and basin/s. The higher and rarer storage volumes could
be contained within areas that could be allowed to flood in these rare events such as
car parking and hard standing areas (areas that would not lead to increased
pollution risk or affects operational plant etc.).
7.131
Water conservation measures in accordance with good practice and modern
building regulations will be considered.
Water Quality
7.132
The surface water drainage design is to be based on best practice guidance such as
CIRIA ‘SuDS Manual’ and advice received from the EA. The EA has stated that they
would like to see the application of Sustainable Drainage measures where possible
141
and a consideration of the effects of high tides on submerged outfalls. As infiltration
is not a viable option due to existing ground conditions and proposed infilling,
storage and on-site attenuation should be considered. The overarching criterion is
not to cause an increase in flood risk off site.
7.133
Contamination related to the storage and handling of materials on site is relatively
minor in nature and in accordance with the draft Sustainable Drainage Standards,
would require at least three levels of treatment prior to discharge to a sensitive
watercourse (River Stour identified by the EA as sensitive). These levels could be
provided by:
a)
b)
c)
The infiltration trench;
Settlement/containment lagoon; and
Petrol interception prior to the outfall.
7.134
This methodology should be applied for both the substation and converter station
sites.
7.135
For the Laydown Area, the runoff would be contained via proposed bunded areas
(treatment level 1) prior to pumping. The pumped water will be passed through a
containment basin (treatment level 2) located within the substation site and then
through a petrol interceptor (treatment level 3) prior to discharge into the river to the
south. As the flow from this site is to be limited by pumping, no additional storage
should be required within the substation site.
7.136
Foul drainage will be required. The total staffing of the combined sites is very low.
Flows are to be separated (substation, converter station and temporary workforce)
thus reducing the total flows at any location. No discharge to the river or
watercourses is to be made. A self-contained septic tank option for each site is to be
provided with the effluent contained and transported off site at appropriate intervals.
In the longer term, consideration will be given to linking these sources and providing
a (possibly pumped) discharge to Southern Water public sewers located to the east.
7.137
A further source of potentially contaminated waters will be the oily water associated
with the petrol interceptors and sumps within the main sites. Each will be a
contained structure and will require off-site removal to a suitably licensed disposal
facility (or ultimately to a suitable off-site foul sewer, subject to Southern Water
approval).
Flood Risk
7.138
Appropriate mitigation measures will be put in place during construction works in
accordance with legislative requirements and good site practice guidance to prevent
flooding during construction from the risks identified.
7.139
Measures will be put in place during construction to ensure that the runoff from site
is not increased. Temporary drainage systems may be required to ensure that this
is met. The temporary drainage systems and systems of work will also take account
of the potential for overland flow from outside of the site to cause flooding on site.
7.140
Measures will be implemented during construction to prevent debris and other
material entering temporary or permanent drainage systems or watercourses. This
142
can be achieved through provision of temporary drainage, construction stage SuDS,
and appropriate site management.
7.141
During the construction phase, if groundwater levels are high, appropriate
techniques will be utilised to mitigate the risk, such as dewatering and ground
freezing. If groundwater dewatering is required, it is likely pumps will be used to
abstract the water from the excavations, and it is likely that the pumped water will be
discharged into the River Stour. Consent will be sought from the EA for any
temporary discharge to the watercourse.
7.142
The proposed construction works will take account of the location of existing water
mains and drains to ensure that construction does not impact upon these assets.
Any necessary works to divert or make use of these assets will be agreed in full with
the appropriate authority at the earliest opportunity and carried out in accordance
with their requirements.
7.143
The FRA undertaken for the site (Appendix 7.1) has outlined a number of mitigation
measures that could be adopted for this site.
7.144
The Construction management plans will include a Construction Environmental
Management Plan (CEMP) and within this will be described the main construction
compound locations and storage areas. Flood risk is to be part of the consideration
in determining the locations of these elements of the works.
7.145
A Flood Plan will be provided for both the construction and maintenance staff as
recommended in the FRA. A Flood Plan will detail appropriate actions in the event of
a flood and will include suitable evacuation procedures, safe egress route and a
plan showing the location of assembly points. The assembly point in this case,
should be outside the floodplain, which should be located toward the west with a
muster point located within the former power station site (a low flood risk area).
7.146
An important recommendation of the CIRIA C688 document ‘Flood Resilience and
Resistance for Critical Infrastructure’ is the setting of resilience/resistance standards
for key infrastructure based on its asset category (importance to the UK) as defined
by the Cabinet Office.
7.147
C688 suggests that for a CAT 5 asset such as the proposed substation site, the
target performance criteria is that the site should remain unaffected by all flood
events up to and exceeding the 1 in 1,000 year event. A CAT 5 site should therefore
remain in operation and be unaffected during these severe flood events. The
guidance suggests that, when considering the flood profile in this area, the vital
operating equipment should be raised above the prediction of the long-term flood
level. The appropriate design flood level is 3.337m AOD which is the highest of the
River Stour 1 in 1,000 year plus climate change levels as indicated in Table 7.13
above. This is approximately 100mm above current ground levels to the north of the
substation site increasing to around 500mm at the southern end with a maximum of
890mm alongside the southwest corner of this site.
7.148
The converter station components would not fall under a CAT 5 asset but could
consider a lower resilience standard. A CAT 3 classification (assets, the loss of
which would affect hundreds of thousands of people) might be more suited. In this
case the suggested performance level would be that the site remain unaffected by
flooding up to the 1 in 200 year flood event with a restricted operational capability for
143
events up to the 1 in 1,000 year event and safe (but potentially not operational) for
events in excess of the 1 in 1,000 year event. Essential operational equipment
within the converter station site is to be protected during the more extreme events.
7.149
Due to inaccuracies in flood modelled data, it is normally a requirement to add a
‘freeboard’ allowance to the modelled flood levels. This freeboard would normally be
300-600mm above the flood level (normally required by the EA to be applied to the
0.5%AEP plus climate change tidal levels). As the 0.1%AEP plus climate change
flood level is above the required standard of protection for the EA, the application of
a freeboard on this level is likely to be discretionary. However, National Grid have an
‘Internal and Contract Specific Policy Statement (Transmission) Flood Mitigation
Policy (PS(T)095 – Issue 1 – January 2011)’. Notwithstanding the requirements and
recommendations of statutory authorities such as the EA, the requirements of this
policy state that for new sites the target resilience level for transmission
infrastructure shall be 1 in 1000 year flood resilience with a suitable allowance for
climate change. The policy also suggests the addition of a further 300mm freeboard
to resilience levels to allow for any errors in the data used. The EA for this project
have already confirmed that the model levels provided have a +/- 150mm tolerance.
Thus the recommended minimum design level for the critical infrastructure elements
for the substation site will be set at 3.637m AOD.
7.150
The predicted flood events that impact the substation and converter sites are those
in excess of the 1 in 200 plus climate change and the current predicted 1 in 1,000
year tidal flood events. As such the impact on the extent of flooding outside the site
area due to land raising will be negligible for most flood events. For the extreme
climate change events the extent of flooding in the areas would include both the
River Stour and Minster Stream and the displaced volume from the proposed land
raising would have a minimal impact of flood depths or off site areas.
7.151
It is not anticipated that further mitigation measures will be required as minor to
negligible effects are not considered to be significant in the current EIA regulations.
Groundwater
7.152
The main mitigation measure to prevent adverse impacts on groundwater during all
phases of development is to ensure good site practice and management. To prevent
pollution, a CEMP will be produced as described above.
Residual Impacts and Conclusion
7.153
Provided that the mitigation measures are implemented properly, it is not anticipated
that there will be significant residual effects to the water environment during the
construction and operation phases of this development. Table 7.21 details the
influence of the mitigation on the adverse impacts identified above. For clarity minor
impacts and below (not Significant in terms of EIA Regulations) are not shown.
144
Table 7.21: Residual Significance
Effects
Potential
Significance
Construction Effects
Surface Water
Construction
Moderate –
material stockpiles
Adverse
and operations
changing overland
flood flow pathways
Proposed Mitigation
Residual
Significance
Construction will be
carried out in accordance
to current guidance and
EA PPGs and the CEMP
as well as consider
storage locations within
the EMP
Construction will be
carried out in accordance
to current guidance and
EA PPGs and the CEMP
as well as consider early
establishment of surface
water storage facilities
within the EMP
Minor –
Adverse
Construction will be
carried out in accordance
to current guidance and
EA PPGs and the CEMP
Construction will be
carried out in accordance
to current guidance and
EA PPGs and the CEMP
as well as consider
storage locations within
the EMP
Minor –
Adverse
Construction will be
carried out in accordance
to current guidance and
EA PPGs and the CEMP
as well as include a Flood
Plan within the EMP and
awareness training for all
site staff.
Groundwater – No Significant Impacts
Minor –
Adverse
Increase in surface
water runoff from
impermeable
surfaces – Converter
and Substation sites
Water Quality
Risk of silt-laden
entering the local
drainage system
Moderate –
Adverse
Moderate –
Adverse
Risk of silt-laden
water or accidental
spillage of
construction
materials into nearby
water bodies –
BayPoint sports
complex pond
Flood Risk
Moderate –
Adverse
Construction works
within flood risk
areas and impact on
works and workers –
Laydown Area
Moderate –
Adverse
Operational Effects
Surface Water
145
Minor –
Adverse
Minor –
Adverse
Increase in surface
Minor –
Construction of
water runoff due to
Adverse to
attenuation facilities,
new impermeable
Moderate SuDS and drainage
surfaces –
Adverse
management to cater for
Substation and
increases and tide-locking
Converter Station
of outfalls
Sites
Flood Risk
Introduction of
Moderate –
Provision of minimum
substation and
Adverse
design platform level
converter station
(CAT 3) to
300mm above predicted
structures within
Major
tidal flood level – design
identified high risk
Adverse
level to be 3.637m AOD
flood zones –
(CAT 5)
climate change
effects
Groundwater – No Significant Impacts
Minor –
Adverse
Minor –
Adverse
Cumulative Impacts
7.154
Potential cumulative effects on hydrology and flood risk from the onshore elements
of the Nemo Link in combination with other components of the Nemo Link i.e. UK,
French and Belgian subsea cables and Belgian onshore infrastructure are described
in Chapter 16.
7.155
Potential cumulative effects of the Nemo Link UK onshore infrastructure in
combination with the connection required to facilitate the operation of the Nemo Link
are described in Chapter 17.
7.156
There is the potential for cumulative effects to arise during the construction and
operation phase of the proposed works due to the construction and operation of
other developments as detailed in Table 1.2.
7.157
Development of the converter station and substation sites will result in a minor
change in water flow, however, this will not increase the overall discharge rate from
the site as the surface water flow will likely be designed to infiltrate into the adjacent
ground immediately prior to reaching the local watercourses or attenuated in order
to improve discharge water quality, hence it is not anticipated that water quality in
the local watercourses and drains will be affected.
7.158
Neighbouring development works at the proposed Richborough Energy Park may
require changes to the drainage network in the area and cumulative effects may
occur if these are not regulated.
7.159
Current planning policy, government and EA guidance (PPS, NPS and EA PPGs)
would impose similar constraints on other developments in terms of attenuation,
flood protection levels and discharge quality that are applicable to this site. In
addition, there will be an increasing requirement to meet WFD quality standards and
the introduction in due course of the National SuDS Standards. Hence, in
hydrological terms, there would not be any significant cumulative effects. Any
overland flow will therefore be localised and should not have an effect to the
surrounding area.
146
7.160
In September 2012, during the preparation of this assessment, Thanet District
Council submitted a planning application (Ref. F/TH/12/0690) for the Pegwell Bay
Flood Defence Scheme. Details of the scheme are enclosed as part of the FRA in
Appendix 7.1. It should be noted that this application does not include its own FRA
but includes a number of Halcrow produced flood maps.
7.161
Also during the preparation of this assessment, details of the construction of new
flood defences and improvements to existing defences with associated works,
landscaping, creation of two flood relief areas and wetland habitat were submitted
by the EA in August 2012 to Dover District Council.
7.162
The two recently submitted flood defence schemes (Pegwell Bay Flood Defence
Scheme and Sandwich Town Tidal Defences) will assist in maintaining and
improving the current level of tidal flood protection within the area of the proposed
cable route, substation and converter station. These defence schemes do not have
any detrimental impact on the site proposals and the site proposals do not impact on
the defence schemes.
7.163
As development poses no significant effect in relation to flooding, drainage and
water quality (assuming mitigation measures discussed above are implemented
properly) to the surrounding area, no cumulative effects are considered likely to
occur as a result.
References

CIRIA ‘The SUDS Manual’ C697, Mar 2007.

CIRIA ‘Flood Resilience and Resistance for Critical Infrastructure’ C688, 2010

Communities and Local Government, ‘East of England Plan, The Revision to
the Regional Spatial Strategy for the East of England’, May 2008

Communities and Local Government ‘National Planning Policy Framework’
NPPF, Mar 2012.

Communities and Local Government ‘Technical Guidance to the National
Planning Policy Framework’, Mar 2012.

DEFRA ‘Interim Code of Practice for Sustainable Drainage Systems’ National
SUDS Working Group, July 2004.

Entec ‘Thanet District Strategic Flood Risk Assessment, Volume 1 – Thanet
SFRA Report’, April 2009

The Flood and Water Management Act 2010

The Pitt Review ‘Learning lessons from the 2007 flood – the independent review
by Sir Michael Pitt’, June 2008

The Thanet District Adopted Local Plan 2006
147

The Water Framework Directive 2000/60/EC, 2000

The Water Resources Act 1991
148
149
150
8.0
ECOLOGY
Introduction
8.1
This chapter provides an assessment of the potential ecological effects of the
Proposed Development (i.e. the onshore elements of the Nemo Link - see Chapter 2
– Project Description) during construction and operation. The assessment has been
undertaken by appropriately qualified and experienced ecologists from TEP based
on findings of a range of ecological surveys and information from identified sources.
Mitigation measures that will be adopted to minimise potential affects, and
opportunities to enhance biodiversity are described.
Legislation and Planning Policy Context
8.2
The provisions of the following Statutory Instruments and Acts of Parliament are
relevant to the assessment:




Wildlife and Countryside Act 1981 (as amended);
The Conservation of Habitats and Species Regulations 2010;
Countryside and Rights of Way (CRoW) Act 2000; and
Natural Environment and Rural Communities Act 2006.
National Planning Policy
8.3
The National Planning Policy Framework (NPPF) was published on 27 March 2012,
coming into immediate effect and replacing the majority of previous Planning Policy
Guidance Notes (PPGs) and planning Policy Statements (PPSs). The NPPF has
been considered in the preparation of the ecology assessment.
8.4
Chapter 11 of the NPPF states that ‘The planning system should contribute to and
enhance the natural and local environment by:



‘Protecting and enhancing valued landscapes, geological conservation interests
and soils;
Recognising the wider benefits of ecosystem services; and
Minimising impacts on biodiversity and providing net gains in biodiversity where
possible, contributing to the Government’s commitment to halt the overall
decline of biodiversity, including by establishing coherent ecological networks
that are more resilient to current and future pressures;’
Local Policy
8.5
The Proposed Development is predominantly within the administrative boundary of
Thanet District Council. However, a section of cable within the BayPoint sports
complex and the south eastern corner of the proposed converter station and
substation site are in the administrative boundary of Dover District Council.
151
8.6
Thanet District Council Local Plan 2006 ‘Saved Policies’ relevant to this assessment
include:




8.7
Policy CC1 - Development in the Countryside;
Policy CC2 - Landscape Character Areas;
Policy NC3 – Local Wildlife Sites; and
Policy SR20 - Undeveloped Beaches.
Relevant Dover District Council policies from Dover Core Strategy, 2010 include:




Policy CP7 - Green Infrastructure;
Policy DM15 - Protection of the Countryside;
Policy DM16 - Landscape Character; and
Policy DM25 - Open Space.
Biodiversity Action Plans (BAPs)
8.8
The signing of the Convention on Biological Diversity at the Rio Earth Summit in
1992 placed an obligation on the UK Government to produce a Biodiversity Action
Plan (the UK BAP). The UK BAP describes actions that need to be undertaken by
which the conservation status of a targeted list of habitats and species can be
maintained or enhanced.
8.9
The UK BAP objectives and targeted actions to protect, maintain and enhance listed
habitats and species are implemented at regional and local level by the Kent
Biodiversity Action Plan (LBAP).
Birds of Conservation Concern
8.10
Bird species that have undergone a population decline in the UK over the last 25
years are included on the Red and Amber Lists of Birds of Conservation Concern
(RSPB, 2009):


Red List species are globally threatened and have experienced a population
decline in Britain of greater than 50% in the last 25 years; and
Amber List species are internationally rare or have localised populations and
have experienced a population decline in Britain of 25% to 49% in the last 25
years.
Method
8.11
The assessment of potential effects has been carried out in accordance with the
Institute of Ecology and Environmental Management’s (IEEM) Guidelines for
Ecological Impact Assessment (2006). This chapter should be read in conjunction
with Appendices 8.1 to 8.8 (survey results).
152
Desk Study
8.12
Information on designated nature conservation sites, protected and otherwise
notable species within 2km of the application site boundary were obtained from the
following sources:








Multi-Agency Geographical Information for the Countryside
(http://www.MAGIC.gov.uk);
Nature on the Map website (http://www.natureonthemap.org.uk);
Kent Wildlife Trust (KWT);
Kent and Medway Biological Records Centre (KMBRC);
Kent Reptile and Amphibian Group (KRAG);
Kent Bat Group (KBG);
Kent Ornithological Society (KOS); and
Royal Society for the Protection of Birds (RSPB).
website
8.13
Information received from the above organisations is included in Appendix 8.1.
8.14
Comprehensive studies have also been undertaken for a number of recent major
schemes in the vicinity of the application boundary. Publicly available information
has been reviewed as part of this assessment.
This includes ecological
assessments undertaken in support of:



Thanet Offshore Wind Farm (2005);
East Kent Access Phase 2 (2004); and
Richborough Power Station Demolition (URS Scott Wilson, August 2011).
Field Survey
8.15
A range of field surveys have been undertaken along the proposed onshore
underground cables route and at the site of the proposed converter station and
substation to establish baseline conditions in respect of habitats and species.
Phase 1 Habitat Survey
8.16
A Phase 1 Habitat Survey was undertaken by TEP during August and September
2011 to map the habitat types present along the proposed onshore cable route to
low water in accordance with the Handbook for Phase 1 Habitat Survey (JNCC,
2007).
8.17
The Phase 1 Habitat Survey of the converter station and substation site was
undertaken during April 2012 following demolition of the cooling towers and chimney
associated with the former power station. Site clearance of the proposed converter
station and substation site continued since the survey was undertaken and repeat
site visits since the site clearance have confirmed the findings of the initial survey.
8.18
The Phase 1 Habitat Survey included an inspection of suitable areas for the
presence of badger setts and other field signs of badger, and an inspection of trees
for the potential to support roosting bats. All habitats were assessed for their
potential to support protected species and any evidence was recorded.
153
8.19
Detailed results from the Phase 1 Habitat Survey are in Appendix 8.2 and are
summarised later in this chapter.
National Vegetation Classification (NVC) Survey
8.20
A National Vegetation Classification (NVC) survey of saltmarsh area surrounding the
proposed cables route north of Pegwell Bay Country Park was undertaken during
August 2011. Quadrats were recorded using standard NVC methodology. The
NVC survey results are in Appendix 8.3.
Reptile Survey
8.21
A reptile survey was undertaken during late August and September 2011 to
determine the presence and distribution of reptiles along the proposed cable route.
Reptile surveys generally use ‘artificial cover objects’ such as old carpet tiles or tins
which are left on a site and subsequently inspected to identify reptiles beneath them.
The proposed cables route is well-used by members of the public and there would
be high risk of tampering with artificial cover objects; surveys were undertaken using
direct observation methods.
8.22
A reptile survey was not undertaken at the proposed converter station and
substation site due to the lack of suitable habitat. The proposed converter station
and substation site is dominated by hard standing. The small areas of vegetation
that are present consist of sparse and short modified grassland, which shows
evidence of disturbance from the demolition activities, and patches of ephemeral
vegetation. This area of the site therefore does not possess habitats that could offer
foraging or refuge opportunities for reptiles.
8.23
Full details of the Reptile Survey are in Appendix 8.4.
Water Vole Survey
8.24
A water vole survey of Unit 11 of Sandwich Bay to Hacklinge Marsh SSSI located to
the north of the former power station site was undertaken during early October
2011. The survey followed methods detailed in The Water Vole Survey Handbook
2nd Edition (Strachen and Moorhouse, 2006). The area contains a number of wet
ditches and is also bordered by Minster Stream to the north.
8.25
Ditches adjacent to the A256 Sandwich Road within Pegwell Bay Country Park and
ditches in Stonelees Nature Reserve were not included as they were dry at the time
of survey in 2011 and were also considered to have a low likelihood of supporting
water voles.
8.26
Further details of the water vole survey are in Appendix 8.5.
Winter Bird Survey
8.27
A winter bird survey was undertaken between November 2008 and May 2009 within
the saltmarsh and mudflat habitats of Pegwell Bay to determine the use of the area
by overwintering and migrating species of birds. Data obtained from Kent
Ornithological Society, has also provided a large amount of data regarding habitat
use by birds within the Pegwell Bay Area. Impacts on wintering birds will be avoided
154
through the timing of cable installation works outside of sensitive periods and repeat
surveys are therefore not necessary.
8.28
The winter bird survey entailed two surveyors mapping wader and wildfowl
distributions in Pegwell Bay on an hourly basis for a complete tide cycle, i.e. high to
low tide or low to high tide. A total of seven visits were completed for this survey.
Survey visits were undertaken once a month from November 2008 to March 2009.
An additional visit was undertaken in February 2009 to target the mid-winter period
when birds are most sensitive to disturbance. Survey days were chosen to ensure
that three surveys were undertaken as the tide was going out (high to low tide) and
three surveys were undertaken as the tide was coming in (low to high tide). Impacts
on wintering birds will be avoided by undertaking cable installation works outside of
sensitive periods so repeat surveys are not necessary. Consultation with Natural
England (NE) and Kent Wildlife Trust (KWT) will be used to identify the most
appropriate timing of the cable installation works. This is consistent with the
approach used for the installation of the Thanet Offshore Wind Farm cables across
Pegwell Bay.
8.29
The winter bird survey report is in Appendix 8.6.
Breeding Bird Survey and Nesting Redshank Survey
8.30
A breeding bird survey was undertaken across the saltmarsh areas of Pegwell Bay
and also in Pegwell Bay Country Park and Stonelees Nature Reserve. The survey
was undertaken on two separate visits on 8th May and 22nd June 2009 to
determine the importance of the area for breeding birds. No breeding bird survey
was undertaken within the site of the proposed converter station and substation due
to the lack of suitable nesting habitats and highly disturbed nature of the site.
8.31
The breeding bird survey entailed two surveyors walking a series of line transects
through peripheral habitats adjacent to the saltmarsh in the north half of the Bay;
suitable bird breeding habitats, including areas of plantation, scrub and tall areas of
herbs in Pegwell Bay Country Park; and an area to the southwest extent of
Sandwich and Pegwell Bay Kent Wildlife Trust Reserve, known locally as Stonelees
Nature Reserve.
8.32
As part of the breeding bird assessment, a separate redshank survey was
undertaken. This entailed two surveyors walking transects within saltmarsh habitats
to determine the presence of nesting redshank.
8.33
Full details of the breeding bird survey and nesting redshank survey are in Appendix
8.7.
Sediment and Invertebrate Survey
8.34
A survey of the sediment and invertebrate communities of the intertidal mudflat
areas of Pegwell Bay was undertaken during August 2009 to determine the
distribution and abundance of prey items that may be used by waders and wildfowl
that affect their distribution within the intertidal area.
8.35
In total four transects were taken at right angles to the shoreline associated with
Cliffs End and the A256. Samples were taken at four points along each transect in
the upper, mid-upper, mid-lower and lower shore.
155
8.36
Details of the sediment and invertebrate survey are in Appendix 8.8.
Assessment of Significance
Determination of Ecological Value
8.37
The habitats and species recorded have been valued in accordance with the criteria
presented in Table 8.1. The Institute of Ecology and Environmental Management
(IEEM) Guidelines for the assessment of ecological impacts aim to establish a
standard in the evaluation of the effects of potential development on wildlife
receptors. Deviating away from the traditional significance matrix, IEEM guidelines
require ecological receptors to be valued (or to have the potential to be valued)
according to a geographical scale.
Table 8.1: Criteria for Evaluation of Ecological Features
Level of
Value
International
National
Regional/
County
Local
Site
Negligible
Ecological Features
Internationally designated sites or candidate sites (e.g. Special
Areas for Conservation (SACs), Special Protection Areas (SPAs),
Ramsar sites);
Nationally designated sites (e.g. Sites of Special Scientific Interest
(SSSIs), National Nature Reserves (NNRs));
Local Nature Reserves (LNRs); Local Wildlife Sites (formerly Sites
of Importance for Nature Conservation), ancient woodlands;
habitats or species populations of importance for Kent
Significant ecological features such as old hedgerows, woodlands,
ponds of importance for the Kent Wildlife Trust reserves;
Features with ecological value of significance within the application
site only
Areas of built development, active mineral extraction, or intensive
agricultural land.
Determination of Significant Effects
8.38
An ecological impact is determined as being significant if it affects the integrity of a
site or the favourable conservation status of a valued feature. Significance is
considered in relation to the value of the receptor. The significance can be positive,
if the effect supports or promotes favourable conservation status, or negative, if it
contradicts or decreases the ability of the feature to maintain its conservation status.
A significant impact, in ecological terms, is defined in the IEEM guidelines as:
’an impact (adverse or positive) on the integrity of a defined site or ecosystem(s)
and/or the conservation status of habitats or species within a given geographical
area, including cumulative impacts.’
8.39
The Government Circular ODPM 2005/06 defines site integrity as:
156
’the coherence of its ecological structure and function, across its whole area, that
enables it to sustain the habitat, complex of habitats and/or the levels of populations
of species for which it was classified’.
8.40
The conservation status of a species is defined in Article 1(i) of the Habitats
Directive as favourable when:
’population dynamics data on the species concerned indicate that it is maintaining
itself on a long term basis as a viable component of its natural habitats; and the
natural range of the species is neither being reduced nor is likely to be reduced in
the foreseeable future; and there is, and will probably continue to be, a sufficiently
large habitat to maintain its population on a long-term basis’.
8.41
The IEEM guidelines also highlight the importance of considering the likelihood that
a change/activity will occur as predicted, and the degree of confidence in that impact
assessment on ecological structure and function. A four point scale, used to
standardise the degree of certainty in a prediction, is stated as follows:
Certain/Near Certain: probability estimated at 95% chance or higher;
Probable: probability estimated at or above 50% but below 95%;
Unlikely: probability estimated at or above 5% but below 50%; and
Extremely Unlikely: probability estimated at less than 5%.
8.42
When describing changes and activities and impacts on ecosystem structure and
function, the following parameters are characterised:
Positive or Negative: is the impact positive or negative?
Magnitude: refers to the size or “amount” of the impact;
Extent: the area over which the impact occurs;
Duration: the time for which the impact is expected to last prior to recovery or
replacement of the resource or feature;
Reversibility: an irreversible (permanent) impact is one from which recovery is not
possible within a reasonable timescale: a reversible (temporary) impact is one from
which spontaneous recovery is possible or for which effective mitigation is possible;
and
Timing/Frequency: some changes may only cause an impact if they happen to
coincide with critical life-stages or seasons (e.g. bird nesting season).
8.43
Wherever possible, conservation status has been determined by reference to
literature, including the UK BAP and LBAP objectives and targets, and by
professional judgement in the absence of clear guidance. The geographic scale at
which a significant effect matters is indicated by the feature’s value.
8.44
Only those habitats and species of at least local value have been considered in this
assessment as significant effects on ecological features of lower value are not
considered material to the decision to proceed with the Proposed Development.
Habitat Regulations Assessment
8.45
The potential impacts of the proposals on the specific features of European
protected areas within the proposed cable route have been assessed within a
document entitled ‘Information for Habitat Regulations Assessment’ (HRA). This
assessment is provided in Appendix 8.9 and is referred to when assessing the
157
impacts of the proposals. A HRA Signposting Document has also been included in
Appendix 8.10 detailing the sections of the Ecology Chapter relevant to HRA.
Existing Environment
Designated Nature Conservation Sites
8.46
Table 8.2 summarises the designated areas within 2km of the application boundary
and these are shown on Figures 8.1 and 8.2. Some of the designations overlap with
one another such that some areas that fall within the application boundary are
covered by multiple designations. Further details of each designated site are in
Appendix 8.1.
Table 8.2: Conservation Designations
Site
Designation
Name
Ramsar
SPA
SAC
Description
Thanet
Coast
and
Sandwich
Bay
A coastal site, consisting of a long
stretch of rocky shore, adjoining areas
of estuary, sand dune, maritime
grassland, saltmarsh and grazing
marsh. The wetland habitats support
15 British Red Data Book
invertebrates, as well as a large
number of nationally scarce species.
The site attracts internationally
important numbers of turnstone
Arenaria interpres and nationally
important numbers of nationally
important wintering populations of four
wader species: ringed plover, golden
plover, grey plover and sanderling, as
well as Lapland bunting. The site is
used by large numbers of migratory
birds.
Thanet
Internationally important populations of
Coast
breeding little tern (Sterna albifrons)
and
and overwintering European golden
Sandwich plover (Pluvialis apricaria) and
Bay
turnstone (Arenaria interpres).
Sandwich Sandwich Bay supports a dune system
Bay
consisting of four Annex I habitats.
Other general site characteristic
habitats include tidal rivers, estuaries,
mud flats, sand flats, lagoons,
saltmarshes, salt pastures, salt
steppes, coastal sand dunes, sand
beaches, machair, inland waterbodies,
bogs, marshes, water-fringed
158
Development
Components in
Designation
Onshore cables
including TJP.
Subsea and
onshore
underground
cables including
TJP.
Subsea and
onshore
underground
cables including
TJP.
Designation
Site
Name
Description
Development
Components in
Designation
vegetation, fens, humid grassland,
mesophile grassland, improved
grassland and coniferous woodland.
SAC
SSSI
NNR
Thanet
Coast
Thanet Coast represents the UKs
longest stretch of coastal chalk, and
contains 4 Annex I habitats, including
reefs, submerged/partially submerged
sea caves, submerged sandbanks and
mudflats/sand flats exposed at low tide
which support specialised algal
communities.
Sandwich This site contains the most important
Bay to
sand dune system and sandy coastal
Hacklinge grassland in South East England and
Marshes also includes a wide range of other
habitats such as mudflats, saltmarsh,
chalk cliffs, freshwater grazing marsh,
scrub and woodland. Associated with
the various constituent habitats of the
site are outstanding assemblages of
both terrestrial and marine plants with
over 30 nationally rare and nationally
scarce species, having been recorded.
Invertebrates are also of interest with
recent records including 19 nationally
rare, and 149 nationally scarce
species. These areas provide an
important landfall for migrating birds
and also support large wintering
populations of waders, some of which
regularly reach levels of national
importance.
Sandwich The NNR is a mix of natural, semi
and
natural; and artificial habitats. Natural
Pegwell habitats include; eroding chalk cliffs
Bay
and wave cut platforms to the north of
Pegwell Bay, intertidal mudflats
developing beaches, sand dunes and
saltmarsh. Semi-natural habitats
include; ancient dune pasture and
coastal scrubland while the re-created
grassland of the Pegwell Bay Country
Park, along with ponds, dykes and
ditches are artificial habitats.
159
None (150m
north of subsea
cables route)
Subsea and
onshore
underground
cables including
TJP.
Subsea and
onshore
underground
cables including
TJP.
8.47
An assessment of the effects of installation of the subsea cable has been included
as part of the Marine cable installation assessment which forms part of the Marine
Application. However, the assessment of the onshore cable also includes the
section of subsea cable that passes through the intertidal area from the low water
mark.
8.48
The subsea cable route passes through approximately 1,900m of the designated
areas including Thanet Coast and Sandwich Bay SPA and Ramsar, Sandwich Bay
and SAC, Sandwich Bay to Hacklinge Marshes SSSI and Sandwich and Pegwell
Bay NNR. The subsea cable does not however pass through the Thanet Coast
SAC the boundary of which is approximately 150m north of the proposed subsea
cable route. The habitats crossed by the subsea cables route are primarily tidal
mudflats and approximately 180m of saltmarsh.
8.49
Sandwich and Pegwell Bay NNR also incorporates Pegwell Bay Country Park and
Sandwich and Pegwell Bay Kent KWT Reserve. The proposed onshore cables
route passes through Pegwell Bay Country Park which consists of a mosaic of rough
grassland, plantation and scrub. Sandwich and Pegwell Bay Reserve, managed by
KWT, incorporates a swathe of habitats around the Country Park. A small part of
the southwest corner of the Sandwich Bay and Pegwell Bay Reserve is owned by
KWT. This part of the larger reserve is known locally as Stonelees Nature Reserve.
Local Wildlife Sites
8.50
Local Wildlife Sites (LWS) are county designations and have no legal protection.
However, they are material considerations within the planning process.
8.51
There are two Local Wildlife Sites (LWS) within 2km of the proposed converter
station and substation site:


Ash Level and South Richborough Pasture; and
Woods and Grassland, Minster Marshes.
8.52
Ash Level and South Richborough Pasture LWS is approximately 15m southwest of
the proposed converter station and substation site boundary. The LWS consists of
a large complex of grazing marsh including botanically species rich ditches which
support invertebrates and wetland birds. Several landowners are now in Natural
England’s Higher Level Stewardship schemes with options for grazing marsh
restoration such as scrape creation to improve wildlife interest of the site.
8.53
The Woods and Grassland, Minster Marshes LWS consists of a mosaic of
grassland, scrubs ponds and woodland habitats, important for supporting a range of
species. This LWS is approximately 500m west of the proposed converter station
and substation site.
8.54
A single Roadside Nature Reserve (RNR) is also present approximately 25m west of
the proposed onshore underground cables route. The RNR is located along a 450m
stretch of the A256 Sandwich Road and comprises the road verge, which is
designated for its botanical interest. RNRs do not receive legal protection but are a
material consideration within the planning process.
160
Biodiversity Action Plans
8.55
The following UK BAP Priority Habitats are listed as present on the Nature on the
Map website within and immediately adjacent to parts of the proposed onshore
underground cables route, converter station and substation.






Fen;
Reedbeds;
Lowland Meadows;
Woodland;
Coastal and Floodplain Grazing Marsh; and
Mudflats.
Habitats
8.56
The habitats present within the application site are illustrated in Figure 8.3. Habitat
descriptions and species lists are provided at Appendix 8.2. The description of
habitats below refers to the different parts of the cables route from low water to the
converter station and substation.
Low Water to TJP
Mudflats
8.57
The area between low water and the proposed TJP dominated by intertidal mudflat
habitat which borders the saltmarsh habitats closer to the shore.
Saltmarsh
8.58
The subsea cables route approaching the TJP and the pit are in an area dominated
by saltmarsh habitat. The saltmarsh communities support typical saltmarsh species
of the local area such as sea purslane (Atriplex portucaloides), common cord-grass
(Spartina anglica), sea aster (Aster tripolium) and glasswort (Salicornia sp). The
NVC survey of the saltmarsh habitats identified five saltmarsh communities within
the subsea cable route and TJP. Details of the NVC saltmarsh habitats are
provided in Appendix 8.3 and are illustrated in Figure 8.4.
8.59
North of the subsea cables route there is stock proof fencing which defines the
working area of the Thanet Offshore Wind Farm (TOWF) cable, which also runs
through saltmarsh habitat. The fencing of the TOWF working area following
completed installation of the cable has resulted in positive recolonisation by
saltmarsh species. Monitoring of the progress of the saltmarsh recolonisation is still
underway.
TJP to Pegwell Bay Country Park (adjacent A256 and Cycle Path)
Saltmarsh
8.60
There is saltmarsh on the lower partly intertidal land west of the TJP. A further small
area of saltmarsh on the landward side of the proposed TJP gives way to modified
neutral grassland close to the A256 and cycle path. The cycle path is embanked
from the level of the saltmarsh and the land falls from this level to the saltmarsh on
161
the coastal side. Degradation of saltmarsh habitats at the foot of the cycle path
slope has occurred due to members of the public using desire lines across the
saltmarsh vegetation to avoid walking on the cycle path.
8.61
The NVC survey of the saltmarsh habitats identified three saltmarsh communities
within the onshore cable route. Details of the NVC saltmarsh habitats are provided
in Appendix 8.3 and are illustrated in Figure 8.4.
Modified Neutral Grassland
8.62
There is modified neutral grassland adjacent to the A256 Sandwich road and cycle
path. Species present in the diverse sward are typical of verge habitats in the area,
dominated by false oat-grass (Arrhenatherum eliatus), red fescue (Festuca rubra)
with abundant buck’s horn plantain (Plantago coronopus), fennel (Foeniculum
vulgare), and Alexanders (Smyrnium olusatrum). There are also some saltmarsh
species that have established at the foot of the slope close to the saltmarsh,
including sea sandwort (Honckenya peploides). Desire lines have been created
parallel to the cycle path where members of the public attempt to avoid using the
cycle path. This has resulted in degradation of the vegetation due to erosion and
compaction.
Water Bodies
8.63
There is a large pool in the saltmarsh habitat on lower ground below this section of
the onshore underground cables route. The pool is tidal and is filled during high
tides that inundate the surrounding saltmarsh. There is no aquatic vegetation within
the pool but saltmarsh vegetation surrounds the pool. The onshore cables are
routed to the northwest of this water body.
Hardstanding
8.64
The cycle path comprises a linear length of hardstanding.
Pegwell Bay Country Park
Semi-Improved Grassland
8.65
Expanses of semi-improved grassland with poor sward diversity occur across
Pegwell Bay Country Park. This grassland was created following capping of the
landfill site, which was the previous land use prior to conversion into a Country Park.
Areas of grassland to the east of the cycle path are periodically grazed by cattle as
part of the management of the Country Park habitats undertaken by KWT.
8.66
The cycle path runs through the grassland in a northeast-southwest direction. The
sward west of the cycle path is dominated by false oat-grass with red fescue,
cock’s-foot (Dactylus glomerata) and a range of locally common species such as
Alexanders, wild carrot (Daucus carota) and yarrow (Achillea millefolium).
Management in this area consists of regular mowing of a 2m wide strip along the
western edge of the cycle path which produces a slightly wider corridor for users of
the cycle path.
162
Plantation Woodland
8.67
There are extensive areas of plantation woodland in Pegwell Bay Country Park.
The woodland provides landscaping around the car park areas within the northern
section of the Country Park, and along the majority of the western boundary, the
woodland acts as screening from the busy Sandwich Road. The most common
species are sycamore (Acer pseudoplatanus), holme oak (Quercus ilex), aspen
(Populus tremula) and field maple (Acer campestre).
Amenity Grassland
8.68
There is an area of amenity grass in the north of the Country Park associated with
the car parking and picnic areas.
Scattered Trees
8.69
Scattered trees are present along proposed onshore cable route. They are mainly
concentrated within semi-improved grassland in the northern section of the Country
Park.
Scattered/Dense Scrub
8.70
There is an extensive area of bramble scrub present within the Country Park, west
of the cycle path. Scattered scrub, dominated by hawthorn, is also present in
grassland areas.
Tall Ruderal Herb
8.71
Tall ruderal herbs in the Country Park tend to be associated with fence lines, ditches
and plantation edges. These areas are generally dominated by species such as
Alexanders (Smyrnium olusatrum), fennel (Foeniculum vulgare), nettle (Urtica
dioica), bindweed (Convolvulus arvensis) and teasel (Dipsacus fullonum).
Ditches
8.72
Ditches are present within the western section of the Country Park adjacent to the
A256 Sandwich Road. The ditches were dry for the majority of 2011, but due to the
wetter conditions experienced between January and July 2012, they have been
observed to hold water. Vegetation is generally absent but dense stands of
common reed (Phragmites australis) and reedmace (Typha latifolia) are present in
some sections of the ditch within the Country Park.
Hardstanding
8.73
The cycle path, access road and car parking areas are areas of hardstanding in the
Country Park.
Stonelees Nature Reserve
Unimproved Coastal Dune Pasture
8.74
The unimproved grassland along the proposed onshore cable route within Stonelees
Nature Reserve route is generally rough with a high proportion of tall herbs and
163
scattered scrub. Southern marsh orchid is also widely present within this area of
grassland.
Tall Ruderal Herb
8.75
More extensive areas of tall ruderal herbs are located within ungrazed areas of
Stonelees Nature Reserve.
Water Bodies
8.76
A number of ephemeral ponds have been created within Stonelees Nature Reserve
by KWT to reintroduce natterjack toads. The ponds have been designed to be
shallow and to hold water for only part of the year making them suitable for the
species. A further ephemeral pond is present along the ditch line in the west of the
Stonelees Nature Reserve. The pond is dominated by reedmace and is generally
dry but holds water periodically.
Scattered/Dense Scrub
8.77
Scattered scrub, comprising mainly hawthorn, is also present in Stonelees Nature
Reserve.
Ditches
8.78
There are ditches adjacent to the A256 Sandwich Road and similarly for those
described in the Country Park, these were dry for the majority of 2011, but due to
the wetter conditions experienced between January and July 2012, they have been
observed to hold water. Vegetation is generally absent but dense stands of
common reed (Phragmites australis) and reedmace (Typha latifolia) are present in
some small sections of the ditch within the Stonelees Nature Reserve.
Semi-Natural Broad-Leaved Woodland
8.79
An area of semi-natural broad-leaved woodland is present within the southern
section of Stonelees Nature Reserve. The woodland consists of mature sycamore
and ash trees with an understorey of scrub species including hawthorn. KWT have
undertaken some clearance of this woodland habitat during winter 2011/2012.
Hardstanding
8.80
The hardstanding cycle path runs through Stonelees Nature Reserve continuing
along the new bypass to the south.
8.81
The cables route crosses the A256 road which has recently been widened to form a
dual carriageway.
BayPoint Sports Complex to Converter Station
8.82
This part of the onshore underground cables route passes from the BayPoint sports
complex to the converter station site. The cables would be installed by HDD which
will involve a pit and working area on the sports complex and another pit and
working area at the converter station site with no disturbance to the ground between
these points. The ground above the cables route comprises the A256, arable land,
164
Unit 11 of the Sandwich to Hacklinge SSSI, Minster Stream and part of the former
Richborough Power Station site.
Scattered Trees
8.83
This habitat occurs within the BayPoint sports complex where pollarded poplars are
present along the north and west boundaries.
Amenity Grassland
8.84
The BayPoint sports complex is dominated by maintained sports fields which are
regularly mown to maintain a short sward.
Hardstanding
8.85
The A256 is dual carriageway and has a tarmacadam surface.
Bare Ground and Ephemeral Species
8.86
Areas of bare ground with ephemeral species are present alongside the widened
section of the A256 associated with the recent road improvement works. These
areas have been seeded and are developing into grass verges.
Arable Grassland
8.87
Arable grassland extends west of the newly widened section of the A256 and south
of the new bypass. The area has been cleared for the development of an anaerobic
digester scheme. This development is separate to the scheme described in this
document.
Unimproved Neutral Grassland
8.88
Within the SSSI, unimproved neutral grassland along the proposed cable route is
generally dominated by dense scrub.
8.89
Areas of semi-improved neutral grassland are also present within Unit 11 of
Sandwich Bay to Hacklinge Marshes SSSI, to the north of the proposed converter
station and substation site.
Water Bodies
8.90
An area dominated by dense reedmace is located in the southeast corner of Unit 11
of the Sandwich Bay to Hacklinge Marshes SSSI. Ordnance Survey maps indicate
that this has historically been a waterbody but it currently does not hold any water.
The base of the waterbody is now filled with reedmace roots and is becoming
colonised by other vegetation.
Scattered/Dense Scrub
8.91
There is an area of dense hawthorn (Crataegus monogyna), blackthorn (Sambucus
nigra) and willow (Salix sp.) scrub in Unit 11 of the Hacklinge Marshes SSSI.
165
Ditches
8.92
There are ditches within Unit 11 of the Sandwich Bay to Hacklinge Marshes SSSI
north of the proposed converter station and substation site. A ditch in the north of
the SSSI holds water and is shaded by dense scrub. Aquatic vegetation occurs in
less shaded parts of the ditch.
Watercourse
8.93
The onshore underground cables route crosses Minster Stream along the north
boundary of Unit 11 of the Sandwich Bay to Hacklinge Marshes SSSI. The south
bank is shaded by overhanging scrub and the north bank is managed though grass
cutting. Some aquatic vegetation is present in the stream.
Converter Station and Substation Site
Modified Neutral Grassland
8.94
Small areas of modified neutral grassland are present around the bases of the
demolished cooling towers within the former power station site. The sward is short
and has been subject to disturbance from the demolition activities.
Scattered Trees
8.95
A small area of scattered trees is located in the southeast corner of the site, north of
the existing site entrance from the A256 Ramsgate Road. There are no other trees
within the boundaries of the proposed converter station and substation site but there
are several around the perimeter of the site.
Bare Ground and Ephemeral Species
8.96
Following demolition works at the former power station site, there are areas of bare
ground within the proposed converter station and substation site which are being
colonised by ephemeral species.
Standing Water
8.97
Since the demolition and clearance of the cooling towers within the site, the bases of
the cooling towers have filled with water creating isolated basins containing water
within the site.
Flora
8.98
There are records of five Schedule 8 (WCA) plant species within 2km of the
Proposed Development. These species are:





Bluebell (Hyacynthpides non-scripta);
Lizard Orchid (Himantoglossum hirsinum);
Deptford Pink (Dianthus armeria);
Martin’s Ramping fumitory (Fumaria reuteri); and
Bedstraw Broomrape (Orobanche caryophillacae).
166
8.99
The majority of records for lizard orchid are from Pegwell Bay Country Park, with a
single record of the species within each of the Stonelees Nature Reserve and the
site of the former power station. Single records for Martin’s ramping fumitory and
bedstraw broomrape originate within the Country Park.
8.100
None of the above species were identified along the proposed cable route or within
the footprint of the converter station and substation site. It is possible that these
species may be present in isolated areas or may appear within the working areas
prior to the commencement of works within suitable habitats such as those present
within the Country Park and Stonelees Nature Reserve.
Amphibians
8.101
A single record of great crested newt approximately 2km northeast of the proposed
onshore underground cable route within Pegwell Bay was received from KRAG.
The record originates from a residential garden in the urban area of Pegwell. No
other records of great crested newts were received within 2km of the search area.
8.102
Records of smooth newt approximately 2km northeast of the proposed cable route
were also received from KRAG originating from the same location as the great
crested newt record. A single record of common frog approximately 60m west of the
proposed cable route was also received.
8.103
Rough grassland, scrub and plantation/woodland habitats within the proposed
onshore cable route within Pegwell Bay, Pegwell Bay Country Park and Stonelees
Nature Reserve provide suitable terrestrial habitat for use by amphibians. The
proposed converter station and substation site consists of hardstanding, short
modified grassland and ephemeral vegetation, and does not provide suitable
terrestrial habitats for amphibians. Although standing water is now present within
the converter and sub-station site, following demolition of the cooling towers, the
standing water is isolated due to its location within the site, surrounded by
unsuitable terrestrial habitats.
8.104
Surveys undertaken in support of the Thanet Offshore Wind Farm (TOWF) cable
installation (2005), East Kent Access Road Phase 2 (2004) and Richborough Power
Station Demolition (2011) have not identified great crested newts in any ponds
within 500m of the proposed converter station and substation site and cable route.
It is therefore concluded that it is unlikely that there are great crested newts within
the Proposed Development areas of the converter station and substation site or
cable route.
8.105
The TOWF surveys identified the presence of smooth newt, common frog, and
common toad in ponds within 250m of the converter station and substation site. The
presence of these species is therefore possible.
8.106
No records of natterjack toads within 2km of the cables route and converter station
and substation site have been identified other than that associated with
reintroduction. KWT has been undertaking a reintroduction scheme of natterjack
toads into Stonelees Nature Reserve since 2008, completing annual surveys of
ephemeral pools to determine the success of the reintroduction. During surveys
undertaken in 2011 a single natterjack toad was identified. However, 2011 was a
very dry year and the ponds dried out rapidly. Toadlets resulting from the
introductions were identified in 2009 and 2010.
167
8.107
The locations of the ephemeral pools used for the reintroductions are not currently
public knowledge and have not been identified in this assessment.
8.108
Terrestrial habitat suitable for natterjack toads is present within the proposed cable
route.
Reptiles
8.109
Records of grass snake, common lizard and slow worm within 2km of the application
boundary have been received from both KMBRC and KRAG. Reptiles are known to
be widespread within the area and can therefore be expected to be present in any
suitable areas of habitat, which includes mosaics of rough grassland, scrub and
woodland or plantation edges.
8.110
A reptile survey undertaken during September 2011 identified common lizard in
suitable habitats along the entire cable route between the landfall to the southern
boundary of Stonelees Nature Reserve. A common lizard was also identified on the
north bank of Minster Stream during water vole surveys undertaken in October
2011. The results of the 2011 reptile survey are provided in Appendix 8.4 and
illustrated in Figure 8.5.
8.111
The maximum number of common lizards counted during any single survey visit was
14 (2nd September 2011, indicating that the survey area has a good population of
common lizards.
8.112
Virtually all parts of the cable route and adjacent habitats are suitable for reptiles.
The exceptions include amenity grassland (in the Country Park and the BayPoint
sports complex), and large areas of hardstanding (car parking areas in the north of
the Country Park).
8.113
There are no areas of suitable reptile habitat within the proposed converter station
and substation site. The site has been cleared and consists of large expanses of
hard standing with short mown modified grassland, which lack foraging shelter and
refuge opportunities. Habitats in the western part of the former power station site,
outside of the application boundary, remain undisturbed by demolition activities and
have high potential to support reptiles.
Bats
8.114
No records of confirmed roosts were received within 2km of the proposed converter
station and substation site or the proposed cable route. Only 7 records of bats in
flight were identified by Kent Bat Group (KBG) within 2km of the proposed cable and
converter station and substation site. These records are all north and west of the
converter station and substation site and were associated with Ebbsfleet Farm,
Cliff’s End and Cottington Road.
8.115
There were bats previously recorded in former office buildings at the power station
site prior to their demolition.
8.116
The records received from KBG indicate nine species of bat are present in the
locality:
168









Serotine bat (Eptescus serotinus);
Daubentons bat (Myotis daubentonis);
Whiskered bat (Myotis mystasinus);
Natterer’s bat (Myotis nattereri);
Noctule bat (Nyctalus noctula);
Nathusius’ pipistrelle (Pipistrellus nathusii);
Common pipistrelle (Pipistrellus pipistrellus);
Soprano pipistrelle (Pipistrellus pygmaeus); and
Brown long-eared bat (Plecotis auritus).
8.117
The assessment for suitable bat roost habitat was undertaken as part of the
Extended Phase 1 Habitat Survey and is reported in Appendix 8.2.
8.118
No trees suitable for supporting bat roosts were identified during the extended
Phase 1 surveys. The majority of trees are of insufficient size and do not have
suitable features such as rot holes, cracked limbs and lifted bark that bats may use
as roosting habitat. Exceptions to these include a group of mature trees in the
woodland in the southwest of Stonelees Nature Reserve where mature sycamore
and ash trees are present. Despite their more mature character, no features
suitable to support bats were identified on these trees.
These trees are
approximately 10m from the onshore underground cables route.
8.119
No trees are present in the proposed converter station and substation site. There
are trees in other areas of the former power station site, outside the application
boundary on the north and east boundaries and to the southwest. The trees to the
southwest have some potential to support roosting bats as they possess
woodpecker holes. These holes are used by ring necked parakeets as nesting sites
and are currently unsuitable for use by roosting bats.
8.120
A bat barn was created west of the former power station site to mitigate the loss of a
roost in the former office buildings which were demolished. The bat barn is
approximately 600m west of the proposed converter station and substation site and
will not be affected by the proposals.
8.121
Habitats along the proposed cable route provide commuting and foraging
opportunities for bats. Plantation edges, scattered scrub and grassland occur
across the Country Park, Stonelees Nature Reserve and also within Unit 11 of the
Sandwich Bay to Hacklinge Marshes SSSI.
8.122
There is no bat foraging or commuting habitat within the converter station and
substation site. The area is dominated by extensive hardstanding areas and lacks
suitable vegetation structure. The River Stour (southwest of the former power
station site), tree lines on the east and north boundary of the former power station
site, and Unit 11 of Sandwich Bay to Hacklinge Marshes SSSI are of high value for
foraging and commuting bats.
Badgers
8.123
One record of badger was obtained within 2km of the proposed cable route,
converter station and substation development, but this dates from 1968 and is not
considered relevant to this assessment.
169
8.124
No evidence of badger was identified within or adjacent to the Proposed
Development area during the site survey. It is concluded that badgers are most
likely absent from the development area and will not be affected by the proposals.
Water Voles
8.125
There are 30 records of water voles within 2km of the Proposed Development
indicating a good local population of the species.
8.126
During surveys in October 2011, water voles were confirmed to use ditch habitats
within Unit 11 of Sandwich Bay to Hacklinge Marshes SSSI which are approximately
40m from the converter station and substation site. Water voles were not confirmed
to be present within Minster Stream, which borders the SSSI to the north, but it is
likely that water voles are present due to the proximity of evidence within the SSSI
and surrounding populations identified through desktop searches. The results of the
water vole survey are provided in Appendix 8.5 and illustrated in Figure 8.6.
8.127
Surveys completed in 2005 for the TOWF cables installation identified water voles
within ditches running parallel with Sandwich Road in the Country Park and
Stonelees Nature Reserve. During 2011 these ditches were dry for much of the
year and are considered to provide sub-optimal water vole habitat. Given the
historic presence of water voles within these ditches, for the purposes of this
assessment, water voles are assumed to be present.
8.128
Surveys undertaken during 2009 and 2010 in support of the demolition of structures
on the former power station site found no evidence of water vole presence on the
River Stour.
Otters
8.129
There are six records of European otter within 2km of the proposed converter station
and substation site, associated with the River Stour and tributaries, although the
most recent of these records dates back to 1997.
8.130
No evidence of otter was identified during surveys of Sandwich Bay to Hacklinge
Marshes SSSI, or the adjacent Minster Stream.
8.131
Surveys completed in 2005 for the TOWF cable installation identified an otter
footprint on the bank of the River Stour, west of the proposed converter station and
substation site. No evidence of otter was recorded during surveys undertaken
during 2009 and 2010 in support of the Richborough Power Station demolition
impact assessment or during the site walkover.
Wintering Birds
8.132
The area surrounding Pegwell Bay is used by large numbers of migratory birds as
they make landfall in Britain in spring or depart for continental Europe in autumn.
These include nationally important numbers of ringed plover (Charadrius hiaticula)
and greenshank (Tringa nebularia) during their migration and red-throated diver
(Gavia stellata) during the winter period. The area is also of importance for several
other species including wintering populations of dunlin (Calidris alpina), curlew
(Numenius arquata), oystercatcher (Haematopus ostralegus), redshank (Tringa
tetanus), sanderling (Calidris alba) and grey plover (Pluvialis squatarola) as well as
170
breeding populations of shelduck (Tadorna tadorna), redshank (Tringa tetanus) and
oystercatcher (Haematopus ostralegus).
8.133
The subsea
conservation
designations
Ramsar site.
8.134
Thanet Coast and Sandwich Bay SPA consists of a long stretch of rocky shore,
adjoining areas of estuary, sand dune, maritime grassland, saltmarsh and grazing
marsh (JNCC, 2001). Specifically the area is designated for supporting populations
of birds of European importance as listed below:



8.135

Ringed plover, 649 individuals representing 2% of the Great British (GB)
population; and
Common greenshank, 35 individuals representing 5.8% of the GB population.
The following species occur at nationally important levels in winter (JNCC, 2008):




8.137
Little tern (Sterna albifrons) – 0.3% of the British breeding population;
European golden plover Pluvialis apricaria – 0.2% of GB overwintering
population; and
Turnstone (Arenaria interpres) – 1.4% of GB overwintering population.
Thanet Coast and Sandwich Bay Ramsar site covers a similar area to the SPA,
covering 2,169 hectares. The wetland habitats support 15 British Red Data Book
invertebrates, as well as a large number of nationally scarce species. The site
attracts nationally important numbers overwintering bird populations including
Lapland buntings (Calcarius lapponicus) and several wader species including ringed
plover, golden plover, grey plover and sanderling. The site is used by large
numbers of migratory birds. The following species occurred at levels of national
importance during migration periods in spring and autumn 2008 (JNCC 2008):

8.136
cables will fall to land in an area consisting of several nature
designations (see Table 8.2 and Figures 8.1 and 8.2).
The
that apply to this area include Special Protection Area (SPA) and
Each of these designations relate to important bird species.
Red-throated diver, 57 individuals, representing an average of 1.1% of the GB
population;
Great crested grebe
(Podiceps cristatus cristatus), 218 individuals,
representing an average of 1.3% of the GB population;
European golden plover, 4190 individuals, representing an average of 1.6% of
the GB population; and
Sanderling 598 individuals, representing an average of 2.9% of the GB
population.
The most numerous bird species recorded during the winter bird survey, carried out
in 2008 and 2009 included lapwing and golden plover followed by dunlin and
oystercatcher (TEP, 2010). The survey identified a number of specific areas within
Pegwell Bay that are used regularly by certain wader and wildfowl species for
roosting or feeding. These areas are listed below and detailed in Appendix 8.6:




The mudflats near the north bank of the River Stour;
The large area of saltmarsh immediately to the east of Stonelees;
Shellness;
Saltmarsh and grazing marsh on the south bank of the River Stour; and
171

The mudflats at the south-east end of Pegwell Bay.
8.138
It is likely that the distribution of wader species is dictated by the abundance of
invertebrate prey species. The Inter-tidal Sediment and Invertebrate Survey
(Appendix 8.8) recorded 42 different invertebrate taxa and distinct areas of Pegwell
Bay could be identified based on the invertebrate species present. Certain species
have widespread distributions within the Bay including Annelid species and the
common cockle (Cerastoderma edule), which was found to be widespread and
abundant. These species are considered important prey for several wader species.
8.139
Table 8.3 summarises species information for birds that occur at nationally or
internationally important levels at the SPA and Ramsar sites.
Table 8.3: Birds Occurring at Internationally or Nationally Important Levels in
Thanet Coast and Sandwich Bay SPA and Ramsar site
Bird
Species
Turnstone
Species Information
Turnstone feed on sandy beaches and rocky shores along the northeast Kent coast particularly in areas of loose stones or seaweeds.
Their preferred food includes peeler crabs, small crustaceans such as
shrimps, and barnacles, as well as marine molluscs. Roosting within
the SPA occurs from Swalecliffe to Pegwell Bay mainly on areas of
sand and shingle but also on man-made structures such as the sea
wall.
Golden
Golden plover overwinter on land around Sandwich Bay. Mudflats
Plover
and sandflats in Pegwell Bay and Sandwich Bay provide roosting
grounds for golden plover. In recent years golden plover has taken to
roosting in large numbers on the intertidal mudflats of the bay itself. It
is likely that, whilst there, some feeding takes place but this is not their
prime feeding habitat, which is in arable fields and grazing marsh
located inland of the dunes of Sandwich Bay. .
Ringed
Over winter, ringed plover are not observed in high numbers in
Plover
Pegwell Bay. When present, they appear to feed near the mouth of
the River Stour.
Greenshank Greenshank are rarely seen in the bay in winter and were not
observed during the TEP winter bird survey. Greenshank tend to feed
on worms, snails and fish.
RedOutside of the breeding season, red-throated divers are numerous
throated
along the east coast of Britain and they are known to overwinter in
Diver
Pegwell Bay. Only four individuals were observed during the TEP
winter bird survey and these were seen towards the middle of the bay,
swimming south. They feed on a wide range of fish species.
Great
Numbers of great crested grebe peak within the Thanet Coast and
Crested
Sandwich Bay Ramsar/SPA site during winter, however, no
Grebe
individuals were observed in Pegwell Bay during the TEP winter bird
survey suggesting individuals tend to reside elsewhere within the
wider designated area. Great crested grebe dive to catch fish as well
as to escape, tending to prefer this to flying.
Sanderling Sanderling overwinter in the UK in places such as Pegwell Bay. Over
172
Bird
Species
Species Information
100 individuals were observed in Pegwell Bay during the TEP winter
bird survey. The birds were observed in various locations, appearing
not to be restricted to certain areas of the Bay.
8.140
Of the birds utilising Pegwell Bay, lapwing, golden plover, turnstone and grey plover
using Pegwell Bay will be most sensitive to disturbance between October and March
when they are present in large numbers. Turnstone, sanderling and grey plover will
also be sensitive during May when numbers of these species peak within the bay for
the spring migration. These migratory species also exhibit autumn migration during
several weeks in August and September.
Breeding Birds
8.141
Little tern traditionally nest at Shell Ness in Pegwell Bay approximately 1.1km south
of the offshore cable route across the bay and approximately 800m east of the cable
route at its closest point. Little tern nest in small, single-species colonies on areas
of shingle and sand. In addition to their breeding grounds little tern feed in the
shallow coastal waters on small fish (e.g. sand eel, pipefish, and gobies) and
crustaceans (shrimps, prawns and crabs). It has been observed through the ongoing surveys undertaken by KWT and other groups that numbers of little terns have
been decreasing dramatically in recent years and this is thought to be largely as a
result of increased disturbance. Although little terns are not present in the UK over
winter, a survey visit was also undertaken in May to include the spring migration
period. Little tern were not identified at any point during the TEP surveys.
8.142
During the 2009 breeding bird transect survey, 34 bird species were observed at the
Country Park and within Stonelees Nature Reserve; 27 species in the early visit
(May 2009) and 21 species in the late visit (June 2009).
8.143
No Schedule 1 species were observed during the 2009 surveys. Seven UKBAP
species (bullfinch, dunnock, herring gull, reed bunting, song thrush, starling and
turtle dove) were recorded on site during the survey. Dunnock and song thrush
have been classified as probable breeders within Pegwell Bay Country Park.
8.144
Species addressed by the LBAP and which were recorded during the survey include
lapwing, reed bunting and turtle dove.
8.145
Eight amber list species which are not UKBAP species (lapwing, kestrel,
housemartin, meadow pipit, mistle thrush, swallow, whitethroat and wheatear) were
also recorded during the survey.
8.146
The Country Park and Stonelees Nature Reserve are considered to have local
importance for breeding birds, since these sites support a range of bird species
including a number of declining Birds of Conservation Concern bird species.
Although some species may not be breeding within the survey area, those that do
not nest will likely use the habitats to support nesting elsewhere outside the
development area. Plantation, scrub, rough grassland and saltmarsh habitats have
potential to support species of breeding birds. In particular, the Country Park and
Stonelees Nature Reserve support good numbers of breeding whitethroat which
173
breed in tall herbs or low shrubby growth in open habitats, hedgerows and
scrubland.
8.147
Surveys to identify the location of nesting redshank were also undertaken in 2009
(Appendix 8.7). These identified three main areas of redshank nesting activity within
Pegwell Bay:



8.148
The lagoon north of Pegwell Bay Country Park;
Saltmarsh east of Pegwell Bay Country Park; and
Saltmarsh South of Pegwell Bay Country Park.
The lagoon north of Pegwell Bay Country Park is of most relevance to this
assessment, as it is approximately 5m east of the proposed cable route, between
the TJP and the Country Park.
Fish
8.149
Information received from the Environment Agency identifies the River Stour as a
migration route for the following protected species of fish:



European Eel (NERC);
Atlantic Salmon (Habitat Regulations); and
River Lamprey (Habitat Regulations).
8.150
European eel, Atlantic salmon and river lamprey are all listed as UK BAP priority
species.
8.151
No part of the River Stour is located within the site, however the river is located
within 15m of the southern boundary of the converter station and substation site.
Seals
8.152
Two species of seals breed within British waters:


8.153
Harbour Seal; and
Grey Seal.
Both species of seal occur within the waters off the coast of Pegwell Bay and
records received from KMBRC indicate the presence of Harbour seal within Pegwell
Bay. There are believed to be approximately 50 harbour seals within the Stour
Estuary.
Baseline Projections
8.154
An integral part of ecological impact assessment is to consider the predicted trends
of each of the ecological features if no development were to be carried out.
8.155
In the absence of the development, the ecological interest of each part of the site
would remain more or less at existing levels. Habitats along the majority of the
cable corridor are currently managed by KWT. Management of these habitats would
continue, maintaining existing ecological interest. Habitats at the former power
174
station, comprising hardstanding are unlikely to alter significantly from their current
state within a reasonable timeframe.
Selection of Key Receptors
8.156
There will be no impact on the Ash Level and South Richborough Pasture LWS as
part of the construction or operation phases of the development. No part of the site
is located within the LWS and standard construction working practices will avoid any
environmental effects from noise, lighting and pollution.
8.157
There will be no impact on the Wood and Grasslands, Minster Marshes LWS as part
of the construction or operation phase of the Proposed Development due to its
location 500m west of the site. Similarly, there will be no impact in the RNR within
the country park, due to its location approximately 25m west of the proposed cable
corridor. These features are therefore not considered key receptors.
8.158
Plantation, woodland and scrub within the survey area are widespread and are of
value as nesting bird habitat. A very small area of these habitats will however be
affected by the proposed works. These habitats will therefore be assessed along
with impacts to breeding birds.
8.159
The plantation, woodland and scrub habitats also hold some potential value for
foraging and commuting bats. Removal of the small areas of these habitats is
unlikely to result in any impact on bats. Bats are therefore excluded from the
assessment.
8.160
Although evidence of otters has previously been identified using the River Stour,
southwest of the converter station and substation, it is not anticipated that any
significant impact on otters periodically using the river will be caused during
construction or operation. Otters are therefore not considered to be a receptor.
8.161
The Key Receptors, identified on the basis of their size and range in relation to local
and national trends, are listed in Table 8.4.
Table 8.4: Ecological Receptors
Receptor
Pegwell Bay
Designated Areas:
Thanet Coast and
Sandwich Bay
Sandwich Bay
Thanet Coast
Sandwich and
Pegwell Bay
(including Pegwell
Bay Country Park)
Stonelees Nature
Reserve habitats
(part of the wider
Sandwich and
Designation/Protection/Status Value
SPA/Ramsar
SAC
SAC
International
NNR
National
SSSI
Local
175
Receptor
Pegwell Bay KWT
reserve)
Unit 11 Sandwich
Bay and Hacklinge
Marshes
Wintering birds
Breeding birds
(including redshank)
Protected Flora
(Lizard Orchid,
Martin’s Ramping
fumitory, Bedstraw
Broomrape
Natterjack Toads
Reptiles (common
lizard, slow worm
and grass snake)
Water voles
River Stour,
European Eel,
Atlantic Salmon and
River Lamprey
Seals
Designation/Protection/Status Value
SSSI
National
Wildlife and Countryside Act
Habitat Regs
Wildlife and Countryside Act
Regional
Wildlife and Countryside Act
Local
Wildlife and Countryside Act
Wildlife and Countryside Act
International
Local
Wildlife and Countryside Act
NERC
Habitat Regs
Local
National
Habitat Regs
National
Local
Prediction and Assessment of Significance of Potential Impacts
8.162
Only those habitats and species of at least local value have been considered as
significant effects on ecological features of less than local value are not likely to be
considered by the local planning authority as material to the decision to proceed with
the Proposed Development. The characterisation of the impacts on valued
ecological features and significance of effects during construction and operation are
described in the absence of mitigation.
Construction
8.163
The description of construction is set out in Chapter 2. Potential environmental
effects upon water and air quality which may arise from spillages or dust generated
during construction are discussed in other chapters (Chapter 7 – Hydrology and
Flood Risk, Chapter 12 Noise and Vibration and Chapter 13 Air Quality). This
chapter identifies the potential ecological effects that may result upon the ecological
receptors identified in Table 8.4, including sites designated for nature conservation
and protected species.
8.164
The cables route has been carefully considered to avoid affecting sensitive habitats
where possible and to exploit opportunities to enhance biodiversity. Potential
predictable effects (prior to mitigation) on Key Receptors of ecological importance
arising from the construction phase works are as follows:
176







Temporary loss and disturbance of saltmarsh habitats within Ramsar, SPA,
SAC, SSSI and NNR areas;
Temporary disturbance of birds overwintering within the saltmarsh and mudflat
habitats within Ramsar, SPA, SAC, SPA, Ramsar, SSSI and NNR areas;
Loss of nesting habitat and temporary disturbance of nesting birds;
Temporary loss of grassland habitats within Stonelees Nature Reserve (SPA,
Ramsar, SSSI and NNR);
Temporary disturbance of reptiles and temporary loss of reptile habitat;
Temporary disturbance of natterjack toads and temporary loss of natterjack
toad terrestrial habitat; and
Temporary disturbance of water voles.
Pegwell Bay Designated Areas
8.165
Table 8.2 provides a list of the designated sites or features for which they are
designated may be affected by the proposed works.
8.166
The subsea cables would pass through approximately 1,900m of designated areas
including Thanet Coast and Sandwich Bay SPA and Ramsar, Sandwich Bay SAC,
Sandwich Bay to Hacklinge Marshes SSSI and Sandwich and Pegwell Bay NNR
before connecting to the onshore cables in a below ground TJP within an area of
saltmarsh. The onshore underground cables would run from the TJP and pass
through further saltmarsh and modified grassland for approximately 260m before
entering the Pegwell Country Park. In total the cable corridor passes through
2,160m of the designated areas of Pegwell Bay. Works that could potentially affect
the intertidal mudflats, saltmarsh and modified neutral grassland habitats during the
construction phase of the development include:





Trenching and installation of the subsea cable across mudflats and saltmarsh
habitats;
Excavation and installation of TJP within saltmarsh habitat;
Excavation of joint pit within Pegwell Bay Country Park;
Excavation and installation of onshore cable within saltmarsh and modified
grassland habitats; and
Reinstatement of excavated areas.
8.167
The trenching works will result in the temporary disturbance of sediments within the
intertidal area and the removal of saltmarsh within the offshore cable corridor and
the temporary removal of saltmarsh and grassland vegetation within the onshore
cable corridor. The effects will however be short term, temporary and reversible,
and would affect a very small area of the Pegwell Bay designated site
8.168
In addition to the above effects, temporary disturbance to wintering birds, breeding
birds and intertidal invertebrates is also likely. These effects have been assessed
separately below.
8.169
The important sand dune and grazing marsh habitats within the designated areas
are generally south of the River Stour, between 800m and 1,300m from the cable
route. There will therefore be no direct effect and no anticipated pathway that may
result in indirect effects on these habitats.
177
8.170
A full assessment of the predicted impacts on the internationally designated sites
(SAC, SPA and Ramsar sites) has also been undertaken within the ‘Information for
Habitats Regulations Assessment’ document (see Appendix 8.9).
National Nature Reserve (NNR) and Pegwell Bay Country Park
8.171
The habitats within the NNR that also fall within the Pegwell Bay designated sites
are described above. The onshore cables would pass through approximately
1,100m of Pegwell Bay Country Park, which is also part of the NNR. The habitats
within this area comprise semi-improved grassland, broadleaved plantation with
occasional scattered scrub which will be affected by:





Surface laying of the cable in the northern section of the Country Park (and
burying with chalk);
Trenching and installation of the onshore cable through semi-improved
grassland plantation and scrub habitats in the southern section of the Country
Park;
Scrub and tree removal to allow cable installation works;
Installation of onshore underground cables; and
Reinstatement of excavated areas.
8.172
The trenching works will result in the temporary removal of grassland, and
permanent removal of scrub and woodland habitats within the Country Park.
8.173
In the northern section of Pegwell Bay Country Park, the cable will be laid on top of
the existing ground level to avoid disturbing the underlying landfill. Chalk will be
used to cover the cables and will be graded into the surrounding ground levels. The
graded chalk will then be used to create a swathe of chalk grassland through the
north of the park, connecting to the area of existing chalk capped area in the
southern section of the Country Park. This will increase habitat and provide habitat
for more diverse range of native species.
8.174
In the north of the Country Park a temporary works compound will be created within
grassland adjacent to the proposed cable route. An access track to the compound
will link to the adjacent A256 Sandwich Road.
8.175
The effects on the grassland will be short term and temporary, while the effects on
plantation and scrub will be permanent.
Stonelees Nature Reserve
8.176
The onshore underground cables would pass through approximately 330m of
Stonelees Nature Reserve which is also part of the Thanet Coast and Sandwich Bay
SPA and Ramsar site, Sandwich Bay to Hacklinge Marshes SSSI, Sandwich and
Pegwell Bay NNR and Sandwich and Pegwell Bay KWT reserve. The habitats
within this area comprise unimproved grassland and broadleaved woodland with
occasional scattered scrub which will be affected by:



Trenching and installation of the onshore cable through unimproved grassland
and broad-leaved woodland habitats;
Scrub and tree removal to facilitate trenching works;
Installation of onshore cable; and
178

Reinstatement of excavated areas.
8.177
The trenching works will result in the temporary removal of grassland and
permanent removal of scrub and woodland habitats within the nature reserve.
8.178
The effects on the grassland habitats will be short term and temporary, while the
effects on woodland and scrub will be permanent. The works will impact a relatively
small area of the Nature Reserve.
Unit 11 Sandwich Bay to Hacklinge Marshes Site of Special Scientific Interest
(SSSI)
8.179
The onshore underground cables would be installed from the BayPoint sports
complex under the A256, Minster Stream and Unit 11 of Sandwich Bay to Hacklinge
Marshes SSSI which consists of unimproved neutral grassland and scrub. The
proposed cable will be installed using horizontal directional drilling, which will avoid
affecting the habitats within this area. There will be no impact upon the SSSI or
Minster Stream as a result of installation of the onshore underground cables.
8.180
No part of the converter station and substation falls within the SSSI and there will be
no direct habitat loss or disturbance impacts from the converter station and
substation station construction.
Wintering Birds
8.181
The subsea cable cables and onshore underground cables will take up to 12 weeks
to install. The cable installation works therefore have the potential to disturb birds
using the habitats as an overwintering site, or passage birds temporarily present
within the bay through:



Visual disturbance of birds through the physical presence of machinery and
people within the mudflats and saltmarsh;
Disturbance of birds from noise generated during cable installation works; and
Disturbance or removal of prey items through trenching works within mudflat
habitats.
8.182
The Intertidal Sediment and Invertebrate Survey (Appendix 8.8) identified four
distinct areas of importance to wintering birds within Pegwell Bay based on the
invertebrate species range and abundance. The most important feeding area is
avoided by the subsea cable route which is approximately 400m metres to the south
of the offshore cable. The patchy distribution of diverse invertebrate communities
and the widespread abundance of prey items such as cockle and Annelid species
will ensure that waders are not dependent on limited or specific feeding locations.
Displaced birds would therefore be able to feed elsewhere in the bay during cables
installation.
8.183
Cables installation will only disturb a very small proportion of the total prey species
in the bay. The trench across the intertidal area will be 1m wide and 1.2m deep.
Overall, it is expected that the magnitude of change will be low. Although bird
numbers of national and international importance visit the site, the impact of the
temporary disturbance effect on wintering bird species, in combination with feeding
179
opportunities across the intertidal area on wintering bird species is likely to be of
minor significance.
8.184
The assessment undertaken as part of the ‘Information for Habitat Regulations
Assessment’ document (Appendix 8.9) concludes that localised simplification of
habitats may result in a reduced range of prey species and reduction of prey items
within areas of the mudflats directly affected by excavation. Excavation within the
mudflats will affect approximately 0.065% of the mudflat habitats and is therefore
unlikely to have a significant effect on the available prey items across the total
available habitat.
8.185
The proposed converter station and substation would be approximately 400m from
important wintering bird areas. The construction site is visually screened from the
internationally designated habitats. There will be no impacts on overwintering birds
as a result of the converter station and substation construction or operation.
Breeding Birds including Redshank
8.186
Pegwell Bay Country Park is of local importance for breeding bird species including
redshank and whitethroat. The Breeding Bird and Nesting Redshank Survey
(Appendix 8.7) identified a total of 34 bird species during the survey although it was
noted that some species may not have been breeding in the survey area.
8.187
Three redshank nesting areas were identified by the survey in Pegwell Bay and one
of these is located at the ephemeral pool within the saltmarsh. This nesting area is
within 20m of the onshore underground cable route so there is potential for
temporary disturbance to breeding redshank if works take place during the nesting
season.
8.188
Works within areas containing dense vegetation, including Pegwell Bay Country
Park and Stonelees Nature Reserve have potential to disturb nesting birds.
Removal of trees, scrub and tall herbs through cables installation has the potential
to disturb a range of passerine birds using the habitats for nesting. Installation
works will result in temporary disturbance of nesting habitats, while the loss of
nesting and foraging habitat in the form of trees and scrub would be permanent.
Only a small area of nesting habitat however would be lost as part of the scheme
and would not result in a significant reduction in nesting habitat.
8.189
There is a small area of suitable nesting habitat within the site of the proposed
converter station and substation, consisting of a group of trees in the southeast
corner of the site. The proposed removal of these trees has the potential to directly
impact upon birds nesting within this habitat if undertaken during the nesting
season. The removal of the trees will also reduce the amount of nesting habitat
available within the site. Visual and noise disturbance also has the potential to
disturb birds nesting within the adjacent habitats, including Unit 11 of Sandwich Bay
to Hacklinge Marshes SSSI. Activity and noise levels are unlikely to be significantly
different to those experienced during demolition works at the site. Additionally, birds
become habituated to this kind of disturbance and nesting activities are unlikely to
be affected.
180
Protected Flora
8.190
No protected species of plants were identified within the development application
boundary during the Phase 1 Habitat surveys. Lizard orchid, bedstraw broomrape
and Martin’s ramping fumitory have previously been recorded in the Country Park
and Stonelees Nature Reserve.
8.191
Cable installation works have the potential to affect individuals of these species
which could result in their loss. The impacts of the cable installation works on
protected species of flora would be temporary and reversible, affecting only a very
small area of suitable habitat. Following reinstatement, suitable recolonisation
opportunities would be provided.
Natterjack Toads
8.192
There is potential for the cable installation works to affect natterjack toads within
Stonelees Nature Reserve through disturbance of a small area of grazed grassland
in the northern section of the Reserve. The works will result in the temporary loss of
terrestrial habitat and may potentially result in injury or death of natterjack toads,
were they to be present within the working areas at the onset or during works.
Construction impacts on natterjack toad habitat will be temporary, and reversible,
affecting a small proportion of the overall surrounding habitat. The impact of
causing injury or death to individual natterjack toads would be permanent.
Reptiles
8.193
Cable installation works between the landfall and the southern edge of Stonelees
Nature Reserve will result in the temporary loss of reptile habitat in the form of
grassland and plantation/woodland edge and scrub habitats. Cabling works also
have the potential to result in injury or death of common lizard, slow worm and grass
snake. The impact of cable installation works on reptile habitat will be temporary,
and reversible, affecting a small proportion of the overall surrounding habitat. The
impact of causing injury or death to individual reptiles would be permanent.
Following reinstatement, reptiles will be able to recolonize along the cable route.
8.194
There will be no effect on reptile habitats within Unit 11 of Sandwich Bay to
Hacklinge Marshes SSSI, north of the converter station, as the cable will be installed
using HDD methods between the BayPoint sports complex and the converter station
and substation site.
Watercourses, Ditches and Water Vole
8.195
Minster Stream and ditches within Unit 11 of Sandwich Bay to Hacklinge Marshes
SSSI are the only watercourses and ditches that will be crossed by the onshore
underground cables. HDD will be used to install the cables under the stream and
SSSI; ditch habitats and water vole populations will not be affected in these areas.
8.196
The onshore cables installation working area within Stonelees Nature Reserve is
approximately 5m from the bank of the ditch that runs parallel to Sandwich Road.
Water voles have previously been identified within this ditch (TOWF, 2005). The
ditch has however deteriorated since water voles were detected, the banks have
become heavily shaded and the ditch is dry for long periods. If water voles are still
present, disturbance to water voles is unlikely.
181
8.197
The construction of the converter station and substation will not directly affect any
ditches within Unit 11 of Sandwich Bay to Hacklinge Marshes SSSI or the River
Stour as the boundary of the site is a minimum of 15m from each of these sites.
River Stour, European Eel, Atlantic Salmon and River Lamprey
8.198
The construction of the converter station and substation will not directly affect the
River Stour. Impacts may however be caused through sediments and pollution
being washed into the river within surface water runoff. Impacts to migratory life
stages of fish species may also be caused through the lighting of the site during
construction.
Seals
8.199
Due to the presence of seals within the Stour Estuary and Pegwell Bay, there is
some potential for disturbance of seals during works within the intertidal zone.
Disturbance will be limited to the presence of vessels, machinery and personnel
during cable installation within the intertidal zone. Disturbance will be localised and
temporary and is likely to cause low levels of disturbance to seals.
8.200
There is further potential for disturbance to seals during the offshore cable
installation works. These potential impacts are assessed in the marine cable
Environmental Statement (see Appendix 16.1 for non-technical summary).
8.201
There is no potential for disturbance to seals during the installation of the onshore
cables or construction of the converter station or substation due to the isolation from
suitable habitats.
Construction Impact Summary
8.202
Table 8.5 summarises the predicted impacts of cables installation and construction
of the converter station and substation on identified ecological receptors, prior to
mitigation.
182
Table 8.5: Construction Impacts
Magnitude and
Extent
Pegwell Bay Designated Areas
Loss of saltmarsh
Moderate (approx.
habitat through
180m)
trenching works during
cable installation
Disturbance of mudflat Moderate (approx.
habitats during
1750m potentially
trenching works and
affected although
cable installation
actual working area
likely to be far less).
Impact Description
Loss of modified
Moderate (approx.
grassland habitats
230m)
through installation of
cable
NNR and Country Park
Loss of semi improved Moderate (approx.
grassland, plantation 1100m)
and scrub habitats
Stonelees Nature Reserve
Loss of grassland
Moderate (approx.
habitats through
330m)
trenching and
installation of cable
Reversibility
Temporary,
during cable
installation
only
Temporary,
during cable
installation
only
Reversible
Impact would be Certain
(recolonisation by
constant during
saltmarsh vegetation) cable installation
only
Reversible
Impact would be Certain
(recolonisation of
constant during
trenched areas of
cable installation
mudflats is likely to
only
extend beyond the
cable installation
period)
Irreversible
Impact would be Certain
constant during
construction
Adverse
Temporary,
during cable
installation
only
Reversible
Impact would be Certain
(recolonisation of
constant
grassland vegetation) throughout cable
installation within
the Country Park
Adverse
Temporary,
during cable
installation
only
Reversible
Impact would be Certain
(recolonisation of
constant
grassland vegetation) throughout cable
installation within
nature reserve
Adverse
Permanent
183
Frequency
Probability
Direction of
Significance
Duration
Adverse
Adverse
Impact Description
Wintering Birds
Disturbance of birds
using Pegwell Bay
during winter period
(October - May) during
installation of cable
Magnitude and
Extent
Minor (cable route
avoids key feeding
areas but would likely
result in displacement
of birds to alternative
feeding areas around
the bay)
Breeding Birds including Redshank
Disturbance of nesting Minor (small areas of
birds during tree and nesting habitat
scrub removal
affected by cable
required ahead of
installation works)
cable installation
within the Country
Park and Stonelees
Nature Reserve
Disturbance of nesting Minor (small areas of
birds during tree and nesting habitat
scrub removal
affected)
required prior to
construction within
converter station and
substation site.
Disturbance of nesting Minor (habitats
redshank during cable adjacent to saltmarsh
installation within
pool next to the cable
proximity of saltmarsh corridor)
lagoon
Reversibility
Frequency
Temporary
during cable
installation
Reversible
(disturbance will
cease following
completion of cable
installation)
Impact would be Probable
constant during
cable installation
only
Adverse
Temporary
during cable
installation
Reversible
(disturbance will
cease following
completion of cable
installation)
Impact would be Probable
constant through
cable installation
period
Adverse
Temporary
during cable
installation
Irreversible (removal
of trees)
Impact would be Certain
constant through
construction
period
Adverse
Temporary
during cable
installation
Reversible
(disturbance will
cease following
completion of cable
installation)
Impact would be Probable
constant through
cable installation
period
Adverse
184
Probability
Direction of
Significance
Duration
Magnitude and
Extent
Protected Flora – Local Value
Removal of protected Minor (loss of
plant species during
individuals)
cable installation
works
Natterjack Toads
Removal of habitats
Moderate (grazed
used by natterjack
unimproved
toads within Stonelees grassland)
Nature Reserve during
cable installation
Direct impact on
Minor
Natterjack toads
causing injury or
death.
Reptiles
Removal of habitats
Moderate (approx.
used by reptiles within 1,700m of cable
Pegwell Bay, Pegwell corridor through
Bay Country Park and modified grassland,
Stonelees Nature
semi improved
reserve during cable
grassland, unimproved
installation
grassland and scrub
habitats)
Direct impact on
Moderate
reptiles during cable
installation causing
injury or death.
Impact Description
Reversibility
Frequency
Permanent
Irreversible
Constant during Unlikely
cable installation
Adverse
Temporary
during
construction
period only
Reversible (through
reinstatement of
habitats)
Constant during Probable
cable installation
Adverse
Permanent
Reversible (risk will
cease following
completion of cable
installation)
Constant during Probable
cable installation
Adverse
Temporary
during cable
installation
only
Reversible
(recolonisation of
vegetation)
Constant during Probable
cable installation
Adverse
Temporary
during cable
installation
only
Reversible (risk will
cease following
completion of cable
installation)
Constant during Probable
cable installation
Adverse
185
Probability
Direction of
Significance
Duration
Impact Description
Magnitude and
Extent
Duration
Reversibility
Water Voles
Disturbance of ditches Minor
Temporary
Reversible (will cease
that support water
following completion
vole within Stonelees
construction)
Nature Reserve
River Stour, European Eel, Atlantic Salmon and River Lamprey
Pollution of river
Moderate
Temporary
Reversible (risk will
habitats used by
cease following
protected species of
completion of
fish during migration
construction period)
through surface runoff
carrying sediments
and chemicals.
Disturbance of
Major
Temporary
Reversible (risk will
migrating fish species
cease following
through lighting
completion of
impacting upon river
construction period)
habitats
Seals
Disturbance of seals
Negligible
Temporary
Reversible (risk will
during cable
cease following
installation across the
completion of
intertidal zone.
construction period)
186
Frequency
Probability
Direction of
Significance
Constant
Unlikely
Adverse
Intermittent
Probable
Adverse
Intermittent
Probable
Adverse
Intermittent
during cable
installation
Probable
Negligible
Operation
8.203
Once installed, the cables will not be visible and will not require any
maintenance or further works except in the unlikely event of failure
necessitating repair. In this case the likely location of any works will be at
the TJP or the two other joint pits along the cable route.
8.204
No effects on designated sites, habitats or protected species are anticipated
during operation of the cable.
8.205
Some minor disturbance of habitats and species within the Pegwell Bay
designated habitats will be caused through surveys that will be undertaken
to monitor the recolonisation of the working areas by saltmarsh species.
This will involve occasional access by surveyors and will be timed to avoid
impacts of wintering and breeding birds.
Converter Station and Substation
8.206
Only six staff will be required to access the converter station and the
substation will be unmanned except for infrequent maintenance inspections
and emergencies. Potential lighting and noise impacts that may disturb
habitats and protected species in adjacent areas will be reduced using
standard methods such as lighting regimes and noise mitigation measures.
Operation Impact Summary
8.207
Table 8.6 summarises the predicted impacts of the development during
operation on identified ecological receptors, prior to mitigation.
187
Table 8.6: Operational Period Impacts
Impact
Description
Magnitude
/ Extent
Duration
Reversibility
Frequency Probability
Direction of
Significance
Temporary (3
visits over 3
years following
installation)
Reversible
Intermittent
Negligible
Pegwell Bay Designated Areas
Monitoring surveys
of saltmarsh
recolonisation
Negligible
188
Certain
Mitigation
8.208
This section identifies the mitigation measures proposed to minimise impacts upon
ecological receptors. It considers the effectiveness of the mitigation and the time
required for the mitigation to become effective. Time is an important factor, as
works such as planting would require an establishment period and a maturation
period before they have the potential to replace mature and structured habitats lost
during construction activities. In some instances though, mitigation measures may
have an immediate effect. Time periods are considered as follows:




Immediate – effective immediately;
Short term – effective within 2 years;
Medium term – effective within 2 to 5 years; and
Long term – effective within 5 to 10 years.
8.209
Mitigation is required for each significant effect upon receptors in order to reduce
the specific impacts of the proposed development to acceptable levels.
8.210
Method Statements will be produced prior to any works within designated areas
detailing how impacts on the habitats and species within the area will be reduced or
avoided. These will be produced in consultation with NE and KWT.
Pegwell Bay Designated Areas
8.211
The route of the subsea and onshore underground cables and location of the TJP
and other joint pits have been chosen to avoid ecologically sensitive receptors
wherever possible. The subsea cable and landfall are within areas of saltmarsh
south of the area previously disturbed by the installation of the Thanet Offshore
Wind Farm cable. This will avoid disturbance to the more extensive areas of
saltmarsh habitats south of the cable corridor.
8.212
Site compounds will be located outside of the Pegwell Bay designated areas. No
equipment, materials, chemicals or fuel will be stored within or adjacent to
designated areas. Compounds within the Richborough Site and Pegwell Bay
Country Park will be used for the storage of equipment, materials and chemicals. All
refuelling of plant will be undertaken within the site compounds, within the
Richborough Site and Pegwell Bay Country Park
8.213
Prior to the start of installation works the saltmarsh areas that are to remain
untouched by the works shall be visibly segregated from the works area using
temporary fencing. An ecologist shall advise as to locations of these habitats and
placement of protective fencing.
8.214
Machinery required to access the intertidal areas will be restricted to set routes to
limit the area impacted.
8.215
Drip trays or plant nappies will be used under all mobile or small plant such as
generators etc.
8.216
Delivery vehicles will deliver to the site compounds to reduce disturbance and risk
of spillages and leaks within the designated areas or wider areas.
8.217
All plant and equipment working in the vicinity of the shore line shall be clean on
delivery. If not all tracks, wheels etc. shall be thoroughly cleaned before entering the
189
working area. Generation of silt shall be minimised by excavators/dumpers etc. by
limiting movements by machinery.
8.218
A contingency plan for spillages etc. shall be produced prior to start on site. Spill
kits will be available in the site compound and all working plant such as
dumpers/excavators.
8.219
Vegetation that will be directly affected by cable installation works will be removed
by cutting turves. The turves will be stored locally and will be replaced following
completion of cable installation and backfilling of the trench. Different saltmarsh
and grassland communities will be stored separately and replaced based on the
NVC habitat types in each part of the saltmarsh. Removal, storage and
replacement arrangements and removal will be determined through production of a
Method Statement in consultation with NE.
8.220
All suitable plant and equipment working in the designated sites will be bio oil
based. A site checklist will be used for traffic management and plant to ensure they
are all in good working order.
8.221
Excavated material on the mudflat habitats will be replaced as quickly as possible to
avoid leaving exposed trenches at times of high tide. There will be no loss of
mudflat habitats as part of the works but the disturbance of the mudflats through
excavation of sediments will be unavoidable.
8.222
Reinstatement of habitats will be undertaken in sections as the cable installation is
completed and immediately following backfilling.
8.223
Following installation of the cable and TJP the working area within the saltmarsh will
be fenced to allow saltmarsh vegetation to re-establish without further disturbance.
This method was used following installation of the Thanet Offshore Wind Farm
cable and has resulted in positive recolonisation of the affected areas by saltmarsh
species. This mitigation will be effective in the medium term.
8.224
Monitoring surveys of the affected saltmarsh will be undertaken for five years
following construction and the results will be submitted to NE and KWT.
8.225
Monitoring surveys of intertidal invertebrates will be undertaken annually for a
period of 5 years following the cable installation works to determine the
recolonisation rates of the disturbed areas of mudflat habitats.
8.226
Full details of the proposed mitigation for cable installation within the Pegwell Bay
internationally designated areas is provided in the ‘Information for Habitat
Regulations Assessment’ document (Appendix 8.9).
Pegwell Bay Country Park
8.227
In the northern section of Pegwell Bay Country Park, the cable will be laid on top of
the existing ground level to avoid disturbing the underlying landfill. Chalk will be
used to cover the cables and will be graded into the surrounding ground levels. The
graded chalk will then be used to create a swathe of chalk grassland through the
north of the Country Park, connecting to the area of existing chalk capped area in
the southern section of the Country Park. This will increase habitat and provide
habitat for more diverse range of native species. The aspect of the mitigation will
be effective immediately.
190
Stonelees Nature Reserve Habitats
8.228
Within Stonelees Nature Reserve, as far as is practical, the working width
associated with cables installation will be kept to a minimum and be kept close to
the existing cycle path. Impacts will be reduced to habitats within the previous
working area of the cycle path, affecting as little of the previously undisturbed
habitats as possible.
8.229
Site compounds will not be located within Stonelees Nature Reserve. No
equipment, materials, chemicals or fuel will be stored within or adjacent to
designated areas. Compounds within the Richborough Site and Pegwell Bay
Country Park will be used for the storage of equipment, materials and chemicals.
All refuelling of plant will be undertaken within the site compounds, within the
Richborough Site and Pegwell Bay Country Park
8.230
All suitable plant and equipment working in the designated sites will be bio oil
based. A site checklist will be used for traffic management and plant to ensure they
are all in good working order.
8.231
Drip trays or plant nappies will be used under all mobile or small plant such as
generators etc.
8.232
All plant and equipment working in the vicinity of the shore line shall be clean on
delivery. If not all tracks, wheels etc. shall be thoroughly cleaned before entering the
working area. Generation of silt shall be minimised by excavators/dumpers etc. by
limiting movements by machinery.
8.233
A contingency plan for spillages etc. shall be produced prior to start on site. Spill
kits will be available in the site compound and all working plant such as
dumpers/excavators.
8.234
To inform the production of a mitigation Method Statement for works within
Stonelees Nature Reserve, an NVC survey will be undertaken of areas to be
affected by the proposals. Information obtained as part of the survey will be used to
produce a Method Statement in consultation with NE detailing mitigation and
working methods to be used during installation of the cable.
8.235
Prior to commencement of works within Stonelees Nature Reserve, temporary
fencing will be installed around the site working areas to ensure encroachment into
surrounding habitats is avoided.
8.236
Grassland habitats to be affected by trenching and cable installation works will be
removed in turves and replaced following reinstatement of subsoil areas. Removal,
storage and replacement arrangements will be determined through production of a
Method Statement in consultation with NE.
8.237
Reinstatement of habitats will be undertaken in sections as the cable installation is
completed and immediately following backfilling.
8.238
Full details of the proposed mitigation for cable installation within the Pegwell Bay
internationally designated areas is provided in the ‘Information for Habitat
Regulations Assessment’ document (Appendix 8.9).
191
Wintering Birds
8.239
Cable installation works within the designated areas saltmarsh and modified
grassland of Pegwell Bay will commence outside the months that peak numbers of
birds using the intertidal and saltmarsh habitats are present. The wintering bird
assessment identified the most sensitive times periods of disturbance for wintering
birds within the intertidal areas as being October to February (for lapwing, golden
plover, turnstone and grey plover) and May (for turnstone, sanderling and grey
plover). Cable installation works within the intertidal and saltmarsh areas will not be
undertaken during this period. This will also apply to any cable installation works
within 50m of the seaward edge of the Country Park to prevent disturbance from the
use of machinery on the edge of the park.
8.240
In the event of delays resulting in the cable installation works within the intertidal
area extending into the sensitive period for wintering birds, further mitigation will be
supplied. Where possible, wooden hoarding will be used to visually screen the
works from birds using the bay. For the duration of the extended working period an
additional warden will be supplied to help deter members of the public entering the
intertidal area during works.
8.241
Cable installation within this area will be undertaken following a Method Statement
produced in consultation with KWT and NE. This mitigation will be effective
immediately.
Breeding Birds including Redshank
8.242
Installation of the onshore cable, TJP and subsea cable within the saltmarsh
habitats north of the Country Park will be phased to avoid the peak nesting period
for species, such as redshank, that use the saltmarsh habitats for nesting purposes
(Mid April to July). During this period no works will be undertaken within 100m of
the pool within the saltmarsh habitats to avoid disturbance to nesting redshank.
Prior to the commencement of works within the saltmarsh habitats, a walkover
survey will be undertaken (with a KWT warden if required) to determine the
presence of any active nests and if necessary works will be postponed until nests
are no longer active. Methods used during this survey and works within the
saltmarsh will be detailed in a Method Statement. This aspect of the mitigation will
be effective immediately.
8.243
Removal of vegetation for cables installation within Pegwell Bay Country Park and
Stonelees Nature Reserve will be undertaken outside of the bird nesting season
(March-August inclusive) or will be preceded by an inspection by an ecologist for
active nests immediately prior to vegetation removal.
8.244
Removal of vegetation within the converter station and substation site will be
undertaken outside of the bird nesting season (March-August inclusive) or will be
preceded by an inspection by an ecologist for active nests immediately prior to
vegetation removal. Replacement planting within the converter station and
substation site will replace nesting habitat removed prior to the start of the
development.
Protected Flora
8.245
Pre-commencement surveys of the cable route will be undertaken to identify any
protected species of flora within the working area. In the event that any protected
plants are discovered, these plants will either be fenced out of the working area or
192
transplanted to undisturbed locations as appropriate to their requirements. Where
practical, measures will be implemented to encourage recolonisation of the working
areas by these species (e.g. seed selection). These methods will be detailed within
Method Statements covering the working methods of cable installation.
Natterjack Toads
8.246
A licence will be obtained from NE to allow the cable installation works that may
affect suitable natterjack toad habitats within 500m of the reintroduction site within
Stonelees Nature Reserve. As part of the licence application, a Method Statement
will be produced in consultation with KWT and NE. The details of the licence will be
determined during the licence application process, but are likely to include a
combination of the timing of works to avoid disturbance to potential hibernation
features during the winter months (Nov-Feb), habitat management and controls to
reduce disturbance effects and translocation. Additionally arisings from the trench
excavation works can be used to create suitable amphibian refugia, following
agreements with KWT and NE. This element of the mitigation will be effective
immediately.
Reptiles
8.247
A repeat survey of suitable reptile habitats will be undertaken prior to the cable
installation works. This information will be used to produce a reptile Method
Statement detailing the methods that will be used to install cables within these
areas and the locations of these methods. The Method Statement will be produced
in consultation with KWT.
8.248
Vegetation within areas affected by works between Pegwell Bay Country Park and
the TJP and within Pegwell Bay Country Park and Stonelees Nature Reserve will be
managed prior to works to degrade habitat suitable for use by reptiles. Potential
refugia will also be removed from the working area and placed within suitable
undisturbed habitats. Vegetation removal will be implemented outside of the bird
nesting period (March to August inclusive) or will be subject to inspections by an
ecologist prior to removal. Habitat management and cable installation will be
undertaken between April and September when reptiles are most active due to
higher temperatures.
8.249
Following completion of cable installation the ground will be reinstated either
through seeding the chalk bunds in the north of the Country Park or by replacing
original topsoil where excavations have taken place.
8.250
Arisings from the excavation works can be used to create reptile refugia in suitable
undisturbed areas of the Country Park.
Bats
8.251
The converter station and substation external lighting scheme would typically only
be used for emergencies and during maintenance activities required outside hours
of daylight. This will ensure that potential bat foraging and commuting habitats are
not detrimentally affected. This mitigation will be effective immediately.
Watercourses, Ditches, and Water Vole
8.252
The working area for cables installation within Stonelees Nature Reserve will be
maintained as a minimum of 5m from the ditch that runs parallel to the proposed
193
onshore cable route. This will avoid disturbing any water voles that may be present
within the ditch.
River Stour, European Eel, Atlantic Salmon and River Lamprey
8.253
The converter station and substation external lighting scheme would typically only
be used for emergencies and during maintenance activities required outside hours
of daylight. This will ensure that fish migration along the River Stour is not
detrimentally affected. This mitigation will be effective immediately.
Seals
8.254
Due to the predicted negligible impacts on seals within the intertidal zone there is
no specific mitigation proposed.
Residual Impacts
8.255
Following mitigation no significant effects on ecological features are predicted, and
there are opportunities to provide features that could provide a benefit for
biodiversity. Cable installation works will be timed to avoid or minimise impacts on
breeding birds, nesting birds and natterjack toads. Different sections of the cable
will be installed at different times depending on the timing constraints within each
section.
Table 8.7: Residual Impacts to Ecological Receptors
Receptor
Pegwell Bay
Designated
Areas
NNR and
Country Park
Stonelees
Nature
Reserve
Habitats
Wintering
birds
Breeding birds
including
redshank
Protected
flora
Natterjack
toads
Reptiles
Receptor
Value
Potential
Impact
Magnitude
International Moderate
adverse
Residual Impact
Magnitude
Phase
Negligible
Construction
National
Moderate
adverse
Moderate
adverse
Minor beneficial
Construction
Minor adverse
Construction
Regional
Minor adverse
Negligible
Construction
Local
Minor adverse
Negligible
Construction
Local
Minor adverse
Negligible
Construction
County
Moderate
adverse
Moderate
adverse
Negligible
Construction
Negligible
Construction
Local
Local
194
Receptor
Receptor
Value
Potential
Impact
Magnitude
Minor adverse
Residual Impact
Magnitude
Phase
Negligible
Construction
Moderate
adverse
Negligible
Construction
Negligible
Negligible
Construction
International Negligible
Negligible
Operation
Watercourses, Local
ditches, water
vole
River Stour,
National
European Eel,
Atlantic
Salmon and
River
Lamprey
Local
Seals
Pegwell Bay
Designated
Areas
Cumulative Impacts
8.256
Potential cumulative effects on ecology from the onshore elements of the Nemo
Link in combination with other components of the Nemo Link (i.e. UK, French and
Belgian subsea cables and Belgian onshore infrastructure) are described in Chapter
16.
8.257
Potential cumulative effects of the Nemo Link UK onshore infrastructure in
combination with the grid connection required to facilitate the operation of the Nemo
Link are described in Chapter 17.
8.258
There is potential for cumulative ecological effects to arise from other projects and
plans in the vicinity of the Proposed Development (see Table 1.2, Chapter 1 for full
details).
8.259
The effects on ecology arising from the Proposed Development are anticipated to
be primarily temporary and reversible in that mitigation will include restoration of
disturbed habitats.
8.260
The following paragraphs consider the cumulative effect of the proposed converter
station, substation and underground cable, in combination with each of the six
development proposals referred to above.
8.261
An assessment of cumulative impacts of the six development proposals has also
been undertaken as part of the Assessment of Likely Significant Effects included on
European Designated Sites (Information for Habitat Regulation Assessment – see
Appendix 8.9).
Richborough A Limited Estate Road and Landscaping
8.262
The new estate road will comprise additional concrete hardstanding around the
perimeter of the former Richborough Power Station. Construction of the road layout
is likely to result in the loss of trees at the northeast boundary of the Richborough
Site, a loss of a small number of trees along the site boundary with the River Stour
and a further loss of trees and shrubs along the east boundary of the site. Areas of
195
modified grassland will also be lost along the east, north-east and southeast
boundaries of the site.
8.263
Due to the location of the new road adjacent to the SSSI north of the site and River
Stour southwest of the site, there is potential for construction activities to impact
upon these receptors. Water voles and their burrows present within the SSSI
habitats may be affected by construction adjacent to the SSSI, north of the site.
8.264
The anticipated impact of the construction of the estate road is anticipated to be
minor adverse. Cumulatively with the Nemo Link scheme the predicted impact on
ecological receptors is predicted to remain minor adverse.
8.265
As part of the landscaping proposals for the estate road, replacement trees will be
planted along the new road layout at the eastern and north east boundaries of the
site. Areas of native shrubs and trees will be planted adjacent to the site entrance
and along the southeast boundary. Existing vegetation along the north boundary of
the Richborough site will also be retained and enhanced. Additional planting at the
south west corner of the site (as part of this converter station and substation
planning application) will also be provided.
8.266
Additionally, the landscaping proposals also include areas of species rich grassland
adjacent to the road layout in the east of the site, along the north access road and
along the new access road in the northwest of the site.
8.267
Ecology corridors are also proposed along the access road in the north west and
leading away from the Nemo Link site to the west, although details of the
landscaping proposed for these areas is unknown.
8.268
Overall, the proposed landscaping is anticipated to result in a slight increase in
areas of habitats within the site and result in a minor beneficial impact on ecological
value of the site. Cumulatively with the Nemo Link schemes landscaping proposals,
which also include planting areas of habitat, along the southwest boundary of the
site, the impact on the sites ecology is predicted to be minor beneficial.
8.269
There will be no temporary cumulative construction effects on ecology as the estate
road network will be constructed prior to commencement of construction works in
relation to the proposed converter station, substation and underground cable works.
8.270
Habitats losses within each of the sites will be offset through the landscaping
schemes. During operation, no impact on the adjacent SSSI and River habitats is
anticipated from the Road Layout and landscaping and suitable mitigation
implemented as part of the Nemo Link scheme will avoid further impacts. On
completion, the cumulative impacts of the estate road and landscaping works with
the Nemo Link scheme are predicted to be negligible.
Richborough Site - Peaking Plant Facility
8.271
The Peaking Plant Facility will be located to the south of the Nemo Link
development at the former power station site and will comprise fifty three diesel
fired generators (approximately 2.6 m high) and a chimney stack (approximately
35m high) with associated fuel storage, parking and access. The facility will occupy
an area of approximately 3.37 hectares (8.3 acres).
196
8.272
The Peaking plant facility is expected to remove areas of trees, scrub and grassland
within the Richborough site. Cumulatively this will result in a greater area of habitat
loss within the Richborough site resulting in a predicted minor adverse impact
8.273
There will be no temporary construction cumulative effects on ecology as the
Peaking Plant Facility will be constructed prior to the commencement of the
construction of the converter station and substation.
8.274
There is potential for the cumulative impacts on the River Stour through disturbance
and light pollution from both the Peaking Plant and Nemo Link schemes. Overall,
the potential cumulative impact of the Richborough Peaking plant with the Nemo
Link scheme is predicted to be minor adverse. However, both schemes will
implement mitigation to reduce impacts on the River Stour, resulting in a negligible
cumulative impact.
Pegwell Bay Flood Defences
8.275
The Flood Defence Scheme will comprise two new flood defence elements; a new
concrete flood wall (141m long and up to 1.2m high) to the north of the petrol station
on the A256 Sandwich Road; and an earth embankment (257 metres long and up to
1 metre high) to the south of the petrol station.
8.276
Consultation has identified that NE is of the opinion that the flood defence scheme
will not adversely affect the European Designated sites. There is potential for
combined construction activity to create higher levels of disturbance to
overwintering birds within the bay. However, the proposed completion period for
the flood defence is during 2013, whereas the proposed start date for the UK
onshore elements of the Nemo Link is late 2014/early 2015. Specifically the HVDC
underground cable and TJP works are unlikely to commence before 2016. There
will therefore be no temporary cumulative effects on ecology during construction as
the flood defence works will be completed before HVDC underground cable and
TJP installation works commence.
8.277
On completion cumulative effects on ecology will be negligible as the impacts of the
cable installation are temporary and habitats will be reinstated upon completion.
8.278
During operation, both the Flood Defence Scheme and the HVDC underground
cable and TJP are passive and will not impact upon ecology within Pegwell Bay.
8.279
There will be no cumulative effects on ecology from construction and operation of
the converter station and substation, due to the isolation of the flood defences by a
distance of approximately 1.76km.
Erection of Glasshouses, Water Storage Tanks and Pack House
8.280
The scheme proposed on Ebbsfleet Lane will comprise the erection of glasshouses
(4.7m high to the apex), three rainwater storage tanks (3.04m above ground) and a
pack house (5.52 metres to ridge height) for the grading and packing of roses,
storage of equipment and to provide staff facilities at Ebbsfleet Lane. No potential
impacts on ecology within the Glasshouses site or surrounding area have been
identified during construction or operation of the scheme.
8.281
There will be no temporary construction cumulative effects on ecology as the
construction of the proposed glasshouses, water storage tanks and pack house will
197
be completed before converter station and substation construction works and
HVDC underground cable installation works commence.
8.282
On completion cumulative effects on ecology are not anticipated due to the distance
(400m) of the greenhouses development from the converter station and substation
development and separation by the East Kent Link Road. Through implementation
of standard mitigation measures, the proposed development is not anticipated to
impact ecology in the wider area during operation. There is therefore not
anticipated to be any cumulative impact on ecology resulting from the operation of
Greenhouses development on Ebbsfleet Lane.
Solar Farm South of River Stour
8.283
A Solar Farm is proposed for an area of land to the southwest of the River Stour
opposite the proposed converter station and substation. The foot print of the solar
farm is in the Ash Level and South Richborough Pasture LWS and will result in the
partial and temporary loss of grazing marsh habitats within this site. Grazing marsh
is a UK BAP priority habitat. No ecological impact on the grazing marsh habitats
has been identified as a result of the construction and operation of the Nemo Link
scheme and so there would be no cumulative effects on grazing marsh habitats.
8.284
The solar farm development borders the River Stour and there is potential for
effects on the river during construction through pollution and sediment creation,
although no impact is predicted from operation of the solar farm.
8.285
There is potential for disturbance and light pollution impacting the River Stour
during the construction of the Nemo Link. Cumulatively therefore the construction
activities of the solar farm and Nemo Link scheme are predicted to result in
potential pollution and disturbance impacts on the River Stour which flows between
the two developments. A cumulative moderate adverse impact is therefore
predicted.
8.286
Mitigation will be implemented for both schemes reducing the impacts on the River
Stour, resulting in a negligible cumulative impact on this receptor.
Cumulative Effect of All Unrelated Developments
8.287
The cumulative effect on ecology of the proposed converter station and substation,
and underground HVDC cables, in combination with all six development proposals
discussed above will result in an adverse impact on ecological receptors in the local
area.
The residual impacts of the onshore elements of the Nemo Link are
assessed to be minor adverse, neutral and minor beneficial, and as such there will
be no significant increase in cumulative impacts as a result of the proposed UK
onshore Nemo Link works.
198
References

Froglife (1999); Reptile Survey: An introduction to planning, conducting and
interpreting surveys for snake and lizard conservation. Froglife Advice Sheet
10, 1999, Froglife, Halesworth.

Institute of Ecology and Environmental Management, (2006). Guidelines for
Ecological Impact Assessment in the United Kingdom (7th July 2006).
http://www.ieem.org.uk/ecia/index.html.

Joint Nature Conservation Committee (2003). Handbook for Phase 1 habitat
Survey: A Technique for Environmental Audit. JNCC, Peterborough.

Joint Nature Conservation Committee (2008). Thanet Coast and Sandwich
Bay Ramsar Information Sheet: UK11070

Rodwell, J.S. 2006. National Vegetation Classification: Users’ Handbook.
JNCC.

Royal Society for the Protection Birds (2009). Birds of Conservation Concern
3. RSPB, Sandy.

Strachan, R. and Moorhouse, T. (2006). Water Vole Conservation Handbook
(2nd edition). Wildlife Conservation Research Unit, University of Oxford

http://www.kentbap.org.uk/

http://www.MAGIC.gov.uk

http://www.natureonthemap.org.uk
199
200
9.0
ARCHAEOLOGY AND CULTURAL HERITAGE
Introduction
9.1
This chapter presents a summary of the findings of a desk-based assessment
(DBA) and field observations and considers the potential impacts from the
construction and operation of the Proposed Development upon known
archaeological, built heritage and historical sites both with and without statutory
protection and impacts upon previously unrecorded archaeological sites. A detailed
report of the baseline information forms Appendix 9.1.
9.2
The archaeological potential of the development site has been assessed by
reference to a Study Area which comprises a 1.5km buffer zone from the maximum
extents of the development. The buffer zone includes the intertidal area between
the landfall and low water mark where there is an overlap with an area examined by
Wessex Archaeology (2010) in relation to the marine components of the
development. The assessment of effects of the marine aspects of the proposal are
contained in the Marine Environmental Statement which has been submitted as part
of the Marine Application; however consideration of the heritage assets noted
between the landfall and low water mark has also been included as part of the
onshore cultural heritage assessment.
Legislation and Planning Policy Context
National
9.3
Table 9.1 provides a summary of statutory legislation relevant to the historic
environment.
Table 9.1: Statutory Legislation with Regard to the Historic Environment
Act or Regulations
Relevant Provisions
Ancient Monuments
and Archaeological
Areas Act 1979
It is a criminal offence to carry out any works on or near
to a Scheduled Monument without Scheduled Monument
Consent (SMC)
Treasure Act 1996
The act defines what constitutes Treasure and states that
any finds of treasure and objects found in association
with treasure must be reported to the local coroner
Planning (Listed
Buildings and
Conservation Areas)
Act 1990
No works can be carried out in relation to a Listed
building without consent. Designation of an area as a
Conservation Area introduces general controls over
demolition and development
The act establishes principles of the development control
process
Burial Act 1857
Under section 25 of the 1857 act, it is generally a criminal
offence to remove human remains from any place of
burial without an appropriate licence issued by the
Ministry of Justice (MoJ), although recent legislative
changes indicate that some cases are exempt from this
requirement
201
A local authority can prohibit the removal of an ‘important’
hedgerow. Hedgerows can be considered important on
grounds of historical or archaeological value or
association
Hedgerow
Regulations 1997
9.4
Table 9.2 summarises the relevant non-statutory protection relating to the historic
environment.
Table 9.2: Non-Statutory Protection of the Historic Environment
Policy or Legislation
Relevant Provisions
National Planning
Policy Framework
(NPPF), Section 12
Section 12 of the NPPF outlines government policy on
the treatment of ‘heritage assets’ (including Scheduled
Monuments, Listed buildings, Conservation Areas,
World Heritage Sites, Historic Parks and Gardens and
Historic Battlefields, but also non-Scheduled sites,
including buried or suspected buried remains), within
the local plan and development control process.
Register of Parks and
Gardens of Special
Historic Interest
The Register identifies important Historic Parks and
Gardens, which should then be considered by the local
planning authority in accordance with NPPF.
Register of Historic
Battlefields
The Register identifies important battlefield sites, which
should then be considered by the local planning
authority in accordance with Section 12 of the NPPF.
Local
9.5
The Proposed Development falls within the administrative districts of both Thanet
District Council and Dover District Council. Policies with regard to the safeguarding
of heritage relevant to the current proposals (HE11, HE 12) have been saved from
the Thanet District Local Plan (2006) and described in Table 9.3. Dover District’s
Core Strategy (2010) does not contain policies specific to the historic environment,
but instead, refers to relevant regional and national policies (Section 12 of NPPF,
see Table 9.2).
Table 9.3: Thanet District Local Plan – Historic Environment Policies
Policy
Relevant Issues
Policy HE11
Archaeological
Assessment
In order to determine planning applications, the district
Council may require the developer/applicant to provide
additional information, in the form of an assessment of the
archaeological or historic importance of the site in question
and the likely impact of development. In certain cases such
assessment may involve fieldwork or an evaluation
excavation. (…) Planning permission will be refused
202
Policy HE12
Archaeological
Sites and
Preservation
Archaeological sites will be preserved and protected on those
archaeological sites where permanent preservation is not
warranted, planning permission will only be granted if
arrangements have been made by the developer to ensure
that time and resources are available to allow satisfactory
archaeological investigation and recording by an approved
archaeological body to take place, in advance or during
development. No work shall take place until the specification
and programme of work for archaeological investigation,
including its relationship to the programme of development,
has been submitted and approved.
Method
9.6
The archaeological assessment was undertaken by an Institute for Archaeologist
(IfA) qualified practitioner in accordance with the IfA Code of Conduct 2010, as well
as with current best practice (as described in English Heritage’s Management of
Research Projects in the Historic Environment (MoRPHE) Planning Notes, 2008).
9.7
Relevant IfA guidelines were consulted which included IfA, 2010: Standard and
Guidance for Archaeological Desk-Based Assessment and English Heritage. 2008:
Conservation Principles. Field observations were conducted in line with the IfA’s
Guidelines for Archaeological Field Evaluation (revised 2009).
Desk-Based Assessment
9.8
Section 2 of the Baseline Report (see Appendix 9.1) details the full data collection
method. A summary of the method is provided below.
Data Sources
9.9
Cultural heritage data was collected from the following sources for two Study Areas
(Study Area A and Study Area B):







National Monument Record (NMR);
Kent Historic Environment Record (KHER);
Superseded Ordnance Survey (OS) mapping;
Relevant secondary sources (including online sources);
Other specialist reports prepared for this assessment;
Field observations; and
Wessex Archaeology Marine Archaeological Environmental
Assessment Report (2010).
Impact
Study Areas
9.10
The two study areas were defined as:

Study Area A: This is centred on the application boundary with an additional
buffer of approximately 1.5km (Figure 9.1). This has been defined in order to
identify known and potential unknown heritage assets within or close to the
development site upon which physical impacts could potentially occur. The
buffer zone includes the intertidal zone between the landfall and low water
203
mark. Data for this area has been summarised from information provided in the
marine archaeological report produced by Wessex Archaeology (2010) which is
being submitted as part of the Marine Application. An assessment of heritage
assets within the intertidal zone has been included within this chapter.

Study Area B: This has been defined in order to identify designated heritage
assets within a wider study area based on a Zone of Visual Influence (ZVI) to a
maximum radius of circa 10km (Figure 9.2) within which visual impacts of the
above ground elements of the Proposed Development i.e. the converter station
and substation, could potentially occur.
9.11
For the determination of visual (indirect) impacts, World Heritage Sites, Scheduled
Monuments (SMs), Grade I and Grade II* Listed Buildings (LBs), Historic
Battlefields, and Registered Parks and Gardens (RPGs) in Study Area B. Potential
effects on long views from or including these heritage assets can be significant
depending on their location, elevation, landscape scale and intervisibility. Visual
impacts on Grade II LBs and conservation areas (CAs) were assessed for a 3km
maximum study area, as long-views are not likely to contribute towards the
significance of such designated assets.
9.12
Heritage asset information, including current status and an initial assessment of
asset importance/sensitivity, was compiled into two gazetteers which are within
Appendix 1 and 2 of the Baseline Report (Appendix 9.1).
Field Observations
9.13
A site visit was undertaken by a qualified RSK archaeologist on 24th April 2012 and
photographs and site notes were taken and maps sketch annotated as appropriate.
The current state of preservation was recorded for areas of known archaeology as
highlighted through previously gathered desk-based sources, and the potential for
hitherto unknown heritage assets assessed.
9.14
A visual assessment of the setting of designated heritage assets potentially subject
to visual impact was also undertaken on 24th April 2012. Heritage assets were
assessed in terms of ·intended sight-lines and/or intervisibility with
contemporaneous heritage assets; views towards, from and within heritage assets
as relevant; landscape situation; dominance or prominence; the degree of alteration
to historic cultural landscapes; and the anticipated scale of proposals in relation to
the heritage assets. Photographs and site notes were taken and maps sketch
annotated as appropriate.
Assessment of Significance
9.15
The assessment of the significance of potential impacts on heritage asset was
determined by comparing the relative receptor importance/sensitivity with the
anticipated magnitude of effect.
Receptor Importance
9.16
The importance of each heritage asset (receptor) within the gazetteers has been
determined to provide a framework for comparison. The categories of importance
do not reflect a definitive level of importance or value of an asset, but a provisional
one based on criteria such as evidential, historical, aesthetic and communal values,
as outlined in English Heritage’s Conservation Principles (2008). Consideration
combining the four value sets offers representation of the importance of a given
204
heritage asset and provides an analytical tool that can inform later stages of
archaeological assessment and the development of appropriate mitigation
strategies.
Table 9.4: Criteria Determining Relative Receptor Importance
Receptor
importance
Description
Very high
(international)
World Heritage sites (including nominated sites)
Scheduled Monuments and Grade I listed buildings of
acknowledged international importance
Assets that can contribute significantly to acknowledged
international research objectives
High
(national)
Scheduled Monuments, listed buildings and conservation
areas
Assets that can contribute significantly to acknowledged
national research objectives
Medium
(regional)
Undesignated heritage assets that contribute to regional
research objectives
Low
(local)
Assets compromised by poor preservation and/or poor
survival of contextual associations
Assets of limited value, but with potential to contribute to local
research objectives
Negligible
(minor)
Assets with very little or no surviving archaeological interest
Unknown
The importance of the resource is not currently known
Effect Magnitude
9.17
The magnitude of impacts has been assessed according to the scale set out below:
Table 9.5: Definitions of Magnitude
Level of
Magnitude
Definition of Magnitude
Major
Total loss or substantial harm to important elements, or features
or characteristics of the baseline (pre-development) conditions
such that post development character or composition or
attributes of baseline will be fundamentally changed.
Moderate
Partial loss or harm to one or more important elements or
features or characteristics of the baseline (pre-development)
conditions such that post development character or composition
or attributes of baseline will be partially changed.
Minor
Minor loss. Change arising from the loss or alteration will be
discernible but underlying character or composition or attributes
of the baseline condition will be similar to pre-development
circumstances or patterns.
205
No Change
No loss or alteration. Change not distinguishable.
Unknown
The exact location, extent or nature of the baseline receptor is
not known and therefore the magnitude of change cannot be
discerned.
9.18
The potential physical (direct) impacts of the Proposed Development on the
heritage resource have been assessed by comparing the land-take and
construction methodology against the location, nature and vulnerability of each
known heritage asset.
9.19
With regard to indirect impacts, initial screening was implemented through
comparison with the ZVI and subsequently through consideration of each receptor’s
proximity, intervisibility, and sensitivity in relation to the development area. Visual
verification of the assessment results were subsequently undertaken by means of
site visits to those receptors identified as the most vulnerable to visual impacts.
Significance of Potential Impacts
9.20
The significance of potential direct and indirect impacts has been assessed by
examining the importance of each known receptor in relation to the anticipated
impact magnitude upon it, and quantified according to the criteria in Table 9.6.
Table 9.6: Significance of Impacts Matrix
Magnitude
Receptor Importance
Very High
High
Medium
Low
Negligible
Unknown
Major
Very
significant
Very
significant
Significant
Low
Negligible
Unknown
Moderate
Very
significant
Significant
Moderate
Low
Negligible
Unknown
Minor
Moderate
Moderate
Low
Negligible
Negligible/
none
Unknown
No Change
None
None
None
None
None
None
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
9.21
For the purposes of this assessment, impact significance is addressed as follows:



Very significant and significant impacts would be considered equivalent to
‘substantial harm to’ or the ‘total loss of significance of’ a heritage asset (as
defined in NPPF [para 132-4]);
Moderate impacts, whilst harmful, are not significant or substantial; and
Low and Negligible impacts are not significant or substantial.
Limitations of the Assessment
9.22
Generally, information held by public data sources is considered to be reliable
however certain limitations, common to any baseline report, should be borne in
mind:
206





9.23
Any HER can be limited because it depends on opportunities for research,
fieldwork and discovery. There can often be a lack of dating evidence for
heritage assets (specifically archaeological sites);
Documentary sources are rare before the medieval period, and many historic
documents are inherently biased;
Primary sources, especially older records, often fail to accurately locate
heritage assets and can be subjective in any interpretation;
By its nature, field reconnaissance survey (FRS) can only identify evidence of
buried archaeological remains with an above-ground signature - other buried
remains may exist; and
Assessments for indirect impacts are conditioned by the time of day, weather
and seasonal conditions of the survey.
The limitations of any impact assessment include:


The lack of clarity surrounding the extent of some heritage assets which makes
it difficult to provide a precise assessment of potential impact; and
The possibility that unknown heritage assets will be encountered during
construction.
Existing Environment
9.24
The Isle of Thanet is situated on a promontory forming the easternmost part of Kent
within a coastal region that has undergone significant landform changes in the past,
which would have influenced occupation and landuse throughout all periods. The
most significant change in this respect is the silting up of the Wantsum Channel,
which had rendered Thanet an island off the mainland coast from the end of the last
ice age (c. 12,000 years ago) until the medieval period (14th century).
9.25
The land generally slopes westwards from the chalk cliffs along the North Sea coast
and southwards to the low lying marshland around Pegwell Bay. The south side of
the Isle of Thanet features three low lying hills rising out of a flat plain of alluvium,
including Ebbsfleet Hill and Cottington Hill. These hills formed a low peninsula
known as the Ebbsfleet peninsula during the times that the Wantsum was open and
navigable. The sides of the Ebbsfleet peninsula to the east and the west formed two
natural havens for cross Channel sea traffic in the past, which reflects its historic
significance as a landing place for the Saxons in the 5th century AD and St
Augustine in the 6th century AD.
9.26
An outline of the archaeological and historic development of the region over time is
included in Section 3.2 of Appendix 9.1.
Known Heritage Resource – Study Area A
9.27
From the data sources outlined above, seven designated and 158 non-designated
heritage assets were recorded.
9.28
All entries are described in full in the sites gazetteer for Study Area A contained in
the Baseline Report (Appendix 9.1) and shown on Figure 9.1. All heritage assets
are referred to only in summary form in the discussions below.
9.29
There are no Scheduled Monuments, World Heritage Sites, Registered Parks and
Gardens or Registered Battlefields within Study Area A.
207
Receptors of High Importance
9.30
There are seven receptors of high importance in Study Area A: one Grade II* Listed
building (RSK D1) and six Grade II Listed buildings (RSK D2-7).
Receptors of Medium Importance
9.31
Twenty-eight non-designated receptors are of a medium importance (RSK 1-2, 4, 68, 12-13, 15-16, 78-79-83, 87-88, 91-97, 141, LIN 1-3). These mostly comprise
archaeological occupation and burial sites, often featuring multiple periods,
recorded as part of modern development control regimes and focussed on the highlying areas of the Ebbsfleet peninsula. Several prehistoric ‘founders’ hoards (RSK
6, 7, 12) are also known. In the light of the significance of the development of the
landscape in relation to the coastline and rivers, medieval sea defences (RSK 96,
97, LIN 1-2) and a transport route of that period (RSK LIN 3) are also included in
this category.
Receptors of Low Importance
9.32
One hundred and twenty one non-designated receptors in Study Area A are of low
importance (RSK 3, 5, 9-11, 14, 17-77, 84-86, 89, 92, 98-101, 103-108, 111-131,
133-135, 137-140, IZ1-2). These can be broadly divided into prehistoric and early
historic (medieval) individual finds or isolated features (RSK 3, 5, 9, 10, 11, 14, 17,
18-77, 88, 92, 98, 100,101, 103, 104, 105, 110); historically attested sites or those
with a traditional association (such as the landing site of the Saxons at Ebbsfleet),
RSK 89 & 99; a large number of military installations (or their former sites) from the
two world wars (RSK 113-118, 122-125, 129, 131-135, 137-138, 140); and sites
related to the industrial development of the landscape in the post-medieval and
modern periods, RSK 106-108, 111, 119-121, 127-128, 130, 139, LIN 4-7); as well
as those related to general rural living (RSK HM2-5).
9.33
Two of these receptors, IZ1 and IZ2, identified by Wessex Archaeology (2010), are
in the intertidal zone between the TJP and low water mark. Both are of low
importance. RSK IZ1 is the findspot of a Roman cup considered a chance
overboard loss and RSK IZ2 is a section of medieval wall function situated near the
coast at Cliffs End. Both records have uncertain locational data.
Receptors of Negligible Importance
9.34
There are five non-designated receptors of negligible importance (RSK 90, 109,
132, 136, HM1) in Study Area A; these are all now demolished sites of a postmedieval and modern date for which no significant below ground remains are
anticipated.
Receptors of Unknown Importance
9.35
There are four non-designated receptors of unknown importance (RSK 102, 142144). These include two suspected archaeological sites identified from aerial
photographic evidence (RSK 143-144), one site with an inconsistent KHER entry
(RSK 102), and one poorly provenanced site of graves recorded at Weatherlees
during the installation of WWII defences (RSK 142).
208
Historic Map Regression
9.36
Superseded OS mapping provided by Envirocheck at 1:10,560/1:10,000 (including
a 100m buffer around the proposal area) and 1:2500 scale maps were also
consulted as part of the assessment.
9.37
Historic map regression shows a rural landscape that has experienced limited
episodic and localised changes from post-medieval and modern industries, the
development of transport infrastructure, and residential development, which leaves
much of the historic structure and character of the landscape intact, if fragmented.
Historic map regression enabled the tracing of changes to the coastline, its sea
defences and associated installations over the recorded period. With respect to the
current proposals, the most notable change is the recording of alignments of a
former coastal or riverine seawall predating the late 19th century (RSK HM5) in
relation to the still partially extant Boarded Groyne (RSK LIN2). The latter is thought
to date from the 14th century. This suggests the cable route lies within an area of
land most likely reclaimed in post-medieval times.
Aerial Photographic Evidence
9.38
The majority of the application boundary lies in an area of reclaimed coastal and
marshland. Where archaeological deposits are present in such areas, these are
likely to lie buried deeply and cannot normally be detected through aerial
photographic examination.
Historic Landscape Characterisation
9.39
Historic Landscape Characterisation has been undertaken by Kent County Council
(2004). The two Study Areas fall mainly within two landscape character areas as
defined by the assessment, namely Thanet to the north and Wantsum and the
Lower Stour Marshes to the south. The limits of each area are distinctly defined by
the southern coastline of the former island (Figures 9.1 and 9.2). The application
boundary falls entirely within the Wantsum and Lower Stour Marshes character
area.
9.40
Thanet’s island quality is preserved by the way it rises out of the marshes to a
modest height of approximately 50m AOD. Its landscape divides into two distinct
areas, a flat plateau and the slope along the chalk outlier to the marshes at the
south and west. With the exception of the urban conurbation of Ramsgate-MargateBroadstairs, settlements are generally nucleic and centre on former mills and ports
or ferry landings at the edge of the former Wantsum Channel. Two of the main
characteristics of the historic landscape character are the long views to and from
the former island across the marshland and its open, unenclosed nature in general,
which is partly the result of a historic lack of vegetation. A sense of place in Thanet
is very strong, in part due to its persistent island quality where historic and ancient
characteristics associated with settlements and road patterns, farming and cultural
use all survive. Thanet is a landscape with a high sensitivity to visual change. The
coherence of the landscape character has already been denuded in the past,
rendering Thanet’s landscape character in need of restoration.
9.41
The marshlands around the north-east Kent coast are the reclaimed and silted up
course of the Wantsum Channel and the former mouth of the River Stour. The land
was originally reclaimed as summer pasture for sheep with much of this work being
209
undertaken by wealthy ecclesiastical estates in the area. There is also historic
evidence for former salt production. There is no settlement within the marsh, and
the road network derives its character from former crossing places and drove roads.
The marshes’ main characteristics form a flat and open landscape with long views
and isolated stretches of farmland crossed by drainage channels. It has reasonable
coherence as a reclaimed marsh in visual terms, however of poor cultural integrity
and with a weak and indistinct sense of place. Sensitivity to visual changes is high
due to the open nature of the historic landscape, and it has been concluded that
new road patterns and land-use has resulted in a denudation of the landscape
character, leaving a need to restore and create.
Site Visit
9.42
The site visit confirmed that the majority of the cable route is within low-lying
reclaimed coastal land. No surface indicator for RSK LIN 1, 125, HM1, 140 or 116
was identified. The subsurface preservation level is unknown.
Archaeological Potential
9.43
The island of Thanet has a rich archaeological and historic resource, and this is
reflected in the high number of sites contained in Study Area A. However, with the
exception of earlier historic sea defences, or later historic sites related to modern
warfare and agriculture, these are exclusively contained within the limits of the
former island, and the changes of the palaeo-environment over time are important
for the assessment of the archaeological potential of the Proposed Development
area in particular. The cable route and converter and substation site lie entirely
within the limits of the former Wantsum Channel as delineated by the HLC
character areas and therefore within land reclaimed since the medieval period. The
majority of the cable route lies outside a late historic sea wall recorded on the 1877
1st edition OS map, and therefore in land reclaimed in the post-medieval period.
9.44
The Wantsum Channel was formed at the end of the last Ice Age about 12,000
years ago from melting waters from the shrinking ice caps and glaciers that made
sea levels rise. Prior to this time, the area of the channel would have been part of
the mainland landmass and there is therefore an unconfirmed potential for the
presence of archaeological artefacts and palaeo-environmental evidence from the
Pleistocene period below the later channel silts. Such horizons are likely to be at
considerable depth.
9.45
The Channel was a navigational route from later prehistoric times and given the
known prehistoric, Roman and Saxon assets on the adjoining dry land areas it is
possible that evidence for its use and the use of the marginal areas will survive in
subsurface deposits. After reclamation, the proposal site would have been
peripheral marshland, most likely used as grazing land, with little potential for any
significant archaeological remains.
9.46
In summary, it is considered that between the landfall and the converter station,
there is an unproven potential for deposits of archaeological interest at depth from
the very early (Pleistocene) prehistoric period (500,000-12,000 years ago), that
there is a negligible potential for archaeological remains from all (Holocene)
prehistoric periods, and medium potential for the later prehistoric, Roman and
earliest historic periods. The potential for significant remains from all later historic
periods from the medieval period onwards is considered low.
210
Known Heritage Resource – Study Area B
9.47
In line with the method outlined above, all higher-grade designated heritage asset
(Scheduled Monuments, Grade I and II* Listings) were plotted within the ZVI of the
above ground elements of the development to a maximum distance of 10km, whilst
the plotting of Grade II listed buildings and conservation areas was limited to 3km
(Figure 9.2).
9.48
Eleven of the designated heritage assets fall within the ZVI (RSK V1-11). The
distance of separation between the converter station and substation site and these
assets is over 1.6km.
9.49
Heritage assets with the highest sensitivity to visual impact are Richborough Castle,
RSK V3, and the archaeological remains within it, RSK V1. These have a shared
history and form one historic complex approximately 2km south of the proposed
converter and substation site.
9.50
The significance of the archaeological and historic complex at Richborough Castle
is equally shared between its evidential, historic, aesthetic and communal values,
all of which are high. This is reflected in its designation as a Scheduled Monument
and its Grade I Listing, as well as its status as a tourist attraction. The site
represents an important event in relation to the Roman occupation of Britain, and
has a strategic relationship with the landscape it is situated within. The historic
complex provides a prominent visible link with the modern as well as the former
landscape, and with events of national importance having taken place within it.
Views related to these heritage assets, particularly their imposing upstanding
remains, are a fundamental part of the significance of this important group of
assets.
Prediction and Assessment of Significance of Potential Impacts
Construction
General Direct Impacts (Study Area A)
9.51
The onshore underground cables will be buried for their entire length between the
low water mark and the proposed converter station and substation site. Installation
by means of open trenching will involve the excavation of a 1.2m wide by 1m deep
trench within a working width of 5-10m, and a permanent easement of 5m.
Horizontal Directional Drilling (HDD) will be used between the BayPoint sports
complex and Richborough Power Station site. The following construction activities
have the potential to impact on archaeological and cultural heritage remains:






Preparatory groundworks of the working width associated with cables
installation;
Trench excavation;
Excavation of HDD launch and receptor pits and transition joint pit (TJP);
Site clearance at the proposed converter station and substation site, including
demolition of the cooling tower bases;
Foundation installation for the converter station and substation; and
Reinstatement and landscaping.
211
Site-Specific Direct Impacts (Study Area A)
9.52
The majority of the heritage assets within Study Area A are sufficiently distant from
the onshore elements of the Proposed Development so as not to be directly
affected through the construction programme. The thirteen assets potentially
affected during construction are shown in Table 9.7.
Table 9.7: Site-Specific Direct Impacts
Site
ID
Description
Importance
Magnitude
of Effect
Significance
of Effect
Proposed
Further
Assessment
or
Mitigation
96
14 century sea wall
(site of)
Medium
No Change
None
None
116
WWII pillbox (site of)
Low
No Change
None
None
119
Richborough power
station (disused)
Low
Major
Low
Record
during
construction
phase
watching
brief
125
RAF salvage yard
(site of)
Low
Minor
Negligible
None
130
1960s sculpture (site
of)
Low
No Change
None
None
140
WWII pillbox (site of)
Low
No Change
None
None
HM1
Post-medieval
coastguard station
(site of)
Low
Major
Low
Record
during
constructionphase
watching
brief
HM2
Ebbfleet House
(post-medieval
dwelling)
Low
No Change
None
None
HM3
Stonelees House
(post-medieval
dwelling)
Low
No Change
None
None
HM5
Seawall observed on
st
1 edition OS map
(site of)
Low
No Change
None
None
th
212
LIN 2
Boarded Groyne
th
(14 century, partially
extant), survival
within converter
station site
boundary/cable route
destroyed through
modern development
Medium
No Change
None
None
LIN 7
East Kent Railway
Low
No Change
None
None
IZ1
Recovery of Roman
cup from dredging
Low
No Change
None
None
Archaeological Potential
9.53
Artefacts and palaeo-environmental deposits of a Palaeolithic date (i.e. pre-dating
the Wantsum Channel) may be present at considerable depth below channel silts
so there is some potential for deep excavations, such as the HDD launch and
receptor pits, to reach such remains. The development site is situated in reclaimed
land within the former Wantsum Channel which was navigable throughout the later
prehistoric periods and onwards. The archaeological potential for the later
prehistoric, Roman and earliest historic periods is considered medium, and low for
significant remains from all later historic periods.
9.54
Following reclamation, the development area would have been utilised as grazing
marshland, and archaeological and cultural heritage remains related to these
activities, where present, are likely to be of a negligible or low value.
Indirect Impacts (Study Areas A and B)
9.55
Visual and indirect effects to the settings of designated heritage assets may arise
during the construction phase. These effects are predicted to be temporary, shortterm, and minimal in magnitude and significance. An assessment of the effects on
specific heritage assets of the presence of the converter station and substation
during operation is presented below.
Operation
Direct Impacts (Study Area A)
9.56
It is not anticipated that the operation of the interconnector will have any impact on
buried archaeology.
9.57
Repairs and refurbishment of the underground cables, converter station and
substation are anticipated to be above ground or to affect areas where the ground
has already been disturbed, investigated and mitigated during construction.
Consequently, no effects on buried archaeology are anticipated during the
operational phases of the Proposed Development.
General Indirect Impacts (Study Area B)
9.58
The operational phase of the Proposed Development could result in an on-going
effect on the setting of heritage assets and historic landscape character.
213
Site-Specific Indirect Impacts (Study Area B)
9.59
The ZVI indicates that the above ground elements of the Proposed Development
potentially affect the setting of 11 designated heritage assets. An assessment has
been made to determine the magnitude of change that the Proposed Development
could have on these assets, in terms of loss of significance through development
within their setting. The results are summarised in Table 9.8 below:
Table 9.8: Site-Specific Indirect Impacts
Site
ID
Description
Receptor
Importance
Magnitude
of Effect
Significance
of Effect
Proposed
Further
Assessment
or Mitigation
V1
Richborough Castle–
Saxon shore fort
(archaeological remains)
SCHEDULED
MONUMENT
Very High
No Change
None
None
V2
Anglo-Saxon cemetery at
Ozengell Grange
SCHEDULED
MONUMENT
High
No Change
None
None
V3
Richborough Castle
GRADE I LISTED
BUILDING
Very High
No Change
None
None
V4
Paramour Grange
GRADE II* LB
High
No Change
None
None
V5
Stourmouth House
GRADE II* LB
High
No Change
None
None
Richborough Farm
GRADE II LB
High
No Change
None
None
V7
Guston Court
GRADE II LB
High
No Change
None
None
V8
Kings End Farmhouse
GRADE II LB
High
No Change
None
None
V9
Mulberry House
GRADE II LB
High
No Change
None
None
V10
Stables about 5m SW of
Guston Court
GRADE II LB
High
No Change
None
None
V11
Castle Farm
GRADE II LB
High
No Change
None
None
V6
9.60
The setting of Richborough Castle including the proposed location of the substation
and converter station makes a positive contribution to the significance of the
upstanding remains of the heritage asset. However, the visual baseline situation to
the east and north east of Richborough Castle comprises ‘Industrial complexes and
factories’ (Ref. Kent HLC) including the site of the former Richborough power
214
station; the proposed converter station and substation would be located on the site
of the former turbine hall and cooling towers of the former Richborough power
station. The impact upon the setting of Richborough Castle from the Proposed
Development would not cause any greater harm than the baseline situation. The
magnitude of change is therefore Negligible and the significance of effect is None.
9.61
For the other designated heritage assets within the ZVI of the proposed converter
station and substation, the contribution made by that part of their setting affected by
the Proposed Development is negligible or neutral. Consequently, and also for the
reasons outlined above in relation to Richborough Castle, there will be no loss of
significance as a result of the Proposed Development and the significance of effect
is None.
9.62
The historic landscape character of the site of the proposed converter station and
substation is recorded by Kent County Council as ‘modern industrial’. The addition
of modern infrastructure to the former power station site will have a neutral effect on
the historic landscape character of the site and surrounding area.
Mitigation Strategy
Physical Impacts
9.63
No significant impacts on heritage assets are predicted. However, through
consultation with the Principal Archaeological Officer at Kent County Council (KCC,
S. Mason, 26th July 2012), mitigation with regard to cables installation via open
trenching is proposed for predicted impacts to the post-medieval coastguard station
(RSK HM1) and Richborough Power Station (disused) (RSK 119) in the form of a
watching brief during construction works.
9.64
A watching brief will also be maintained during the cable installation to ensure that
any previously unrecorded archaeological remains are identified and recorded
during groundworks.
9.65
In addition, a watching brief with regard to Pleistocene and Palaeolithic remains will
be undertaken during any deep excavations (i.e. excavations beyond the modern
overburden) related to the scheme. Both phases of the watching brief would be
undertaken in line with a Written Scheme of Investigation agreed with KCC in
advance of the fieldwork, and followed by a programme of analysis and reporting
also to be agreed with and delivered with KCC.
Indirect (Visual) Impacts
9.66
The assessment has concluded that the development of the substation and
converter station will not result in any loss of significance to designated heritage
assets through development within their setting. Consequently, no mitigation is
proposed in relation to designated heritage assets.
Residual Impacts
9.67
It is anticipated that after the programme of archaeological mitigation has been
implemented, the archaeological and cultural heritage resource within and close to
the development area will remain unaffected and the overall residual impact of the
scheme is therefore neutral.
215
Cumulative Impacts
9.68
Potential cumulative effects on archaeology and cultural heritage from the onshore
elements of the Nemo Link in combination with other components of the Project (i.e.
UK, French and Belgian subsea cables and Belgian onshore infrastructure) are
described in Chapter 16.
9.69
Potential cumulative effects of the Nemo Link UK onshore infrastructure in
combination with the grid connection required to facilitate the operation of the Nemo
Link are described in Chapter 17.
9.70
There is the potential for cumulative effects to arise during the construction and
operation phase of the proposed works due to the construction and operation of
other developments as detailed in Table 1.2.
Direct Impacts
9.71
Richborough Energy Park will be constructed on the former power station site.
Mitigation has been proposed and agreed with Kent County Council in relation to
the adverse effects of these works on the former power station site. On completion
of an appropriate programme of archaeological mitigation in relation to both
proposed developments, effects on buried archaeology will be neutral and no direct
cumulative impacts on the historic environment are predicted as a result of these
developments.
9.72
Similarly, for other developments within the cable route corridor, the individual
effects of each development on previously unknown buried archaeology can be
mitigated. On completion of an appropriate programme of archaeological mitigation
in relation to each proposed development and the installation of the cables, effects
on buried archaeology will be neutral and no direct cumulative impacts on the
historic environment are predicted as a result of these developments.
Indirect Impacts
9.73
This assessment concludes that the construction of the converter station and
substation will not result in any harm to the historic environment through historic
landscape impacts or development within the setting of a heritage asset. Therefore
the Proposed Development will not contribute to any cumulative effects on the
historic environment in combination with other proposed developments.
216
217
218
10.0
LANDSCAPE AND VISUAL EFFECTS
Introduction
10.1
This chapter assesses the anticipated effects on landscape and views of the
Proposed Development (i.e. the converter station and substation at the former
Richborough Power Station site and the underground and overground cable
connection between Pegwell Bay and the converter station and substation site). It
provides a description of the landscape in which the development is proposed and
includes reference to published landscape assessments relating to the general
locality, before considering the anticipated effects of the Proposed Development on
landscape character during construction and on completion. It describes the nature
of existing views and includes a prediction of the visual effects of the Proposed
Development during construction and operation.
10.2
The converter station will comprise a principal building which will re-use the derelict
steel frame structure of the existing former turbine hall. This part of the building will
extend to the existing height of the steel frame, at approximately 30.8m. The
converter station building would also be extended to the north (by approximately
65m) with a maximum height of 25m; a further building extension approximately
45m in length and 18m high. The outdoor equipment associated with the converter
station would be a maximum height of 12m and would be constructed to the north of
the building. The proposed 400kV substation to the northwest of the converter
station would consist of outdoor electrical equipment, with a centrally located
building containing gas insulated switchgear (GIS) at a maximum height of 15m.
The maximum height of the outdoor electrical equipment within the substation will
be 13m. Colour graded cladding is proposed to the converter station building,
ranging from a muted green at the building’s base to off-white at the roofline. Due
to its lower height the substation building will be clad in a single colour (muted
green). External lighting to the converter station and substation site will be required
for safety and security purposes (for maintenance purposes, in emergencies and
triggered by intruder detection) but will be kept to the absolute minimum necessary.
A 1.6 hectare temporary lay-down area for materials and plant will be located to the
immediate west of the substation during the construction period. This temporary
area will also be on land which was part of the former power station and now forms
part of the Richborough Energy Park. Refer to Chapter 2 for a full description of the
Proposed Development.
10.3
This landscape and visual impact assessment also considers the effects of the
subsea underground cable connection between the low water mark and the
Transition Joint Pit (TJP) at Pegwell Bay and the onshore underground and
overground cable connection between the TJP at Pegwell Bay and the converter
station and substation site. Refer to Chapter 2 for a description of the Proposed
Development.
Planning Policy Context
10.4
Chapter 4 includes a review of National, Regional and Local Planning Policy
relevant to the site and the surrounding area. The following paragraphs summarise
planning policy relevant to landscape and views.
219
National Planning Policy Framework, March 2012
10.5
The following aspects of the National Planning Policy Framework (NPPF) are
applicable to the Proposed Development and relevant to landscape character and
visual amenity.
7. Requiring Good Design
10.6
The Government emphasises the importance of the design of the built environment.
The NPPF outlines that good design is a key aspect of sustainable development
and should contribute to making places better for people. The NPPF lists qualities
that developments should achieve, including:






10.7
Functions well and add to the overall quality of the area;
Establishes a strong sense of place;
Optimises the potential of the site to accommodate development;
Responds to local character and history, and reflects the identity of local
surroundings and materials, whilst not preventing or discouraging appropriate
innovation;
Creates safe and accessible environments; and
Is visually attractive as a result of good architecture and appropriate
landscaping.
The NPPF emphasises the importance of applicants working closely with those
directly affected by proposals to evolve designs and take account of the views of
the community.
11. Conserving and Enhancing the Natural Environment
10.8
The NPPF identifies the importance for developments to enhance the natural and
local environment by protecting and enhancing valued landscapes, geological
conservation interests and soils, recognising the wider benefits of ecosystems,
minimising the impacts on biodiversity and increasing the net gains in biodiversity,
and preventing risk from unacceptable levels of effects on soil, air, water, noise
pollution and land instability.
Regional Planning Policy
The South East Plan: Regional Spatial Strategy for the South East of England, May
2009
10.9
At the time of writing, the South East Plan continues to be a material consideration
in the planning process although relatively little weight should be given to the
policies it contains. RSS policies relevant to landscape character and visual
amenity are identified and briefly discussed below. RSS policies below are
discussed further in Chapter 4.

Policy CC6: Sustainable Communities and Character of the Environment
Policy CC6 states that ‘actions and decisions associated with the development and
use of land will actively promote the creation of sustainable and distinctive
communities. This will be achieved by developing and implementing a local shared
vision which ‘respects, and where appropriate enhances, the character and
distinctiveness of settlements and landscapes throughout the region, and uses
220
innovative design processes to create a high quality built environment which
promotes a sense of place. This will include consideration of accessibility, social
inclusion, the need for environmentally sensitive development and crime reduction’.
The South East is described in Policy CC6 as having a ‘high quality environment
with a rich heritage of historic buildings, landscapes and habitats’.

Policy C4: Landscape and Countryside Management
Policy C4 states that ‘outside nationally designated landscapes, positive and high
quality management of the region’s open countryside will be encouraged and
supported by local authorities and other organisations, agencies, land managers,
the private sector and local communities, through a combination of planning
policies, grant aid and other measures. In particular, planning authorities and other
agencies in their plans and programmes should recognise, and aim to protect and
enhance, the diversity and local distinctiveness of the region’s landscape, informed
by landscape character assessment’.
Policy C4 requires that ‘Local authorities should develop criteria-based policies to
ensure that all development respects and enhances local landscape character,
securing appropriate mitigation where damage to local landscape character cannot
be avoided’.

Policy C6: Countryside Access and Rights of Way Management
This policy requires that local authorities should encourage access to the
countryside, particularly by maintaining, enhancing and promoting the Public Rights
of Way system, and permissive and longer distance routes.

Policy BE6: Management of the Historic Environment
Policy BE6 encourages local authorities and other bodies to ‘adopt policies and
support proposals which protect, conserve and, where appropriate, enhance the
historic environment and the contribution it makes to local and regional
distinctiveness and sense of place. The region's internationally and nationally
designated historic assets should receive the highest level of protection’.
The RSS qualifies that ‘The historic environment includes the physical evidence of
past human activity’. ‘It is not limited to the built environment and archaeological
sites, but includes landscapes, both urban and rural and as an example of its great
diversity, marine heritage sites around the coast. These environments are fragile
and require protection’.
Local Planning Policy
Thanet District Council and Dover District Council
10.10
The application site falls within two administrative boundaries; Thanet District
Council and Dover District Council. The application site is predominantly in Thanet
District, although part of the eastern edge of the converter station and substation
site and a small section of the underground cable route fall within Dover District.
10.11
The saved planning policies of the Thanet Local Plan relevant to landscape
character and visual amenity and the Proposed Development are detailed in ES
221
Chapter 4 (Planning Context) and the Planning Statement and illustrated where
possible on Figure 10.1. Relevant planning policies from the emerging Thanet
District Draft Core Strategy and the Dover Development Plan which incorporates
saved policies from the Local Plan and policies from the adopted Core Strategy
Development Plan Document have also been included.
Kent Design Guide 05/06 (December 2005)
10.12
Both Thanet and Dover District Councils have adopted the Kent Design Guide
prepared by Kent County Council. This guide emphasises the value of good design
and stresses the importance of respecting landscape context and character in new
development, stating that ‘the design of new developments should evolve from the
special local or Kentish character’.
Method
10.13
The assessment of landscape and visual effects has been undertaken in
accordance with the Guidelines for Landscape and Visual Assessment, Second
Edition (Landscape Institute/Institute of Environmental Management and
Assessment, 2002).
10.14
The baseline assessments were undertaken by Chartered Landscape Architects
from The Environment Partnership Limited (TEP) Limited, experienced in landscape
and visual assessment.
The assessment of landscape character included
consideration of published landscape assessments, map based information and
aerial photography together with a site survey. The visual assessment was
primarily undertaken through site visits to identify the visual receptors and to
experience the existing views. Site survey was undertaken for both assessments in
early August 2011 and late April 2012 when weather conditions were generally dry
with sunny spells, and visibility was good.
10.15
The study area used for the assessment of landscape and visual effects equates to
the Zone of Theoretical Visibility (ZTV) of the Proposed Development. The ZTV
defines the approximate area from which the existing site is visible and from which
the Proposed Development would be visible. This has been determined through a
combination of computer generated mapping, which has been subsequently refined
through desk-based study and field survey work taking into account the localised
screening effects of built form and vegetation (see Figure 10.2).
10.16
Consultation has taken place with the planning case officers at Thanet and Dover
District Councils, primarily to agree photomontage viewpoint locations. The agreed
photomontage viewpoint locations are shown at Figure 10.3; also included are
photograph viewpoint locations.
10.17
The methods of baseline assessment and the assessment of effects and
significance are described below.
Method for Landscape Character Assessment
10.18
Desk study and field survey were undertaken to identify the landscape features or
elements which form the key characteristics of the study area.
10.19
An evaluation was made of the importance or value of elements and character, the
condition or quality of the landscape and its capacity to accommodate change
without greatly affecting its character.
222
10.20
Landscape value assessment considers the relative value that is attached to
different landscapes. In a policy context the usual basis for recognising certain
highly valued landscapes is through the application of local or national designations.
In non-designated landscapes, assessment seeks to identify the value of the
landscape at a specific scale; identify the receptors to which it is important; and
identify why the landscape is important to them.
10.21
Landscape condition (or quality) is a factual description of the physical state of the
landscape, and about its intactness, from visual and functional perspectives.
10.22
Landscape sensitivity or capacity refers to the degree to which a landscape can
accommodate change without suffering detrimental effects on its character. This
sensitivity varies with:





Existing land use;
The pattern and scale of the landscape;
Visual enclosure/openness of views, and distribution of visual receptors;
The scope for mitigation, which would be in character with the existing
landscape (where appropriate); and
The value placed on the landscape.
10.23
The capacity of a landscape to accommodate change is generally expressed in
relation to specific types or nature of development and a specific type of
development generally needs to be known in order to determine the magnitude of
effect.
10.24
Magnitude considers the scale of effect (i.e. large/medium/small); its nature
(adverse or beneficial); and its duration (short, medium, long-term/permanent or
temporary). More weight is usually given to effects that are greater in scale and
permanent or long-term in duration. In assessing the duration of the effect,
consideration is given to the effectiveness of mitigation, particularly where planting
is proposed as part of the works which would change or reinforce landscape
character. The criteria for assessment of effects on landscape character are
outlined in Table 10.1 below.
223
Table 10.1: Criteria for Assessment of Magnitude of Effects on Landscape
Magnitude of
Effect
Typical Criteria
High
Total loss of or major alteration to key elements/features/
characteristics of the baseline i.e. pre-development landscape
or view and/or introduction of elements considered to be totally
uncharacteristic when set within the attributes of the receiving
landscape.
Moderate
Partial loss of or alteration to one or more key
elements/features/ characteristics of the baseline landscape or
view and /or introduction of elements that may be prominent but
may not necessarily be considered to be substantially
uncharacteristic when set within the attributes of the receiving
landscape.
Low
Minor loss or alteration to one or more key
elements/features/characteristics of the baseline landscape.
Introduction of elements that are generally characteristic with
the surrounding landscape.
Negligible
Very minor loss or alteration to one or more key
elements/features/ characteristics of the baseline landscape.
Introduction of elements characteristic with the surrounding
landscape – approximating to the ‘no change’ situation.
Source: LI/IEMA 2002, p145
Assessment of Significance
10.25
The significance of the effect of a development is not related to an absolute scale
but is a judgement based on the magnitude of the anticipated effect (or scale of
change), the importance or value of the landscape and the sensitivity or capacity of
the landscape to accommodate a specific development.
10.26
The significance of effect also considers the nature of the effect. Change can be
consistent with or can enhance the landscape. Conversely it may be at odds with
or harmful to the landscape’s key features or character. The significance of
landscape effects has been considered according to the criteria adapted from
examples given in LI/IEMA (2002) pp140 – 141, outlined below in Table 10.2 below.
224
Table 10.2: Guidance on Significance of Landscape Effects
Significance
Definition
Major adverse
A proposed scheme would result in effects that:
 cannot be fully mitigated and may cumulatively amount to
a severe adverse effect;
 are at a considerable variance to the landscape degrading
the integrity of the landscape;
 will be substantially damaging to a high quality landscape.
Moderate
adverse
A proposed scheme would:
 be out of scale with the landscape or at odds with the local
pattern and landform;
 leave an adverse impact on a landscape of recognised
quality.
A proposed scheme would:
Minor adverse
Neutral
 not quite fit into the landform and scale of the landscape;
 affect an area of recognised landscape character.
A proposed scheme would:
 complement the scale, landform and pattern of the
landscape;
 maintain existing landscape quality.
A proposed scheme has the potential to:
Minor beneficial
10.27
 improve the landscape quality and character;
 fit in with the scale, landform and pattern of the landscape;
 enable the restoration of valued characteristic features
partially lost through other land uses.
Moderate
beneficial
A proposed scheme would:
 fit very well with the landscape character;
 improve the quality of the landscape through removal of
damage caused by existing land uses.
Major beneficial
A proposed scheme would:
 enhance and redefine the landscape character in a
positive manner
 repair or restore landscape badly damaged or degraded
through previous uses
The significance of the effect of a development on the landscape is a judgement
based on the capacity of the landscape to accommodate change and the magnitude
of the anticipated effect.
Method for Visual Impact Assessment
10.28
The first stage in visual impact assessment is to establish the extent and nature of
existing views of the site from principal representative viewpoints, and the nature
and character of the visual amenity of the potentially sensitive visual receptors (or
viewers). This involves defining the approximate area from which the existing site is
225
visible and from which the Proposed Development would be visible. As described
above the ZTV was initially determined by computer generated mapping, desk
study of Ordnance Survey mapping and aerial photography.
10.29
This was followed by field survey to verify the extent of potential visibility and to
identify features which might screen views (such as built form and vegetation), and
to identify potential visual receptors. The existing steel frame of the turbine hall on
site forms a useful reference for determining the extent of visibility.
10.30
The field survey work for the visual assessment was carried out at the same time as
the landscape assessment. No access to properties was sought and the
assessment of views from properties is therefore based on a best assumption from
publicly accessible locations outside or close to the properties.
10.31
Visual receptors may include:





Users of recreational landscapes, public footpaths and bridleways including
tourists and visitors;
Residents;
Users of sports grounds and amenity open space;
Users of public roads, railways, canals or navigable waterways; and
Workers (in their workplace).
10.32
An analysis of the importance of the view and the sensitivity of visual receptor is
relevant to assessment of effects on views. Importance of views is generally
considered in the context of values placed on scenes, alternatives available and the
relative scenic quality (for example, its appearance in guidebooks, on tourist maps,
by facilities such as viewpoints provided for its enjoyment and references to it in
literature or art).
10.33
Sensitivity of visual receptors depends upon the location of viewpoint, the activity of
the receptor, expectations and the importance of the view. For example, a person
may be considered a receptor of low sensitivity when engaged in work in a factory
or when driving, where attention is not generally paid to the view, whereas the same
person may be considered a receptor of high sensitivity when visiting a viewpoint in
a National Park.
10.34
In visual assessment, lower storey views from residential properties are generally
considered to be more sensitive than upper storey views, as these are the rooms in
which residents spend more time experiencing the view. (This is not universally the
case as some residences have living rooms on upper storeys).
10.35
The land use planning system considers that public views are of greater value than
views from private property. In this assessment, sensitivity was generally assigned
to receptors as shown in Table 10.3 below.
226
Table 10.3: Relative Sensitivity of Receptors
Receptors
Relative Sensitivity
Residential properties (lower storey views)
High
Residential properties (upper storey views)
Moderate
Users of recreational paths and other public rights of High
way
Users of open space
High
Golf course users
Moderate
Sports pitch/playing field users
Low
Workers/visitors at businesses
Low
Motorists/rail users
Low
10.36
The importance of the view and the sensitivity of the receptor are considered in
determining the magnitude of effect (the scale of change) and in making a
judgement assessment of the significance of effect.
10.37
The assessment of effects determines the scale or magnitude of visual effects by
considering the scale of change of view (proportion occupied by development); the
degree of contrast or integration; the duration and nature of change; the angle of
view; the distance from the receptor; and the extent of area over which changes are
visible.
10.38
The magnitude of effect is considered in accordance with criteria as presented in
Table 10.4 below.
Table 10.4: Criteria for Assessment of Magnitude on Effects of Views
Magnitude
of Effect
Typical Criteria
High
Total loss of or major alteration to key elements, features or
characteristics of the existing view and/or introduction of elements
considered totally uncharacteristic.
Moderate
Partial loss of or alteration to one or more key elements/features/
characteristics of the baseline view and/or introduction of elements
that are prominent. The alteration in view may not necessarily be
considered substantially uncharacteristic when set within the
context of the existing view.
Low
Minor loss of or alteration to one or more key elements/features/
characteristics of the baseline view. Introduction of elements
which are generally characteristic of or similar to features in
existing view.
Negligible
Very minor loss or alteration to one or more key elements/features/
characteristics of the baseline view. Introduction of elements
characteristic of or similar to features in existing view –
approximating to the ‘no change’ situation.
227
Source: LI/IEMA 2002, p145
Assessment of Significance
10.39
Assessment of the significance of visual effects is a judgement of the scale or
magnitude of effect and the sensitivity of the receptor. In establishing a judgement,
general guidance given in LI/IEMA 2002 has been adopted. Large-scale changes
which introduce new, discordant or intrusive elements into the view are considered
to be more likely to be significant than small changes or changes involving features
already present in the view. Changes in views from recognised and important
viewpoints or amenity routes are likely to be more significant than changes affecting
other less important paths and roads. Changes affecting large numbers of people
are generally more significant than those affecting a relatively small group of users.
(However, in wilderness landscapes the sensitivity of the people who use these
areas may be very high and this would be reflected in the significance of the
change).
10.40
The significance of effects has been considered in the context of the comparative
scale at Table 10.5 overleaf.
Table 10.5: Criteria for Assessment of Visual Effects
Significance
of Visual
Effect
Typical Criteria
Major
An effect of major significance is generally recorded where a high
magnitude of effect occurs to a highly sensitive receptor. In this
instance, this could be where the new development would appear
clearly in a view which at present has open land as a large part of
its view.
Moderate
An effect of moderate significance is generally recorded where a
medium magnitude of effect is experienced by a receptor of high
or moderate sensitivity. In this instance, this could be where
parts of the development would be visible in a view but the new
development would not comprise a large part of the view.
Minor
An impact of minor significance generally relates to a low
magnitude of effect and often relates to a change in a distant view
or a change in only a small part of view, possibly because the
view is already screened to a large extent.
Neutral
A neutral impact is generally recorded where there is no
discernible change to the existing view, or where adverse and
beneficial impacts balance.
Source: LI/IEMA 2002
10.41
To illustrate the anticipated effect on views for some of the nearest and most
sensitive visual receptors, seven photomontage views have been prepared (see
Figure 10.3 for photomontage viewpoint locations). These viewpoints were agreed
with the Thanet and Dover District Councils. ‘Before’ and ‘after’ views are shown in
228
Figures 10.17 to 10.23.
Further detail of the method used to prepare
photomontages is provided at Appendix 10.1.
Existing Environment
Site Location and Context
10.42
The application site includes the proposed converter station and substation site at
the former Richborough Power Station. This part of the application site is
approximately 7.65ha and is approximately 3km southwest of Ramsgate and 4km
north of Sandwich.
10.43
The application site also includes the subsea underground cable route, between the
low mean water mark and Transition Joint Pit in Pegwell Bay, which is the buried
point of connection between the onshore and subsea cables. The length of the
subsea cable route between the low mean water mark and Transition Joint Pit is
1.8km. The onshore underground cables will run from the Transition Joint Pit on
the coastal side of the existing footpath and cycleway which runs parallel to the
A256 Sandwich Road, through Pegwell Bay Country Park, then into Stonelees
Nature Reserve and the former BayPoint sports complex. From the sports complex,
the cables will be routed by horizontal directional drilling beneath the A256, Minster
Stream, and a compartment of Hacklinge Marshes SSSI terminating in the
converter station. The length of the underground cable route between the Transition
Joint Pit and converter station is 2.3km.
10.44
The application site occupies low lying ground near Pegwell Bay where the River
Stour enters the sea. The application site is also closely associated with the A256,
which runs around Pegwell Bay and connects Ramsgate and Sandwich. As well as
residential settlement and outdoor leisure facilities associated with the coastal
location (such as the beach at Pegwell Bay, Pegwell Bay Country Park and golf
courses), south of the former power station there are a number of industrial land
uses. This includes the substantial Pfizer site at Great Stonar which sits between
the application site and Sandwich and is comprised of laboratories, production
facilities, offices and a combined heat and power plant. Inland, to the west, arable
land use predominates.
10.45
The converter station and substation site is derelict. The three cooling towers and
tall chimney, which stood on the site were demolished in March 2012, leaving the
steel frame of the former turbine hall as the only remaining structure.
Existing Landscape Character
10.46
This section summarises the findings of the desk-top review of published
documents and assesses the existing landscape character of the surrounding area.
The assessment has been undertaken using a combination of desk based
resources and field survey. Desk study consists of a review of the following:




Natural England National Landscape Character Assessment;
The Landscape Assessment of Kent, October 2004;
Thanet District Landscape Character Assessment 2001; and
Dover District Council Landscape Character Assessment, January 2006.
229
Natural England National Landscape Character Assessment
10.47
The site of the redundant Richborough power station is on the eastern edge of the
North Kent Plain National Character Area (NCA) as characterised by Natural
England.
National Character Area 113: North Kent Plain
10.48
The North Kent Plain NCA comprises land between the Thames Estuary to the
north and the chalk of the Kent Downs to the south. This area is described as
open, low and gently undulating dominated by very productive agricultural land
uses. Traditional orchards, soft fruits, and agricultural crops are identified in central
and eastern areas and are noted as often being enclosed by poplar or alder
shelterbelts and scattered small woodlands. Agricultural land is however recorded
as mostly devoid of hedgerows. Field boundaries are often marked by changes in
crop rather than hedgerows. There are extensive areas of ancient woodland
including on higher ground around Blean. The River Stour is the main catchment in
the area and its tributaries and associated wetland habitats (including areas of
grazing marsh, reedbeds, lagoons and gravel pits) are noted as an important
feature in the east.
10.49
Large settlements and urban infrastructure (including lines of pylons) are noted as
often being visually dominant in the landscape, referring to development around
Greater London and the Medway Towns in the west and around towns further east
and along the coast. Towns in the east are connected with London via major rail
and road links. The NCA profile for the North Kent Plain also comments that
industrial and commercial developments including associated pylons and masts
have impacted significantly on character, especially in flat, open landscapes such
as Thanet and the North Kent fruit belt.
The Landscape Assessment of Kent, October 2004
10.50
The application site mainly falls within ‘The Wantsum and Lower Stour Marshes’
Landscape Character Area (LCA), although the underground cable connection
crosses a small section of the ‘Thanet’ LCA, which is to the north of ‘The Wantsum
and Lower Stour Marshes’ LCA. Less than 1.5km south west of Richborough Power
Station is the ‘East Kent Horticultural Belt’ LCA. These LCAs are illustrated on
Figure 10.1 and brief descriptions are provided below.
The Wantsum and Lower Stour Marshes
10.51
This character area refers to marshlands in north-east Kent, which are the
reclaimed and silted up course of the Wantsum Channel and the former mouth of
the River Stour. The flat large-scale landscape is noted as having very long views
but is bordered by the gentle slopes of the Thanet chalk to the north and east, and
the horticultural belt to the south and west. This higher ground is described as
abutting the marsh in a very irregular pattern, softening and adding interest to an
otherwise uniform expanse, and providing some backgrounding by landform in all
views. A viewpoint at Upstreet is identified where the eye is drawn to the twin
towers of the Richborough power station (now demolished) and the wind turbine,
and to the church tower of St Nicholas at Wade on Thanet.
10.52
The defining characteristics of this area are described as:
230







10.53
Flat, open and remote landscape;
No settlement on marshland;
Reculver Towers and Richborough Fort marking the end of the Wantsum
Channel;
Regular field pattern fringed with dykes and drainage ditches;
Flood defences are characteristic elements;
River courses, flooding and waterlogging; and
Coastal influences relating to climate, sand dunes and seabirds.
The condition of this landscape character area has been determined as being poor,
and the area has been assessed as being moderately sensitive to landscape
change. The area’s landscape strategy refers to actions that restore and create,
including the restoration of the ecological and visual interest of the area’s drainage
channels, restoration of the land patterns of drainage and sea defences and the
creation of wetland/marsh/grassland and new reed beds.
Thanet
10.54
Thanet is described as a distinct landscape area defined by the former limits of the
island that was cut off from the mainland by the Wantsum Channel before it was
silted up approximately 1,000 years ago. Local topography has been noted as
resulting in two distinct landscape types; the flat plateau top above the 40 metre
contour and the sloping backdrop to the marshes between 20 and 40 metres above
ordnance datum.
10.55
The defining characteristics of this area are described as:







10.56
Open, large scale arable fields;
Lack of vegetation, in part historic due to early intensive agriculture;
Long views both to the ‘island’ from the main routes onto it, and back from
Thanet over the old Wantsum Channel, now the Chislet Marshes;
The central domed ridge to the island, with an aerodrome dominant on the
crest;
Exposed landscape, historically long denuded seaside/coastal influence with
big skies;
Open cliff-tops, bleak, grassy spaces; and
Existing power lines form a significant visual intrusion in the open landscape,
as do new lighting columns along the improved Thanet Way, notably at night.
The condition of this landscape character area has been determined as being poor,
and the area has been assessed as having a very high degree of sensitivity to
landscape change. The landscape strategy for Thanet refers to restoring the area’s
characteristics including for example, restoring and enhancing views, including sea
views from key locations, restoring the scale and containment of small settlements
on the edge of the marshes, and ensuring that development and associated
planting respect and enhance the landform.
East Kent Horticultural Belt
10.57
This character area is a generally flat and farmed landscape that lies approximately
between 10 and 40 metres above ordnance datum. Significant areas of orchard
and horticultural crops are referred to at East Stourmouth, Preston, Elmstone,
Westmarsh, Upper Goldstone and Perry and to the east at Woodnesborough.
231
10.58
Some of the orchards north of Ash are noted as being grubbed up and growers are
diversifying, for example into viticulture; changing the character of the countryside in
this area.
10.59
The area is mainly large-scale arable with limited grassland, and is mostly open.
The area slopes gently down to the adjacent marshland and the Stour river valley.
Views are recorded as often very long, for instance from the Roman road at
Hersden across to Thanet, and from Grove Hill across to Stodmarsh and the Stour
valley.
10.60
Between Wingham and Ash is an enclosed and secluded landscape with occasional
fruit and even hops scattered among the arable fields. A small scale agricultural
landscape persists around small hamlets with hedged lanes, shelterbelts and a
narrow twisting road network.
10.61
The landscape is increasingly open east of Ash with long views to Richborough
Power Station. The few undulations disappear, field boundaries are less in
evidence, and the landscape becomes increasingly level as it grades towards the
Wantsum and Lower Stour Marshes. Small pockets of industry do occur such as
the proposed business use for the old Chislet and Betteshanger Collieries.
10.62
The defining characteristics of this area are described as:











10.63
Medium scale landscape enclosed by hedgerows and shelterbelts, gradually
sloping or flat;
Some contained, small-scale landscapes in the central area;
Mainly large-scale arable with limited grassland around Richborough,
Wingham, Stodmarsh, Upstreet, Maypole and Ford south-east of Hunters
Forstal;
Long views from higher ground and for instance from the Roman Road at
Hersden across to Thanet, and from Grove Hill across to Stodmarsh and the
Stour valley;
Coastal and marsh edges;
Diverse agriculture with vineyards, soft fruit, orchards and glasshouses;
Small isolated linear villages, some piecemeal development along roads based
on original small hamlets or farms;
Isolated, square, buff-coloured farm cottages;
Very narrow winding roads following the field and drainage pattern;
Regimented, intensive feel to farmland; and
Some blocks of unmanaged land, particularly towards the marginal wetlands.
The condition of this landscape character area has been determined as being
moderate, and the area has been assessed as having low sensitivity to landscape
change. The area’s landscape strategy refers to creating and reinforcing including
the creation of nuclei of small-scale landscapes, reinforcing the character of the
marsh-edge by encouraging the development of wetland areas, and by reinforcing
drainage patterns and shelterbelts as functional and visual elements within the
landscape.
Thanet District Landscape Character Assessment 2001
10.64
This detailed landscape character assessment was carried out by Thanet District
Council as part of the preparation of the Isle of Thanet Local Plan. The landscape
character assessment has since been fully reviewed as part of the Local Plan
232
review and in light of new guidance. The district has been divided into six
landscape character areas. Landscape character areas relevant to the Proposed
Development are illustrated on Figure 10.1 and are briefly described below.
10.65
The application site at and in the vicinity of the former Richborough power station
site is located at the eastern extent of ‘The Former Wantsum Channel’ character
area. The majority of the onshore and intertidal underground cable route is within
the ‘Pegwell Bay’ character area.
The Former Wantsum Channel
10.66
‘The Former Wantsum Channel’ character area runs inland as an east-west corridor
of approximately 1km width. This area includes all the flood plain of the River Stour
and is of historic, cultural and visual significance because it represents the former
sea channel that used to separate the Isle of Thanet from the mainland. This has
silted up over several centuries to form a vast, flat, open landscape with an ancient
field system. The area is defined by an extensive ditch and dyke system, the
former sea walls and isolated groups of trees, which provide visual evidence of the
physical evolution of the landscape.
Pegwell Bay
10.67
The ‘Pegwell Bay’ character area lies to the east of former Richborough Power
Station site and ‘The Former Wantsum Channel’ character area referred to above.
Pegwell Bay is described as an extensive area of mixed coastal habitats, including
mudflats, saltmarsh and coastal scrub, which form an open and relatively unspoilt
landscape, with a sense of remoteness and wildness despite the relative proximity
of development and large open skies. One of its most important features is
identified as being the unique sweep of chalk cliffs viewed across Pegwell Bay from
the south.
The Former Wantsum North Shore
10.68
‘The Former Wantsum North Shore’ character area is immediately north of ‘The
Former Wantsum Channel’ and forms a narrow broadly east-west corridor. The
area is characterised by distinctive and often quite steep hill slopes leading down
from the Central Chalk Plateau to The Former Wantsum Channel. The landscape
is described as being very open with few features and the former shoreline is more
distinct in some places than others. From the upper slopes there are extensive
views over the whole of ‘The Former Wantsum Channel’ and toward ‘Pegwell Bay’
character area and the sea. The area also provides the setting for a number of
former channel-side villages, including Minster which lies just over 2km to the
northwest of Richborough Power Station. The area contains a large number of
archaeological sites (including Minster Abbey and the historic landing site at St
Augustine). These elements all contribute in providing visual evidence of the
growth of human activity in the area.
The Central Chalk Plateau
10.69
‘The Central Chalk Plateau’ is to the north of ‘The Former Wantsum Channel’ and is
surrounded on its northern and eastern sides by ‘The Urban Coast’ character area.
This central part of the district ‘is characterised by a generally flat or gently
undulating landscape, with extensive, unenclosed fields under intensive arable
cultivation’. This open landscape is fragmented by the location of large-scale
233
developments, such as the airport and is influenced by its proximity to ‘The Urban
Coast’ character area.
The Urban Coast
10.70
‘The Urban Coast’ character area is a largely heavily urbanised area that includes
Ramsgate (approx. 3km northeast of Richborough Power Station) and forms almost
a continuous conurbation on the north and eastern coast. ‘The Urban Coast’ is
characterised by traditional seaside architecture, active harbours, beaches and
some open clifftop areas, and the pattern of bays and headlands is described as
providing long sweeping views of the coast.
Dover District Council Landscape Character Assessment, January 2006
10.71
The application site is in Thanet District, although part of the eastern edge of the
converter station and substation site and a small section of the underground cable
route fall within Dover District. A Landscape Character Assessment is available for
Dover District (prepared by Jacobs Babtie), excluding land within the Kent Downs
Area of Outstanding Natural Beauty (AONB).
10.72
The Landscape Character Assessment for Dover identifies six landscape types and
twelve landscape character areas across Dover District. Part of the converter
station and substation site and underground cable route referred to above is within
Dover Landscape Type 1 and within LCA 4, ‘The Sandwich Corridor’. Landscape
Type 1 is described as a flat visually open landscape with small to medium scale
fields divided by ditches with none or only occasional hawthorn and willow scrub.
Land use includes grazing, mostly improved pasture, and some arable. Much of the
land is ‘reclaimed’ and traditionally unsettled. Former landfill and industrial
development is identified north of Sandwich.
10.73
Landscape Type 2 is east of the converter station and substation site extending
east of the River Stour. Key characteristics of this landscape type are noted as
comprising an irregular and low landform, typically devoid of tree cover and visually
unenclosed. Land use within this landscape type is varied including golf courses, a
nature reserve and beach.
10.74
Landscape Type 3 is southwest of the converter station and substation site, beyond
the ‘Ash Levels’ (LCA 3 referred to below), and extending across agricultural land
towards the A257 running west from Sandwich and to the north of Ash. This
landscape character type is described as a very gently undulating to nearly flat
landscape, enclosed by high hedges and shelterbelts, although more open across
arable land. Hedgerows are dominant with mature trees generally associated with
buildings and settlement. Small to medium scale arable fields (away from
marshland edge) occasionally have few internal boundaries and are defined by
narrow enclosed roads. Land use also includes orchards, market gardening and
occasional pasture and horse grazing. There are numerous small villages, hamlets,
groups of buildings, small churches and large timber barns across the landscape.
10.75
Dover Landscape Character Areas (LCAs) within the site’s context include:
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The Sandwich Corridor (LCA 4);
Sandwich Bay (LCA 6);
Ash Levels (LCA 3);
Richborough Castle (LCA 4);
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Preston and Ash Horticultural Belt (LCA 2); and
Little Stour Marshes (LCA 1).
10.76
The above are illustrated on Figure 10.1 and the key characteristics of the LCAs are
provided below.
10.77
The ‘Sandwich Corridor’ (LCA 4), the ‘Ash Levels’ (LCA 3), ‘Richborough Castle’
(LCA 5) and ‘Little Stour Marsh’ (LCA 1) landscape character areas are within
landscape character type 1.
10.78
Key characteristics of The Sandwich Corridor (LCA 4) are described as:
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10.79
Key characteristics of the Ash Levels (LCA 3) are described as:
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10.80
Flat landscape;
Broad native hedgerows and tall metal fencing along roads;
Huge, modern buildings with brick and glass dominant;
Large car parks;
River Stour and boat culture;
Associated mudflats and bird life;
Large lake;
Industrial pockets;
Straight, wide main road; and
Limited views due to buildings dominating landscape.
Low lying, flat and open landscape;
Farmland used as permanent grassland and for winter cereals;
Sheep and cattle graze the open, improved pasture land;
No obvious field pattern, fields are of varying shapes of a smaller size than
agricultural land to the west and south;
Drainage ditches along field boundaries;
Little built development creating a predominantly horizontal landscape with little
to interrupt the view or focus the eye;
Views extend across the fields due to the flat topography and lack of tree cover
and are possible to the higher ground of Thanet to the north of the former
Wantsum Channel; and
Development in the east is visible, in particular Pfizer and the former
Richborough power station within what is described as the Sandwich Corridor.
Key characteristics of the ‘Richborough Castle’ landscape character area (LCA 5)
are described as:
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Roman Fort and amphitheatre built on a higher knoll of land in comparison to
the surrounding flat ‘Ash Levels’;
Arable agricultural land surrounding the Castle, divided by native hedgerow,
into medium sized flat fields with no significant shape or pattern;
The settlement of Richborough is to the west of the Castle and comprises a
scattering of houses of mixed character;
Views are relatively far reading from the Castle due to its slightly elevated
position;
Sandwich and the Sandwich Corridor are visible, but screened in parts by
hedgerows; and
235
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10.81
Key characteristics of the ‘Little Stour Marshes’ landscape character area (LCA 1)
are described as:
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10.82
Three separate areas: The Stourmouth Valley; The Preston and Deerson
Valley, and the North Wingham Valley;
Similar to the Ash Levels, the area is flat and mainly used as permanent
grassland with some winter cereal, in particular to the south;
No obvious field pattern, fields are of varying shapes although of consistent
size;
Drainage ditches define field boundaries; and
Footpaths follow the waterways, for example the Saxon Shore Way along the
Little Stour in the Stourmouth Valley.
The ‘Sandwich Bay’ landscape character area (LCA 6) is within landscape
character type 2. Key characteristics of Sandwich Bay (LCA 6) are described as:
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10.83
Pfizer industrial buildings are noted as being dominant in the view, as well as
out of scale and character.
Flat to gently undulating topography;
Dunes;
Sand and shingle;
Occasional scrub;
Birdlife;
Wide expanse of sea;
Golf courses;
Coarse coastal grasses;
Some farmland;
Large houses in open plan estate;
Few roads;
Seasonal change; and
Exposed landscape with extensive views out to sea.
The ‘Preston and Ash Horticultural Belt’ landscape character area (LCA 2) is within
landscape character type 3.
Key characteristics of the Preston and Ash
Horticultural Belt (LCA 2) are described as:
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Includes the settlements of Stourmouth, Preston Ash, Marshborough,
Woodnesborough and Worth;
Relatively flat, although slightly undulating landscape compared to the ‘Stour
Marshes’ and ‘Ash Levels’;
A variety of agricultural land uses including orchards, vineyards, greenhouses,
vegetables, pasture and arable land;
Tree cover with some native hedgerows and clumps of native trees and shrubs
in places; and
Poplar windbreaks and orchard plantations add to the tree cover.
Landscape Designations
10.84
There are no landscape designations within or surrounding the Proposed
Development site.
236
10.85
There is no land in the area surrounding the Proposed Development that qualifies
for conditional exemption from capital taxes on the grounds of outstanding scenic,
scientific or historic interest.
Description of the Site and Surrounding Landscape Character
10.86
The converter station and substation site comprises 7.65ha of previously developed
land. Following the demolition of the former power station cooling towers and
chimney, the steel frame of the former turbine hall is the only built structure left on
the proposed converter station and substation site and the site is being cleared of
demolition debris.
10.87
The 1.8km subsea underground cable route runs in a westerly direction across
Pegwell Bay between the low mean water mark and Transition Joint Pit (TJP),
which is in saltmarsh (covered by a number of wildlife designations). The 2.3km
onshore underground cable route runs in a westerly direction from the TJP across
saltmarsh before turning southward at a point just south of Pegwell Bay Service
Station and crossing grassland on the coastal side of the existing footpath and
cycleway (a Sustrans Regional Route) which runs parallel to the old A256 Sandwich
Road. The cable route then crosses into Pegwell Bay Country Park which is public
open space comprising amenity grassland, rough grassland, scrub and trees which
has been established on land reclaimed following landfill. The cable route
continues southward and parallel with the A256 Sandwich Road through Stonelees
Nature Reserve which consists of a mixture of grassland, scrub and occasional
trees (and is covered by a number of wildlife designations) and into the western
edge of the former BayPoint sports complex. From the sports ground, the cable
would be routed by horizontal direction drilling to the south west, passing beneath
the A256, Minster Stream, and a compartment of Hacklinge Marshes SSSI (an area
of scrub with trees), entering the converter station and substation site at the
northeastern corner.
10.88
To the west of the converter station and substation site a narrow strip of land
separates the converter station and substation site from the River Stour. A
concrete wall and metal railings (remnants of the previous land use) form the
eastern edge of the river at this point and this boundary is open.
10.89
To the south of the converter station and substation site there are a number of
industrial sites on each side of the A256, including the Thanet Offshore Windfarm
132kV Substation to the immediate south. The River Stour sits behind industrial
land uses on both the eastern and western sides of the A256 and is hidden from
view for road users.
10.90
The A256 lies close to the converter station and substation site’s eastern boundary.
This part of the application site is separated from the main road by a petrol filling
station and rough grass verge and there are also some tree groups close to the
eastern site boundary.
10.91
To the north of the converter station and substation site is an area of scrub with
trees, which is designated a SSSI. Beyond this is Weatherlees Hill Wastewater
Treatment Works, Richborough Solar Farm and the new A256 bypass.
10.92
A 500kW anaerobic digestion plant is being built (November 2012) adjacent the
new roundabout on the A256 and the new bypass, between the new lane (off the
roundabout) leading to Ebbsfleet Farm to the north and Minster stream in the south.
The anaerobic digestion plant comprises an agricultural building (maximum height
237
12m), a cylindrical digestate storage tank (with a 6m high wall, measuring 14.82m
high to the peak of the gas collection roof), and two cylindrical digesters, (also with
a 6m high wall, but not as tall at approximately 12.2m high to the peak of the dome).
Digester tanks and the storage tank will be clad in green aluminium. The anaerobic
digestion plant will also comprise a covered CHP generator and control room,
hardstanding, mounding to the north western site boundary with Minster stream and
mixed native shrub mix planting to the north eastern site boundary. 2.4m high
green palisade fencing is proposed to secure the site.
10.93
North of the anaerobic digestion plant, between the new A256 bypass and
Ebbsfleet Lane is a new solar park including 10 rows of solar panels positioned
0.6m above ground with an overall height of 2.3m. The site is secured by 2 metre
high fencing.
10.94
To the northwest of the converter station and substation site, the former power
station site continues as a narrow strip of cleared land adjacent to the River Stour.
This land is part of the proposed Richborough Energy Park and the 1.6 hectare
temporary laydown area required for the construction of the converter station and
substation development would be on the land to the immediate west of the
application site. In the western part of Richborough Energy Park and to the north of
the river there is a single wind turbine and two masts, which are prominent vertical
features in the landscape.
10.95
The application site is part of an area of low lying ground (less than 5m AOD)
associated with the River Stour, close to where it enters the sea at Pegwell Bay.
The low lying river floodplain (or marshes) west of the former power station is
drained by a network of ditches and is mainly under arable use, although fields of
pasture and rough grazing flank the river. Fields are regularly sized and broadly
geometric. Occasional hedgerows and hedgerow trees are found within this lower
lying ground, but the landscape is generally open and remote, being devoid of
roads or built form, with the exception of two high voltage (132kV) overhead
powerlines which run from the former power station westward broadly along the
path of the River Stour and are prominent features in views from low ground looking
along the valley floor. A further overhead line runs southward from the former
power station and crosses the southern valleyside to the west of Richborough
Roman Fort and Amphitheatre. There are also two railway lines, which are flanked
by mature vegetation belts. There is a railway line running southward across the
valley from Minster to Sandwich, which passes the converter station and substation
site approximately 0.5km to the west. A second railway line runs east-west along
the northern edge of the Stour floodplain through Minster, connecting with
Ramsgate.
10.96
The southern valleyside is gently sloping and there are a number of fruit orchards
on this side of the valley, interspersed with some arable fields. The orchards are
protected by tall hedgerows and shelterbelts, which create an enclosed character in
contrast to the open marshes to the north. The area is crossed by a series of
narrow winding lanes which follow field patterns. Along the network of lanes are
linear villages, small hamlets and farmsteads.
10.97
The northern valleyside is more steeply sloping than the southern valley slopes with
larger-scale arable fields. Fields boundaries are often open, allowing extensive
views across the valley (the former Wantsum Channel) and out to Pegwell Bay.
The transition from the floodplain marshes to the northern valley side is defined by
the southern edge of the historic village of Minster and the railway line which runs
along this edge. Apart from Minster, other residential settlement occurs as linear
238
development along a network of minor roads. A number of these minor roads have
been severed at their northern extents where the A253 and A299 run along the
ridgeline toward Ramsgate. Suburban and ‘out of town’ development associated
with the southwestern edge of Ramsgate has an urban influence on landscape
character and the edge of Ramsgate is visible on the skyline from locations within
the landscape to the southwest. Kent International Airport is also positioned on the
ridgeline and is a prominent feature, with views of aeroplane activity on the skyline
possible from a number of locations.
10.98
The former power station site forms part of a number of industrial sites and urban
influences, associated with the old A256, which runs past Pegwell Bay and
connects Ramsgate with Sandwich. At the northern end of the A256 corridor, the
landscape consists of a mixture of arable land extending to clifftops, residential
suburban development at Cliffs End and the southwestern edge of Ramsgate and
recreational open space associated with the beach at Pegwell Bay. Further south
the A256 urban corridor is separated from the coast by a combination of mud flats,
salt marsh and scrub around the southern edge of Pegwell Bay and the mouth of
the Stour. Pegwell Bay Country Park, established over landfill as an area of
scattered trees and scrub with amenity and rough grassland, sits within this
landscape. On the west side of the old A256 is St Augustine’s Golf Course and
Stonelees Golf Centre, which contain established tree planting in groups and
around their boundaries. The converter station and substation site sits to the south
of this area, and from this point southward industrial units and land uses are visible
to either side of the A256. East of the A256 corridor, a mixture of rough grazing
land with a few arable fields and golf courses extend along the coast toward
Sandwich. Although devoid of mature woodland and tall trees, this landscape
appears well vegetated in views across Pegwell Bay and from higher ground on the
valley sides, although some of the low lying salt marshes and intertidal area are
open in themselves. The presence of industry, other urban influences and coastal
habitats partly bring a bleak feel to the coastal landscape.
10.99
Key characteristics identified within the published landscape character assessments
are evident in the landscape within the study area. Along the coast between
Ramsgate and Sandwich these characteristics include:
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Flat landscape;
Industrial pockets;
Straight wide main road;
Mixed coastal habitats, including mudflats, saltmarsh and coastal scrub;
Sense of remoteness and wildness despite the relative proximity of
development;
Large open skies; and
Sweep of chalk cliffs viewed across Pegwell Bay from the south.
10.100 Within the low lying ground of the Stour Valley (former Wantsum Channel) these
characteristics include:
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Flat, open and remote landscape;
Small to medium scale fields divided by ditches;
Land use includes grazing, mostly improved pasture, with some arable land;
Much of the land is ‘reclaimed’ and traditionally unsettled;
Occasional hawthorn or willow, reeds and flax along ditch lines;
No roads or buildings and few footpaths in north-south direction;
Former landfill and industrial development is identified north of Sandwich; and
239
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Lines of pylons are noted as dominating the open and often treeless landscape.
10.101 On the northern side of the Stour Valley these characteristics include:
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Open, large scale arable fields;
Long views both to the ‘island’ from the main routes onto it, and back from
Thanet over the old Wantsum Channel, now the Chislet Marshes;
The central domed ridge to the island, with an aerodrome dominant on the
crest; and
Suburban character to towns.
10.102 On the southern side of the Stour Valley these characteristics include:
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Medium scale landscape enclosed by hedgerows and shelterbelts, gradually
sloping or flat;
Diverse agriculture with vineyards, soft fruit, orchards and glasshouses;
Small isolated linear villages, some piecemeal development along roads based
on original small hamlets or farms;
Very narrow winding roads following the field and drainage pattern;
Regimented, intensive feel to farmland; and
Some blocks of unmanaged land, particularly towards the marginal wetlands.
Landscape Value, Condition and Sensitivity
10.103 The landscape within and surrounding the application site is not covered by any
landscape designations and is generally judged to be of local value to nearby
residents. Pegwell Bay is promoted as a tourist destination although primarily for its
wildlife interest.
10.104 The landscape condition of the application site and immediate surroundings is
generally poor. This reflects recent development along the coastline and changes
in agricultural practices in the surrounding landscape. The orchard landscape on
the southern valleyside is in moderate condition, as this area is broadly intact with
only some encroachment of arable land and hedgerow loss.
10.105 In terms of the overall sensitivity of the landscape within and surrounding the
application site to this type of development, the application site borders the eastern
edge of an agricultural landscape, and is associated with a well vegetated
landscape between Ramsgate and Sandwich which already contains industrial
development to either side of the A256. The converter station and substation site is
on brownfield land, which contains the steel frame structure of a derelict building.
The converter station and substation development would be consistent with the
existing landscape character and would match the scale of existing industrial built
form. The landscape is of local value and although the landscape is open to the
west, existing vegetation along the coastline would help accommodate this
development in the landscape and mitigation by way of tree planting would not be
out of character. The underground cable route, which will be reinstated following
construction, runs close to the A256 and across restored land at Pegwell Bay
Country Park. Overall the landscape is of low sensitivity to change.
Existing Views
10.106 The visual influence of the Proposed Development site has been determined
through a combination of computer generated mapping, topographic analysis and
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field evaluation of features affecting visibility such as built form and trees, hedgerow
and woodland that would filter and screen views of the development. This work
determined the potential visibility of the Proposed Development site and identified
visual receptors. Visual receptors identified were also discussed with the Planning
Case Officers from Thanet and Dover District Councils as part of the agreement as
to which viewpoints photomontage views should be prepared.
10.107 Field survey has considered all receptors from where views of the Proposed
Development are likely and what existing views comprise. No access has been
sought to private properties or land and an assessment has been made from the
nearest publicly accessible viewpoint. Single frame and panoramic photographic
views were taken from a number of these locations (see Figures 10.4 to 10.16).
These images illustrate the current views in the area and form part of the baseline
against which the proposed converter station and substation and underground
cable route is assessed.
10.108 There are views towards the Proposed Development from public viewpoints which
would be experienced by visitors to public open space or heritage open space,
walkers on Public Rights of Way, road users and rail users in the surrounding area.
Private receptors refer to residential properties, businesses and private golf courses
and sports grounds anticipated to have views towards the Proposed Development.
10.109 The approximate Zone of Visual Influence (ZVI) of the Proposed Development
extends to elevated viewpoints on the western edge of Ramsgate and along the
valley slope to encompass visual receptors in the vicinity of Minster and Monkton.
The ridgeline to the Isle of Thanet Plateau coincides with the A299 and Kent
International Airport and marks the extent of the ZVI to the north.
10.110 To the west of the Proposed Development, the generally flat and open nature of the
Stour Valley (former Wantsum Channel) allows some distant views toward the
converter station and substation site for public and private receptors as far west as
Sarre, St Nicholas at Wade, and Upstreet (which is approximately 10km distant).
Beyond this the Stour Valley turns southward and distance, intervening topography
and vegetation prevent further views. Within the ZVI the reclaimed marshes to
either side of the River Stour have few visual receptors apart from the public right of
way network and the occasional minor road crossing or dwelling.
10.111 To the south of the Proposed Development, visibility from higher ground on the
south side of the Stour Valley is generally restricted by orchards and the tall
hedgerows and shelter belts associated with them. Apart from the more extensive
views available from the Roman Fort and Amphitheatre at Richborough, visual
receptors are generally limited to the residents’ views from those dwellings on the
edge of the open marshland to the north, as well as the occasional glimpsed view
from the public right of way and minor road network further south. To the
immediate south of the Proposed Development, other industrial and urban
development near Sandwich prevents views from extending much beyond the
BayPoint sports complex, with some slightly more distant views possible from the
long distance footpath routes on the coast and within the Prince’s Links Golf Course
and Royal St George’s Golf Course.
10.112 To the east of the Proposed Development nearer views are possible from amenity
open space along the coastline and the ZVI also extends out into Pegwell Bay.
241
Visual Receptors
10.113 For this site, public and private visual receptors are anticipated to comprise the
following (see Figure 10.2 for visual receptor locations):
Public Views
Walkers along the following Public Rights of Way (PROW):
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1.1a – Saxon Shore Way at former Richborough Power Station;
1.1b – Saxon Shore Way near Roman Fort;
1.1c - Saxon Shore Way at Boxlees Hill (south of Minster) including footpath
connections south of Marsh Farm Road;
1.1d - Saxon Shore Way at Plucks Gutter;
1.1e – Saxon Shore Way at Royal St George’s Golf Club;
1.2a – Stour Valley Walk at Sandwich Flats/Prince’s Golf Links;
1.2b – Short section of Stour Valley Walk at Cooper Street;
1.3a – Thanet Coastal Path at Pegwell Bay Country Park to Cliffs End;
1.3b - Thanet Coastal between Cliffs End and the edge of Ramsgate;
1.4 – PROW at Potts Farm Drove;
1.5 - PROW at Goldstone Drove (and PROW which runs parallel 0.2km to the
west);
1.6 - PROW at Westmarsh Drove (and PROW which runs broadly parallel to
the east);
1.7a and 1.7b - PROW network east of Minster (1.7a - north of the railway line
and 1.7b – south of the railway line);
1.7c – PROW west of Cliffs End;
1.8 - PROW southwest of Minster;
1.9a - PROW south of Manston/Manston Road;
1.9b – PROW south of Nethercourt;
1.10 - Network of PROW around Monkton Marshes/Docker Hill;
1.11 - PROW between Brookestreet Farm and East Street; and
1.12 – PROW north of Monkton and Minster.
Users of the following public open spaces and outdoor tourist attractions:
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2.1 – Pegwell Bay Country Park;
2.2 – Stonelees Nature Reserve;
2.3 – St Augustine’s Cross;
2.4 – Richborough Roman Fort;
2.5 – Richborough Roman Amphitheatre;
2.6 – Pegwell Bay picnic area and beach;
2.7 - Sandwich boat trips up River Stour;
2.8 - Sandwich boat trips to Pegwell Bay; and
2.9 - West Cliff, Ramsgate.
242
Users of the following roads and railway lines:
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3.1a - A256 Sandwich Road (North of the converter station and substation site,
including site entrance) including the adjacent Sustrans Regional Route;
3.1b – A256 new bypass (East Kent Access Road Phase 2);
3.1c - A256 Ramsgate Road (south of the converter station and substation site)
including the adjacent Sustrans Regional Route;
3.2 - Ebbsfleet Lane (north and south of the new A256 bypass);
3.3 – Rural lane south of Minster (Marsh Farm Road);
3.4 – Richborough Road between Roman Amphitheatre and Roman Fort;
3.5 - Grinsell Hill and other rural lanes northeast of Minster, and Cottington Rd
and Thorne Hill;
3.6 - Pegwell Road, Ramsgate;
3.7 - A299 Canterbury Road West between Mount Pleasant and Ramsgate;
3.8 - A256 Haine Road (on western side of Ramsgate, north of intersection with
A299);
3.9 - Other minor roads south of River Stour;
3.10 - Manston Road (either side of A256);
3.11 - A299 Canterbury Road West (between Monkton roundabout and Mount
Pleasant) and also a footpath and cycleway route which runs parallel and to the
south;
3.12 - A253 Island Rd (between Sarre and Monkton roundabout);
3.13 - Minor road between Plucks Gutter and Gore Street;
3.14 - A28 Canterbury Road at St Nicholas at Wade;
3.15 - Railway line from Ramsgate to Minster;
3.16 - Railway line from Minster to Sandwich; and
3.17 - Railway line west of Minster (along Stour Valley).
Private Views
Residents living at the following properties:
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









A1 - Houses on Ebbsfleet Lane near the junction with Sandwich Road (A256);
A2a – Ebbsfleet Farm;
A2b – No. 1 Ebbsfleet Farm Cottages on Ebbsfleet Lane;
A3 – House between industrial units on Ramsgate Road;
A4a – Houses at Sevenscore;
A4b – Houses at/near Thorne Farm;
A5 - Houses on Whitehouse Drove;
A6a - Cliffs End (south of railway line);
A6b – Cliffs End (north of railway line);
A7 - Castle Road, Richborough;
A8 - Houses on Rubery Drove;
A9 - House at/west of Richborough Farm;
A10 - Houses near Guston Farm, Potts Farm and Lower Goldstone;
A11 - Minster and surrounds;
A12 - House at Little Cliffsend Farm and Coastguard Cottages;
A13 - Nethercourt, Ramsgate;
A14 - Pegwell, Ramsgate;
A15 - Houses at Hoo;
A16 - Stanner Court residential tower block and new housing development on
Manston Road, Ramsgate;
243






A17 - East Stourmouth and surrounds;
A18 – Sandwich;
A19 – Sarre;
A20 - Upstreet;
A21 – East Street; and
A22 – St Nicholas at Wade.
Users of the following golf courses and sports facilities:






B1 – Stonelees Golf Centre;
B2 – St Augustine’s Golf Course;
B3 – Manston Golf Centre near Ramsgate;
B4 – Prince’s Golf Links near Sandwich;
B5 – Royal St George’s Golf Club near Sandwich; and
B6 – BayPoint sports complex.
Workers and customers at the following businesses:











C1 – Businesses and industrial units near the site entrance and to the south of
the converter station and substation site on the A256;
C2 – BayPoint sports complex;
C3a - The Sportsman Inn Public House, Sandwich Road (old A256);
C3b – Pegwell Bay Service Station, Sandwich Road (old A256);
C4 - Pegwell Bay Hotel, Pegwell Road;
C5 - The Sir Stanley Gray and Belle Vue Public Houses, Pegwell Road;
C6 - Lord of the Manor Public House off A299;
C7 - Industrial Park, Laundry Road, Minster;
C8 – Holiday Inn and Premier Inn, Minster;
C9 – Wayside Caravan Park, Minster; and
C10 – Sarre Windmill.
Sensitivity of Visual Receptors Identified
10.114 Sensitivity of visual receptors depends upon location of viewpoint, expectations and
activity of the receptor and the importance of the view. Leisure walkers using Public
Rights of Way and users of public open space within the ZVI have been assessed
as being of high sensitivity to visual change. Visual receptors using the local road
network within the ZVI are anticipated to be primarily motorists and are assigned a
low sensitivity to visual change, with the exception of users of ‘rural lanes’
(designated under saved policy within Thanet District Council’s Local Plan 2006)
which have been assigned a moderate sensitivity.
10.115 Residents with lower storey views are judged to be receptors of high sensitivity to
visual change, whilst residents with upper storey views towards the site are
considered to have a moderate sensitivity to visual change.
10.116 Generally workers and visitors to private businesses are considered to have a low
sensitivity to visual change, unless appreciation of the setting of the business
premises and the views from it are part of the customer experience. ‘Wayside
Caravan Park’ in Minster, Pegwell Bay Hotel and Sarre Windmill have been
assessed as being of high sensitivity to visual change, and other pubs and visitor
accommodation which would contain visual receptors have been assessed as being
of moderate sensitivity to visual change.
244
10.117 Golf course users are considered to have a moderate sensitivity to visual change,
as the setting and views from a golf course may be part of the enjoyment of the
sport, whereas users of sports pitches are considered to have a low sensitivity to
visual change as the focus would be on the sport being played.
Importance of Views
10.118 The majority of views are of local (low) importance to local residents and a relatively
small number of tourists.
The views from Richborough Roman Fort and
Amphitheatre (an English Heritage visitor attraction) have been recorded as being
of moderate importance. (Views from Richborough Roman Fort and Amphitheatre
are also considered as part of the archaeology and cultural heritage assessment –
see chapter 9). No views in the study area are recorded as being of high (national)
importance.
Nature of Existing Views
10.119 Tables 10.10 to 10.15 in Appendix 10.2 provide a description of the existing views
from each of the visual receptors identified. Figures 10.4 to 10.16 include site
photographs taken from viewpoint locations identified on Figure 10.3 and Figures
10.17 to 10.23 present ‘before’ views from the photomontage viewpoint locations
shown on Figure 10.3. In summary, all of the visual receptors identified within the
ZVI have existing views of the derelict frame of the former turbine hall building
within the converter station and substation site. Apart from the existing views
experienced by a few visual receptors immediately adjacent to the converter station
and substation site, it is the upper part of the derelict frame that is visible above
intervening vegetation. From elevated viewpoints on the Stour valleysides the
derelict frame is set below the horizon and is not visually prominent. In views from
lower ground the former turbine hall sits on the skyline, including in more distant
views across the lower lying marshes. In near views of the converter station and
substation site, the derelict nature of the former turbine hall is apparent. A number
of these existing views also comprise nearby industry and built form, such as the
BayPoint sports complex to the south of the Proposed Development and the wind
turbine and masts located west of the converter station and substation site. These
features create a complex pattern, in views from elevated viewpoints, of vegetation
with glimpses of built form along the coastline.
10.120 Existing views of the underground cable route are generally restricted to visual
receptors close to the route, which include users of the Sustrans Regional Route,
Stonelees Nature Reserve and Pegwell Bay Country Park. The exception is the
route across the intertidal mudflats which are open and visible from a number of
more distant visual receptors surrounding Pegwell Bay. Although the underground
cable route crosses ecological habitat and green space, the nearby A256 and urban
development along the coast are already components in a number of the views of
the cable route.
Prediction and Assessment of Significance of Potential Impacts
Construction Phase
Effects on Landscape Character
10.121 Construction effects would be associated largely with the introduction and
movement of site vehicles and construction machinery, site preparation and build,
245
some tree removal to accommodate the cable route within Pegwell Country Park,
excavated underground cable trenches, stockpiled material, site compounds,
storage buildings, temporary fencing and signage. Construction activity would not
be uncharacteristic or out of context with the landscape character of the coastal
corridor between Ramsgate and Sandwich.
10.122 The magnitude of effect on landscape character as a result of the Proposed
Development (including works to the underground cable route) during the
construction period would be moderate adverse. The landscape generally has a low
sensitivity to change and is of local value or importance, resulting in a moderate
adverse significance of effect on landscape character during construction.
Effects on Views
10.123 Some receptors with views towards the application site (including the underground
and overground cable route) would experience negative visual effects during
construction. However, these would be temporary short term effects. Visual effects
anticipated during the construction phase are identified in Tables 10.10 to 10.15 in
Appendix 10.2 and range from moderate to minor adverse effects for a small
number of visual receptors closest to the site and those at elevated viewpoints, with
more distant and also low lying visual receptors experiencing a neutral effect.
On Completion
Effects on Landscape Character
10.124 Following reinstatement of the cable swathe the magnitude of effect on landscape
character as a result of the proposed cable route (including the overground section
of cable through the northern part of Pegwell Country Park and along the A256 in
this locality), would be negligible. The overground cable route through the northern
part of Pegwell Country Park cleared of trees and scrub, will be capped with chalk,
(similar to capping across the former landfill which Pegwell Country Park
encompasses), and will be quickly re-established as grassland. The overground
cable route would comprise a low adverse magnitude of effect on the landscape.
The landscape has a low sensitivity to change and overall the underground cable
route would result in a neutral significance of effect.
10.125 As assessed above in relation to temporary construction effects, the magnitude of
effect on landscape character during any maintenance or repair works required in
relation to the overground and underground cable route would be no greater than
moderate adverse in a localised area due to ground disturbance, stockpiling and
construction activity. The significance of this short term effect on landscape
character would be moderate adverse.
10.126 Implementing the Proposed Development at the converter station and substation
site would be consistent with the existing character of the A256 coastal corridor
between Ramsgate and Sandwich, which already comprises industrial development
and includes the derelict site of the former Richborough Power Station. Vegetation
associated with open space, golf courses, nature reserves, designated wildlife
habitats and the railway lines assists in accommodating existing development within
the coastal landscape and wider landscape context, including the open and low
lying marshes to the west. Although the development would introduce elements
that are generally characteristic of the surrounding landscape, it would extend built
development across the existing derelict site, which would increase the extent of
industrial development presently evident in the locality.
246
10.127 The magnitude of effect on the landscape character of the converter station and
substation site on completion (and prior to mitigation) would be low adverse. The
landscape has a low sensitivity to change which would result in a minor adverse
significance of effect (prior to mitigation).
Effects on Views
10.128 On completion (and prior to mitigation) some receptors with views towards the
application site (including the underground and overground cable route) would
experience negative visual effects. Visual effects anticipated on completion are
identified in Tables 10.10 to 10.15 (in Appendix 10.2) and range from moderate to
minor adverse effects for a small number of visual receptors closest to the
application site and those at elevated viewpoints, with more distant and also low
lying visual receptors generally experiencing a neutral effect.
10.129 Figures 10.17 to 10.23 present views of converter station and substation proposals
from the photomontage viewpoint locations shown on Figure 10.3.
10.130 Table 10.6 below summarises judgements made when assessing anticipated visual
effects of the Proposed Development (including the underground and overground
cable route) on each of the identified visual receptors on completion.
Table 10.6: Summary of Anticipated Visual Effects on Completion
Visual Receptor
Sensitivity
Importance
of view
Magnitude
of Effect
Significance
of Effect On
Completion
Effects on Views from Public Rights of Way
1.1a
Saxon Shore Way at
Former Richborough
Power Station
High
Low
Moderate
adverse
Moderate
adverse
1.1b
Saxon Shore Way
near Roman Fort
High
Low
Negligible
Neutral
1.1c
Saxon Shore Way at
Boxlees Hill (south of
Minster) including
footpath connections
south of Marsh Farm
Road
High
Low
Negligible
Neutral
1.1d
Saxon Shore Way at
Plucks Gutter
High
Low
Negligible
Neutral
1.1e
Saxon Shore Way at
Royal St George’s Golf
Club
High
Low
Negligible
Neutral
1.2a
Stour Valley Walk at
Sandwich
Flats/Prince’s Golf
Links
High
Low
Negligible
Neutral
247
Visual Receptor
Sensitivity
Importance
of view
Magnitude
of Effect
1.2b
Short section of Stour
Valley Walk at Cooper
Street
High
Low
Negligible
Significance
of Effect On
Completion
Neutral
1.3a
Thanet Coastal Path at
Pegwell Bay Country
Park
High
Low
Low
adverse
Minor
adverse
1.3b
Thanet Coastal Path
between Cliffs End
and the edge of
Ramsgate
High
Low
Negligible
Neutral
1.4
PROW at Potts Farm
Drove
High
Low
Negligible
Neutral
1.5
PROW at Goldstone
Drove (and PROW
which runs parallel
0.2km to the west)
High
Low
Negligible
Neutral
1.6
PROW at Westmarsh
Drove (and PROW
which runs broadly
parallel to the east)
High
Low
Negligible
Neutral
1.7a
&b
PROW network east of
Minster
High
Low
Negligible
Neutral
1.7c
PROW west of Cliffs
End
High
Low
Low
adverse
Minor
adverse
1.8
PROW southwest of
Minster
High
Low
Negligible
Neutral
1.9a
PROW south of
Manston/Manston
Road
High
Low
Negligible
Neutral
1.9b
PROW south of
Nethercourt (Chalk
Hill) also Sustrans
Regional Route 15
High
Low
Negligible
Neutral
1.10
Network of PROW
around Monkton
Marshes/Docker Hill
High
Low
Negligible
Neutral
1.11
PROW between
Brookestreet Farm and
East Street
High
Low
Negligible
Neutral
1.12
PROW north of
Monkton/Minster
High
Low
Negligible
Neutral
Effects on Views from Public Open Space and Outdoor Tourist Attractions
2.1
Pegwell Bay Country
Park
High
Low
Low
adverse
Minor
adverse
2.2
Stonelees Nature
Reserve
High
Low
Low
adverse
Minor
adverse
248
Visual Receptor
Sensitivity
Importance
of view
Magnitude
of Effect
2.3
St Augustine’s Cross
High
Low
Low
adverse
Significance
of Effect On
Completion
Minor
adverse
2.4
Richborough Roman
Fort
High
Moderate
Low
adverse
Minor
adverse
2.5
Richborough Roman
Amphitheatre
High
Moderate
Negligible
Neutral
2.6
Pegwell Bay picnic
area and beach
High
Low
Negligible
Neutral
2.7
Sandwich boat trips up
River Stour
High
Low
Moderate
adverse
Moderate
adverse
2.8
Sandwich boat trips to
Pegwell Bay
High
Low
Negligible
Neutral
2.9
West Cliff, Ramsgate
High
Low
Negligible
Neutral
Effects of Views from Roads and Rail
3.1a
Old A256 Sandwich
Road (north of
converter station and
substation site,
including site
entrance) also
Sustrans Regional
Route 15
Low/
Moderate
Low
Low
adverse
Neutral
(Minor
adverse for
footpath and
cycleway
users)
3.1b
New A256 bypass
(East Kent Access
Road Phase 2)
Low
Low
Negligible
Neutral
3.1c
A256 Ramsgate Road
(south of converter
station and substation
site) also Sustrans
Regional Route 15
Low
Low
Negligible
Neutral
3.2
Ebbsfleet Lane (north
and south of new A256
bypass)
Low
Low
Negligible
Neutral
3.3
Marsh Farm Road
(rural lane south of
Minster)
Moderate
Low
Negligible
Neutral
3.4
Richborough Road
between Roman
Amphitheatre and
Roman Fort
Low
Low
Negligible
Neutral
3.5
Grinsell Hill and other
rural lanes northeast of
Minster and Cottington
Road and Thorne Hill
(Sustrans Regional
Route 15)
Moderate
Low
Low
adverse
Minor
adverse
249
Visual Receptor
Sensitivity
Importance
of view
Magnitude
of Effect
Significance
of Effect On
Completion
Neutral
3.6
Pegwell Road,
Ramsgate
Low
Low
Negligible
3.7
A299 Canterbury Road
West between Mount
Pleasant and
Ramsgate
Low
Low
Low
adverse
Neutral
3.8
A256 Haine Road (on
western side of
Ramsgate, north of
intersection with A299)
Low
Low
Negligible
Neutral
3.9
Other minor roads
south of River Stour
Low
Low
Negligible
Neutral
3.10
Manston Road (either
side of A256)
Low
Low
Negligible
Neutral
3.11
A299 Canterbury Road
West (between
Monkton roundabout
and Mount Pleasant)
including the footpath
and cycleway to the
south
Low/
Moderate
Low
Negligible
Neutral
3.12
A253 Island Road
(Gore Street to
Monkton roundabout)
Low
Low
Negligible
Neutral
3.13
Minor road between
Plucks Gutter and
Gore Street
Low
Low
Negligible
Neutral
3.14
A28 Canterbury Road
at St Nicholas at Wade
Low
Low
Negligible
Neutral
3.15
Railway line from
Ramsgate to Minster
Low
Low
Negligible
Neutral
3.16
Railway line from
Minster to Sandwich
Low
Low
Low
adverse
Neutral
3.17
Railway line west of
Minster (along Stour
Valley)
Low
Low
Negligible
Neutral
Effects on Views from Private Residences
A1
Houses on Ebbsfleet
Lane near the junction
with Sandwich Road
(old A256)
Moderate
Low
Low
adverse
Minor
adverse
A2a
Ebbsfleet Farm
Moderate
Low
Low
adverse
Minor
adverse
A2b
No. 1 Ebbsfleet Farm
Cottages on Ebbsfleet
Lane
Moderate
Low
Low
adverse
Minor
adverse
250
Visual Receptor
Sensitivity
Importance
of view
Magnitude
of Effect
A3
House between
industrial units on
Ramsgate Road
(A256)
High
Low
Low
adverse
Significance
of Effect On
Completion
Minor
adverse
A4a
Houses at Sevenscore
High
Low
Negligible
Neutral
A4b
Houses at/near Thorne
Farm
Moderate
Low
Low
adverse
Minor
adverse
A5
Houses on
Whitehouse Drove
High
Low
Negligible
Neutral
A6a
Cliffs End (south of
railway line)
Moderate/
High
Low
Negligible
Neutral
A6b
Cliffs End (north of
railway line)
Moderate/
High
Low
Low
adverse
Minor
adverse
A7
Castle Road,
Richborough
Moderate
Low
Low
adverse
Minor
adverse
A8
Houses on Rubery
Drove
Moderate/
High
Low
Negligible
Neutral
A9
House west of
Richborough Farm
High
Low
Negligible
Neutral
A10
Houses near Guston
Farm, Potts Farm and
Lower Goldstone
Moderate
Low
Negligible
Neutral
A11
Minster and surrounds
Moderate
Low
Low
adverse
Minor
adverse
A12
House at Little
Cliffsend Farm and
Coastguard Cottages
Moderate/
High
Low
Negligible
Neutral
A13
Nethercourt,
Ramsgate
High
Low
Negligible
Neutral
A14
Pegwell, Ramsgate
Moderate
Low
Negligible
Neutral
A15
Houses at Hoo
Moderate
Low
Negligible
Neutral
A16
Stanner Court
residential tower block
and new housing
development on
Manston Road,
Ramsgate
High
Low
Negligible
Neutral
A17
East Stourmouth and
surrounds
Moderate
Low
Negligible
Neutral
A18
Sandwich
Moderate
Low
Negligible
Neutral
A19
Sarre
High
Low
Negligible
Neutral
A20
Upstreet
Moderate
Low
Negligible
Neutral
A21
East Street
Moderate
Low
Negligible
Neutral
251
Visual Receptor
Sensitivity
Importance
of view
Magnitude
of Effect
A22
High
Low
Negligible
St Nicholas at Wade
Significance
of Effect On
Completion
Neutral
Effects on Views from Private Golf Courses and Sports Facilities
B1
Stonelees Golf Centre
Moderate
Low
Negligible
Neutral
B2
St Augustine’s Golf
Club
Moderate
Low
Negligible
Neutral
B3
Manston Golf Centre
near Ramsgate
Moderate
Low
Negligible
Neutral
B4
Prince’s Golf Links
near Ramsgate
Moderate
Low
Negligible
Neutral
B5
Royal St George’s Golf
Club near Sandwich
Moderate
Low
Negligible
Neutral
B6
BayPoint sports
complex
Low
Low
Low
adverse
Neutral
Effects on Views from Private Businesses
C1
Businesses and
industrial units near
the site entrance and
to the south of the
converter station and
substation site on the
A256 Ramsgate Road
Low
Low
Low
adverse
Neutral
C2
BayPoint sports
complex
Low
Low
Negligible
Neutral
C3a
The Sportsman Inn
Public House, old
A256 Sandwich Road
Moderate
Low
Negligible
Neutral
C3b
Pegwell Bay Service
Station, Sandwich
Road
Low
Low
Negligible
Neutral
C4
Pegwell Bay Hotel,
Pegwell Road
High
Low
Negligible
Neutral
C5
The Sir Stanley Gray
and Belle Vue Public
Houses, Pegwell Road
Moderate
Low
Negligible
Neutral
C6
Lord of the Manor
Public House off A299
Moderate
Low
Negligible
Neutral
C7
Industrial Park,
Laundry Road, Minster
Low
Low
Low
adverse
Neutral
C8
Holiday Inn and
Premier Inn, Minster
Moderate
Low
Low
adverse
Minor
adverse
C9
Wayside Caravan
Park, Minster
High
Low
Low
adverse
Minor
adverse
252
Visual Receptor
Sensitivity
Importance
of view
Magnitude
of Effect
C10
High
Low
Negligible
Sarre Windmill
Significance
of Effect On
Completion
Neutral
Mitigation
Construction Phase
10.131 Mitigation of likely construction effects on landscape and views would be largely
achieved through the implementation of a Construction Environmental Management
Plan which would include the following measures:




Protection of trees to be retained to BS 5837 (2005), for the duration of the
construction works;
Screening on-site activity where practical whilst at the same time not being a
highly negative visual distraction in itself;
Management of site traffic to and from site, minimising excessive traffic
movement on the surrounding road network; and
Management of working times to minimise visual effects of construction in
evenings and at weekends when residential and sports and leisure receptors
may be most likely to be present.
Operational Phase
10.132 Mitigation of likely long-term effects on landscape and views would be largely
achieved through the following measures:

The use of colour graded cladding to the converter station building, ranging
from a muted green at the building’s base to off-white at the roofline. This will
minimise landscape and visual effects and particularly the effect on views
where the building sits on the horizon. Due to its lower height the substation
building will be clad in a single colour (muted green); and

Tree and shrub planting proposed on the western boundary of the converter
station and substation site to partly filter and screen some views of the
converter station from the west and northwest (in particular from the Saxon
Shore Way and from River Stour) and to filter and screen views of the
substation proposals from the south (in particular from the Saxon Shore Way).
See Figure 10.4 Planting Proposals.
10.133 In addition to the above, the wider proposals for Richborough Energy Park include
the implementation of new planting as part of a separate but closely related
planning application (submitted by Richborough A Limited (RAL)) for a new estate
road to the perimeter of the former Richborough Power Station site (see section on
cumulative effects below). These planting proposals have been referenced as part
of this planning application and will include replacement tree planting along the
eastern and north eastern site boundaries (partly mitigating trees loss to
accommodate the new road), new native trees, shrubs and fruit trees near the site
entrance, existing trees and shrubs on the northern site boundary being retained
and enhanced with new native tree planting, and new native trees and shrubs along
part of the sites western boundary adjacent the River Stour in front of new
fencing. In the unlikely event that the estate road landscaping proposals are not
253
implemented, National Grid Nemo Link Limited (NGNLL) proposes to enter into
arrangements with RAL to ensure the landscaping and estate road proposals are
delivered and would be prepared to enter into a planning obligation to this
effect. These landscape proposals are considered below as part of the proposed
converter station and substation development.
Residual Impacts
Residual Effects on Landscape Character during the Construction Period
10.134 With mitigation the residual temporary effects on landscape character during the
construction period would remain moderate adverse.
Residual Effects on Views during the Construction Period
10.135 Mitigation measures would help reduce temporary construction effects on visual
receptors, although the significance of effect on views (as identified in Tables 10.10
to 10.15 in Appendix 10.2) would remain the same. These visual effects would
range from moderate to minor adverse effects for a small number of visual
receptors closest to the site and those at elevated viewpoints, with more distant and
also low lying visual receptors experiencing a neutral effect.
Residual Effects on Landscape (with mitigation and after 15 years establishment)
10.136 Mitigation measures would reduce the significance of effect of the proposed
converter station and substation on landscape character to minor adverse to
neutral. New planting around the site and at the site entrance would improve the
landscape quality of the site and would assist in integrating the Proposed
Development into the site’s context.
10.137 The significance of effect on landscape of the underground cable route, and
overground section capped with chalk, would remain neutral on completion with
mitigation and after establishment.
Residual Effects on Views (with mitigation and after 15 years establishment)
10.138 The residual effects of the Proposed Development, including the implementation of
planting proposed to the western site boundary and planting proposed as part of the
wider Richborough Energy Park (relating to the estate road to the site perimeter),
have been taken to be those effects still remaining after approximately 15 years
when new tree and shrub planting will be maturing.
10.139 The greatest residual effects anticipated on public receptors, following mitigation
and 15 years’ establishment would be moderate to minor adverse. This moderate
to minor negative significance of effect on views would be experienced from the
section of the Saxon Shore Way (receptor 1.1a) adjacent to the converter station
and substation site and by river users on the Stour (receptor 2.7) adjacent to the
converter station and substation site. Although it would be difficult to screen the
development entirely from these viewpoints, tree and shrub planting along the
riverside would screen the majority of the substation GIS building and external
equipment, external equipment relating to the converter station and part of the
converter station building in some views looking north, east, and southeast. Three
public receptors would experience a minor adverse to neutral significance of effect
on views following mitigation and 15 years’ establishment, including PRoW west of
Cliffs End (receptor 1.7c), Richborough Roman Fort (receptor 2.4) and Grinsell Hill
254
and other rural lanes northeast of Minster and Cottington Road and Thorn Hill
(receptor 3.5). All other public receptors would experience a neutral significance of
effect on views following mitigation and 15 years establishment. New tree planting
to the site perimeter (part of the wider Richborough Energy Park estate road works)
and new tree and shrub planting along part of the western site boundary, in addition
to existing intervening vegetation in the view, would screen the majority of the
substation development and external equipment associated with the converter
station, resulting in views of the upper part of the converter station building only.
Generally these views would not be different to existing views and some aspects of
the views would improve.
10.140 The greatest residual effects anticipated on private receptors, following mitigation
and 15 years’ establishment would be minor adverse to neutral and relates to views
from five receptors: Ebbsfleet Farm (A2a), No.1 Ebbsfleet Farm Cottages (A2b),
Castle Road, Richborough (A7), Minster and the surrounds (A11), and Wayside
Caravan Park, Minster (C9). The significance of residual effects of the Proposed
Development on all other private views following the establishment of planting
mitigation measures would be neutral. Although it would be difficult to screen the
development entirely from these viewpoints, new tree and shrub planting to the site
perimeter would screen the majority of the substation development and external
equipment associated with the converter station, resulting in views of the upper part
of the converter station building only, which would not be discernibly different to
existing views.
10.141 Table 10.7 overleaf summarises the anticipated residual visual effects on each
identified receptor following 15 years’ establishment post mitigation, alongside the
visual effects on completion of the Proposed Development previously identified.
255
Table 10.7: Summary of Anticipated Residual Visual Effects
Visual Receptor
Significance of
Visual Effect On Completion
Significance of
Visual Effect –
with mitigation
and after
approximately
15 years
Effects on Views from Public Rights of Way
1.1a
Saxon Shore Way at Former
Richborough Power Station
Moderate adverse
Moderate to Minor
adverse
1.1b
Saxon Shore Way near Roman Fort
Neutral
Neutral
1.1c
Saxon Shore Way at Boxlees Hill
(south of Minster) including footpath
connections south of Marsh Farm
Road
Neutral
Neutral
1.1d
Saxon Shore Way at Plucks Gutter
Neutral
Neutral
1.1e
Saxon Shore Way at Royal St
George’s Golf Club
Neutral
Neutral
1.2a
Stour Valley Walk at Sandwich
Flats/Prince’s Golf Links
Neutral
Neutral
1.2b
Short section of Stour Valley Walk
at Cooper Street
Neutral
Neutral
1.3a
Thanet Coastal Path at Pegwell
Bay Country Park
Minor adverse
Neutral
1.3b
Thanet Coastal Path between Cliffs
End and the edge of Ramsgate
Neutral
Neutral
1.4
PROW at Potts Farm Drove
Neutral
Neutral
1.5
PROW at Goldstone Drove (and
PROW which runs parallel 0.2km to
the west)
Neutral
Neutral
1.6
PROW at Westmarsh Drove (and
PROW which runs broadly parallel
to the east)
Neutral
Neutral
1.7a
&b
PROW network east of Minster
Neutral
Neutral
1.7c
PROW west of Cliffs End
Minor adverse
Minor adverse to
Neutral
1.8
PROW southwest of Minster
Neutral
Neutral
1.9a
PROW south of Manston/Manston
Road
Neutral
Neutral
1.9b
PROW south of Nethercourt (Chalk
Hill) also Sustrans Regional Route
15
Neutral
Neutral
1.10
Network of PROW around Monkton
Marshes/Docker Hill
Neutral
Neutral
256
Visual Receptor
Significance of
Visual Effect On Completion
1.11
PROW between Brookestreet Farm
and East Street
Neutral
Significance of
Visual Effect –
with mitigation
and after
approximately
15 years
Neutral
1.12
PROW north of Monkton/Minster
Neutral
Neutral
Effects on Views from Public Open Space and Outdoor Tourist Attractions
2.1
Pegwell Bay Country Park
Minor adverse
Neutral
2.2
Stonelees Nature Reserve
Minor adverse
Neutral
2.3
St Augustine’s Cross
Neutral
Neutral
2.4
Richborough Roman Fort
Minor adverse
Minor adverse to
Neutral
2.5
Richborough Roman Amphitheatre
Neutral
Neutral
2.6
Pegwell Bay picnic area and beach
Neutral
Neutral
2.7
Sandwich boat trips up River Stour
Moderate adverse
Moderate to Minor
adverse
2.8
Sandwich boat trips to Pegwell Bay
Neutral
Neutral
2.9
West Cliff, Ramsgate
Neutral
Neutral
Effects of Views from Roads and Rail
3.1
Old A256 Sandwich Road (north of
converter
a
station and substation site,
including site entrance) also Sustrans
Regional Route 15
Neutral
(Minor adverse for
footpath and
cycleway users)
Neutral
3.1
New A256 bypass (East Kent Access
Road
b Phase 2)
Neutral
Neutral
3.1
A256 Ramsgate Road (south of converter
station
c and substation site) also Sustrans
Regional Route 15
Neutral
Neutral
3.2
Ebbsfleet Lane (north and south of new
A256 bypass)
Neutral
Neutral
3.3
Marsh Farm Road (rural lane south of
Minster)
Neutral
Neutral
3.4
Richborough Road between Roman
Amphitheatre and Roman Fort
Neutral
Neutral
3.5
Grinsell Hill and other rural lanes
northeast of Minster and Cottington Road
and Thorne Hill (Sustrans Regional Route
15)
Minor adverse
Minor adverse to
Neutral
3.6
Pegwell Road, Ramsgate
Neutral
Neutral
3.7
A299 Canterbury Road West between
Mount Pleasant and Ramsgate
Neutral
Neutral
3.8
A256 Haine Road (on western side of
Ramsgate, north of intersection with
A299)
Neutral
Neutral
257
Visual Receptor
Significance of
Visual Effect On Completion
3.9
Other minor roads south of River Stour
Neutral
Significance of
Visual Effect –
with mitigation
and after
approximately
15 years
Neutral
3.1
Manston Road (either side of A256)
0
Neutral
Neutral
3.1
A299 Canterbury Road West (between
Monkton
1
roundabout and Mount Pleasant)
including the footpath and cycleway to the
south
Neutral
Neutral
3.1
A253 Island Road (Gore Street to
Monkton
2
roundabout)
Neutral
Neutral
3.1
Minor road between Plucks Gutter and
Gore
3 Street
Neutral
Neutral
3.1
A28 Canterbury Road at St Nicholas at
Wade
4
Neutral
Neutral
3.1
Railway line from Ramsgate to Minster
5
Neutral
Neutral
3.1
Railway line from Minster to Sandwich
6
Neutral
Neutral
3.1
Railway line west of Minster (along Stour
Valley)
7
Neutral
Neutral
Effects on Views from Private Residences
A1
Houses on Ebbsfleet Lane near the
junction with Sandwich Road (old A256)
Minor adverse
Neutral
A2
Ebbsfleet Farm
a
Minor adverse
Minor adverse to
Neutral
A2
No. 1 Ebbsfleet Farm Cottages on
Ebbsfleet
b
Lane
Minor adverse
Minor adverse to
Neutral
A3
House between industrial units on
Ramsgate Road (A256)
Minor adverse
Neutral
A4
Houses at Sevenscore
a
Neutral
Neutral
A4
Houses at/near Thorne Farm
b
Minor adverse
Neutral
A5
Houses on Whitehouse Drove
Neutral
Neutral
A6
Cliffs End (south of railway line)
a
Neutral
Neutral
A6
Cliffs End (north of railway line)
b
Neutral
Neutral
A7
Castle Road, Richborough
Minor adverse
Minor adverse to
Neutral
A8
Houses on Rubery Drove
Neutral
Neutral
258
Visual Receptor
Significance of
Visual Effect On Completion
A9
House west of Richborough Farm
Neutral
Significance of
Visual Effect –
with mitigation
and after
approximately
15 years
Neutral
A1
Houses near Guston Farm, Potts Farm
and0Lower Goldstone
Neutral
Neutral
A1
Minster and surrounds
1
Minor adverse
Minor adverse to
Neutral
A1
House at Little Cliffsend Farm and
Coastguard
2
Cottages
Neutral
Neutral
A1
Nethercourt, Ramsgate
3
Neutral
Neutral
A1
Pegwell, Ramsgate
4
Neutral
Neutral
A1
Houses at Hoo
5
Neutral
Neutral
A1
Stanner Court residential tower block and
new6housing development on Manston
Road, Ramsgate
Neutral
Neutral
A1
East Stourmouth and surrounds
7
Neutral
Neutral
A1
Sandwich
8
Neutral
Neutral
A1
Sarre
9
Neutral
Neutral
A2
Upstreet
0
Neutral
Neutral
A2
East Street
1
Neutral
Neutral
A2
St Nicholas at Wade
2
Neutral
Neutral
Effects on Views from Private Golf Courses and Sports Facilities
B1
Stonelees Golf Centre
Neutral
Neutral
B2
St Augustine’s Golf Club
Neutral
Neutral
B3
Manston Golf Centre near Ramsgate
Neutral
Neutral
B4
Prince’s Golf Links near Ramsgate
Neutral
Neutral
B5
Royal St George’s Golf Club near
Sandwich
Neutral
Neutral
B6
BayPoint sports complex
Neutral
Neutral
Effects on Views from Private Businesses
259
Visual Receptor
Significance of
Visual Effect On Completion
C1
Businesses and industrial units near the
site entrance and to the south of the
converter station and substation site on
the A256 Ramsgate Road
Neutral
Significance of
Visual Effect –
with mitigation
and after
approximately
15 years
Neutral
C2
BayPoint sports complex (Great Stonar)
Neutral
Neutral
C3
a
The Sportsman Inn Public House, old
A256 Sandwich Road
Neutral
Neutral
C3
b
Pegwell Bay Service Station, Sandwich
Road
Neutral
Neutral
C4
Pegwell Bay Hotel, Pegwell Road
Neutral
Neutral
C5
The Sir Stanley Gray and Belle Vue
Public Houses, Pegwell Road
Neutral
Neutral
C6
Lord of the Manor Public House off A299
Neutral
Neutral
C7
Industrial Park, Laundry Road, Minster
Neutral
Neutral
C8
Holiday Inn and Premier Inn, Minster
Minor adverse
Neutral
C9
Wayside Caravan Park, Minster
Minor adverse
Minor adverse to
Neutral
C1
0
Sarre Windmill
Neutral
Neutral
Cumulative Impacts
10.142 Potential cumulative effects on landscape and views from the onshore elements of
the Nemo Link in combination with other components of the Project (i.e. UK, French
and Belgian subsea cables and Belgian onshore infrastructure) are described in
Chapter 16.
10.143 Potential cumulative effects of the Nemo Link UK onshore infrastructure in
combination with the grid connection required to facilitate the operation of the Nemo
Link are described in Chapter 17.
10.144 The converter station and substation site falls within the wider Richborough Energy
Park, which occupies the site of the former Richborough power station.
Consideration has been given to other Richborough Energy Park proposals that
require planning permission, listed below:
1
2
Estate road and structural planting around the perimeter of the former
Richborough Power Station; and
Richborough Peaking Plant Facility to the south of the proposed converter
station.
10.145 Other proposals, at different stages of the planning process, exist in the site’s
context. These proposals include; a Materials Recycling Facility (with planning
permission) proposed south of the converter station and substation site; a flood
defence scheme in the vicinity of the proposed underground cable route at Pegwell
260
Bay (with planning permission); glasshouses, rainwater storage tanks and a pack
house at Ebbsfleet Lane, north-east of the converter station and substation site
(awaiting a planning decision); and a proposal for a 5MW solar farm on land west of
the converter station and substation site, not yet submitted for planning permission.
Table 1.2 of Chapter 1 provides full details of other unrelated projects subject to the
cumulative assessment below.
10.146 The following paragraphs consider the cumulative effect of the proposed converter
station, substation and underground and overground cable on completion (with
mitigation and after establishment), in combination with each of the six development
proposals referred to above.
Richborough A Ltd Estate Road and Structural Planting (awaiting planning decision)
10.147 The new estate road will comprise new concrete hardstanding around the perimeter
of the former Richborough power station site, partial removal of trees along the
eastern, north eastern and northern boundaries of the former power station site and
new planting to the site perimeter. Residual landscape and visual effects (with
mitigation and following establishment) recorded above in relation to the proposed
converter station and substation includes consideration of new planting associated
with the new estate road.
10.148 There will be no temporary construction effects on landscape and views as the
estate road will be constructed before construction works commence in relation to
the proposed converter station, substation and underground cable works.
10.149 The new road and proposed converter station and substation would be
concentrated within the former Richborough power station site and new tree
planting will partly mitigate for tree loss resulting from the new road. Cumulative
residual effects on landscape character (with mitigation and after establishment)
would be minor adverse to neutral, as recorded in relation to the proposed
converter station and substation.
10.150 There will be cumulative effects on views from receptors in close proximity to the
site, including the Saxon Shore Way and River Stour to the northwest, west and
south of the converter station and substation site, and from the A256 to the east
(including motorists and footpath and cycleway users). Concrete hardstanding and
site traffic would be visible from these receptors along with the converter station and
substation and associated outdoor equipment. Tree removal on the eastern
boundary will increase the extent of both developments visible in the view from the
A256. New tree and shrub planting along the eastern boundary and at the site
entrance will provide some filtering and screening of site traffic using the new road
and the converter station and substation proposals, particularly as planting matures
overtime.
10.151 Southerly views of site traffic on the new road are anticipated to be glimpsed at
most (in front of the proposed converter station and substation development)
between intervening trees and above intervening scrub vegetation. Oblique views
from the rear garden belonging to a residential property to the south between
industrial units on the A256 are anticipated of both the new road and Proposed
Development. However tree and shrub planting proposed to the western site
boundary would mature overtime, partly filtering and screening the substation GIS
building and outdoor substation elements.
261
10.152 The significance of cumulative residual visual effects (with mitigation and after
establishment) will be no greater than recorded for the proposed converter station
and substation, including new planting associated with the estate road and the
converter station site. Cumulative residual visual effects will range between
moderate to minor adverse and neutral for receptors in close proximity to the site.
Cumulative residual effects are not anticipated at greater distances and on low lying
ground due to screening of the new road by intervening vegetation and
development.
Richborough Peaking Plant Facility, South of the Proposed Converter Station
(awaiting planning decision)
10.153 The Peaking Plant Facility will occupy an area of approximately 1.13 hectares
compared to over 7 hectares occupied by the proposed converter station and
substation site. The Peaking Plant will comprise fifty three diesel fired generators
(approximately 2.6m high) and four chimney stacks (approximately 35m high) with
associated fuel storage, parking and access. A 4m high fence will secure the site
perimeter and a 3m high acoustic barrier will be installed around the facility beyond
site planting.
10.154 Planting will comprise densely planted native trees, shrubs and fruit trees,
(minimum 10m wide planting area) on the eastern and north eastern site boundary
with the A256. Along the southern boundary (adjoining the site of the proposed
Materials Recycling Facility discussed below) will be a mix of scattered trees within
a minimum 5m wide planting area. Existing trees along the eastern and southern
boundaries of the site will be retained where possible. Planting on the western site
boundary with the River Stour will include densely planted shrub planting beneath
existing overhead lines, and shrubs and or fruit trees adjacent. Planting around the
proposed Peaking Plant Facility will provide partial filtering and screening of the
proposed 3m high acoustic fence beyond proposed perimeter fencing.
10.155 There will be no temporary construction effects on landscape and views as the
proposed Peaking Plant Facility will be constructed before construction works
commence in relation to the proposed converter station, substation and
underground (and overground) cable works.
10.156 The proposed Peaking Plant will be consistent with the character of the A256
coastal corridor between Ramsgate and Sandwich; the landscape has a low
sensitivity to this type of change. The Peaking Plant chimney stacks will be the
tallest component of both the Peaking Plant and the proposed converter station and
substation; however, the proposed chimneys will be seen within the context of the
30.8m high converter station building. The scale and massing of the proposed
Peaking Plant will result in a relatively small addition to the built form of the
converter station located to the north. Cumulative residual effects (with mitigation
and after establishment) on landscape character will be minor adverse to neutral, as
recorded in relation to the proposed converter station and substation.
10.157 On completion there will be intervisibility between the proposed Peaking Plant and
the proposed converter station and substation. However visual receptors will not be
sensitive to cumulative visual effects as they will be workers at their workplace and
both developments are industrial in character.
10.158 On completion views of the proposed converter station and substation in
combination with the Peaking Plant Facility would extend across the approximate
ZVI identified in Figure 10.2. However, in the majority of views within the ZVI, the
262
proposed converter station and substation, and the Peaking Plant at Richborough
Energy Park, would form a very minor component of the view, which will be of the
upper part of the converter station building and the top of Peaking Plant chimneys in
some views set within a well vegetated and already industrial landscape. It is
anticipated that visitors to Richborough Roman Fort and nearby residents, residents
on Ebbsfleet Lane, and residents and the PROW network between Minster and
Cliffs End will experience cumulative visual effects. In each case these views will
be similar to existing views, and from some of these locations views are already
restricted to an extent by built form and vegetation.
10.159 Residual cumulative visual effects will be experienced by a few sensitive visual
receptors in closer proximity, particularly users of the Saxon Shore Way and river
users to the immediate south of Richborough Energy Park. Overtime planting along
the western boundary of the converter station site and proposed to the perimeter of
the Peaking Plant Facility will mature reducing visibility of part of these
developments, particularly from the Saxon Shore Way and River Stour.
10.160 Overall the cumulative residual visual effects (with mitigation and after
establishment) of the proposed converter station and substation development with
the Peaking Plant will be no greater than moderate to minor adverse.
Materials Recycling Facility, South of the Proposed Converter Station Site (planning
permission granted)
10.161 The proposed Materials Recycling Facility (MRF) comprises two sites south of the
proposed converter station and substation site (and proposed Peaking Plant
referred to above). Development proposed on Site A (south of the Stonar Cut) will
comprise the replacement of the existing materials processing facility with an ‘Lshaped’ building (17.2m high) of a similar scale and appearance to the existing
waste processing shed at the northern end of this site. The northern part of the site
will remain as existing.
10.162 Development proposed on Site B (immediately south of the proposed Peaking
Plant) will comprise the transfer of the existing materials processing facility from the
southern part of Site A to the central part of Site B, and two new buildings to house
an anaerobic digester plant (85m x 37m x 14.25m high) and a maturation shed
(75m x 37m x 14.4m high). Other components include a staff and office building, a
soil washing plant, and alterations to the site access road. 8 metre high steel sheet
walling (similar to that used at Site A) is proposed to the Ramsgate Road frontage
and at the northern and southern ends of the site. Vehicle parking, a weighbridge
and wheel washing facilities will also be provided within the site.
10.163 Residual cumulative effects on landscape and views during construction are not
anticipated as the proposed Materials Recycling Facility is likely to be constructed
before the converter station and substation construction works commence. Should
construction works be undertaken at the same time, cumulative landscape and
visual effects will be concentrated in an existing industrial area adjacent the A256
and will be temporary, for a short period of time.
10.164 Development proposed within sites A and B above will relocate the existing
materials processing facility within site A to site B further north on the A256, and will
introduce new buildings to cleared brownfield land south of the proposed converter
station and substation site. The MRF will develop an existing gap in development,
on brownfield land, within the A256 corridor between Ramsgate and Sandwich, and
will be of a similar type and character as existing adjacent development; the
263
landscape has a low sensitivity to this type of change. Cumulative residual effects
(with mitigation and after establishment) on landscape character of the proposed
Materials Recycling Facility and proposed converter station and substation will be
minor adverse to neutral, as recorded in relation to the proposed converter station
and substation.
10.165 On completion (with mitigation) there will be some intervisibility between the
proposed MRF on site B, and the proposed converter station and substation. Views
would also comprise the proposed Peaking Plant sited between these
developments. Visual receptors will not be sensitive to cumulative visual effects as
they will be workers at their workplace, surrounded by development of a similar
industrial character.
10.166 On completion (with mitigation) there will be residual cumulative visual effects on
motorists, pedestrians and cyclists along the A256, walkers along the Saxon Shore
Way including near the Roman Fort, boat users on the River Stour, rail passengers
on the Minster to Sandwich railway line, and residents living at the house on the
A256 between industrial units. In general Proposed Development will be visible in a
greater extent of some views than existing; however development will be similar in
character to existing industry in the surrounding area.
10.167 The significance of cumulative residual visual effects (with mitigation and after
establishment) will be no greater than recorded for the proposed converter station
and substation. Cumulative residual visual effects will range between moderate to
minor adverse and neutral for receptors in close proximity to the site. Cumulative
residual effects are not anticipated at greater distances and on low lying ground due
to screening of the new road by intervening vegetation and development.
Pegwell Bay Flood Defence Scheme (planning permission granted)
10.168 The proposed flood defence scheme (along the Pegwell Bay coastline where the
flood defences are at their lowest elevation) will comprise two new flood defence
elements; a new concrete flood wall (141 metres long and up to 1.2 metres high) to
the north of the petrol station on the A256; and an earth embankment (257 metres
long and up to 1 metre high) to the south of the petrol station.
10.169 No temporary cumulative effects on landscape and views are anticipated as the
flood defence works will likely be completed before cable installation works start in
the vicinity of flood defence works.
10.170 On completion and following reinstatement works, there will be no cumulative
residual effects on landscape and views where the cable is proposed underground.
Where the cable route is proposed overground and capped with chalk
(approximately 1m high), cumulative residual effects on landscape and views will be
neutral. Raised ground and tree removal within the northern part of Pegwell Bay
Country Park to accommodate the proposed cable route will be seen within the
context of the proposed flood defence, (comprising an earth embankment up to 1
metre high in this locality) from Pegwell Bay including part of the Thanet Coastal
Path (1.3a) and the A256 (3.1a).
10.171 Residual cumulative effects on landscape and views on completion of the proposed
flood defence scheme and the proposed converter station will also be neutral where
the top of the converter station is visible above intervening trees in combination with
the flood defence scheme from Pegwell Bay.
264
Erection of Glasshouses, Water Storage Tanks and Pack House (awaiting planning
decision)
10.172 A planning application has been submitted for glasshouses (4.7m high to the apex),
three rainwater storage tanks (3.04m above ground) and a pack house (5.52 metres
to ridge height) for the grading and packing of roses, storage of equipment and to
provide staff facilities at Ebbsfleet Lane. This application site is northeast of the
proposed converter station and substation site.
10.173 Temporary cumulative effects on landscape and views during construction are not
anticipated as proposed glasshouses, water storage tanks and pack house will
likely be constructed before converter station and substation construction works and
cable installation works commence.
10.174 On completion residual cumulative effects (with mitigation) on landscape will be
minor adverse to neutral, as recorded in relation to the proposed converter station
and substation development. Proposed Developments will be consistent with the
character of the A256 coastal corridor between Ramsgate and Sandwich, which
comprises industrial and agricultural development and includes the larger scale
anaerobic digester being built on the opposite side of the new A256 bypass to the
glasshouse site, and existing solar farms; one adjacent the proposed glasshouse
site and the other west of the new A256 bypass between the wastewater treatment
works and the anaerobic digester.
10.175 Residual cumulative effects are anticipated in views from receptors including:






Houses on Ebbsfleet Lane near the junction with the old A256 Sandwich Road
looking west (A1);
Ebbsfleet Farm looking southwards (A2a);
No. 1 Ebbsfleet Farm Cottages on Ebbsfleet Lane looking southwards (A2b);
Stonelees Golf Centre looking southwest (B1);
New A256 bypass looking southwards (3.1b); and
Ebbsfleet Lane, where not screened by intervening roadside hedgerow (3.2).
10.176 Cumulative residual visual effects (with mitigation and after establishment) will be
no greater than effects recorded in relation to the proposed converter station and
substation on completion (with mitigation), ranging from minor adverse to neutral
(recorded for Ebbsfleet Farm and No.1 Ebbsfleet Farm Cottages), to neutral effects
for visual receptors closest to both sites. Overtime new tree planting along the new
A256 bypass will mature.
Solar Farm on the ‘Banana Land’ West of the River Stour (planning application not
yet submitted)
10.177 A 5MW solar farm is proposed across approximately 13.68 hectares of land to the
west of the River Stour, (referred to as the ‘Banana Land’) compared to over 7
hectares occupied by the proposed converter station and substation site.
10.178 Residual cumulative effects on landscape and views during construction are not
anticipated as the proposed solar farm will likely be built before construction works
start in relation to the proposed converter station and substation.
10.179 On completion (with mitigation and after establishment) residual cumulative effects
on landscape will result in a slightly greater adverse effect than reported for the
265
proposed converter station and substation in isolation, but no greater than minor
adverse overall. The proposed solar farm will introduce rows of photovoltaic panels
to open grazing land in the Ash Levels landscape character area, on the opposite
side of the River Stour to the proposed converter station and substation site. The
proposed solar farm site is within the context of existing solar farms to the northwest
(west and east of the new A256 bypass) and would be seen in the context of
existing larger scale development (including the windfarm substation south of the
former power station site, overhead lines, a wind turbine and adjacent masts and
industrial units on the A256) so as to appear as part of the industrial corridor in this
locality.
10.180 Minor adverse residual cumulative effects on landscape are considered to be
temporary as the proposed solar farm site can be returned to grazing land following
cessation of the solar farm.
10.181 On completion, there will be intervisibility between the proposed converter station
and substation and the solar farm west of the River Stour. However visual
receptors will not be sensitive to cumulative visual effects as they will be workers at
their workplace in an area characterised by industry. Existing solar farms are also
visible in the sites’ surroundings when travelling along the new A256 bypass.
10.182 Residual cumulative effects are anticipated in views from receptors including:




Saxon Shore Way;
River Stour;
the A256 (Ramsgate Road); and
Railway line between Minister and Sandwich.
10.183 A slightly greater adverse magnitude of effect is anticipated on walkers along the
Saxon Shore Way and boat users along the River Stour as the solar farm will
restrict some views across previously open grazing land within the context of the
converter station and substation site. The significance of cumulative residual visual
effects on these receptors adjacent and in the vicinity of the solar farm and
converter station and substation site will be no greater than moderate adverse.
10.184 Other cumulative residual visual effects are anticipated to be no greater than effects
recorded in relation to the proposed converter station and substation, ranging from
moderate to minor adverse effects for a small number of visual receptors closest to
the site to neutral or no effects on other identified visual receptors.
Cumulative Effect of all Above Developments
10.185 The significance of residual cumulative effects on landscape character and on
views of the proposed converter station and substation in combination with all six
development proposals (excluding the solar farm) is considered as being no greater
than residual effects (with mitigation and after establishment) recorded in relation to
the proposed converter station and substation. Upon completion (with mitigation
and after establishment) residual cumulative effects of the solar farm on landscape
will result in a slightly greater adverse effect than reported for the proposed
converter station and substation in isolation, but no greater than minor adverse
overall. Development proposals will increase the extent of development in the area;
however the scale of Proposed Developments will be smaller than the proposed
converter station and substation buildings, and proposals are sited within an area
already affected by the derelict turbine hall at the former Richborough power station
266
site, a wind turbine and associated masts; electricity overhead lines, industrial units
on the A256 (Ramsgate Road), Pfizer development, Weatherlees Hill Wastewater
Works, an aerobic digester, and a solar farm to the east and west of the new A256
bypass.
10.186 Residual effects on landscape character (with mitigation) will be minor adverse to
neutral and residual visual effects (with mitigation) will range between moderate to
minor adverse and neutral. Walkers along the Saxon Shore Way and boat users on
the River Stour would experience the most significant visual effects of moderate to
minor adverse.
267
268
11.0
TRAFFIC AND TRANSPORT
Introduction
11.1
This chapter assesses the potential construction and operation traffic and transport
related impacts of the Proposed Development (i.e. the UK onshore elements of the
Nemo Link (see Chapter 2 Project Description).
11.2
The topics listed below are discussed in detail within this chapter:






Relevant transport and environmental policy;
Description of proposed access routes and arrangements;
Types, volumes and timings of vehicles accessing the site during construction
and operation;
The likely significance of environmental effects;
The likely environmental impacts of the vehicles accessing the site; and
Measures to be undertaken to mitigate against environmental impacts.
Legislation and Planning Policy Guidance
11.3
The following relevant national and local planning policy and legislation have been
considered during the preparation of this assessment:
National


Traffic Management Act 2004; and
National Planning Policy Framework 2012.
Local

11.4
In addition, this chapter has been produced in line with the Design Manual for
Roads and Bridges (DMRB), Volume 11 taking into account UK legislation with
regard to Environmental Impact Assessment (EIA) regulations, namely:



11.5
Kent Local Transport Plan 3 2011-2016.
Section 105 of the Highways Act 1980, as amended by the Highways
(Assessment of Environmental Effects) Regulations 1988;
The Highways (Assessment of Environmental Effects) Regulations 1994 and
1999; and
The Highways (Environmental Impact Assessment) Regulations 2007.
Other relevant guidance used in the production of this assessment includes:



Guidance on Transport Assessment” Department for Transport, 2007;
“Guidelines for the Environmental Assessment of Road Traffic” Institute of
Environmental Assessment (IEA) 1993. (Now known as the Institute of
Environmental Management and Assessment (IEMA)); and
Design Bulletin 32 (1992), Appendix 2: Passing places on narrowed
carriageways.
269
Method
11.6
The need for an Environmental Assessment of the transport related implications of
the Proposed Development is highlighted in several documents and guidance
notes. The Department for Transport’s (DFT’s) document, “Guidance on Transport
Assessments” (2007), states:
“The environmental impacts of any significant development need to be addressed.
This might include it being covered by a separate Environmental Statement (ES),
which involves an assessment of a development’s potential environmental
implications, including those that are transport related. This will help ensure the
impacts and the scope for mitigating them are properly addressed.”
11.7
The above guidance precedes a key document called “Guidelines for the
Environmental Assessment of Road Traffic” produced by the Institute of
Environmental Assessment, (1993). This follows a Government White Paper on The
Environment in September 1990. The White Paper was a reflection of the growing
concern amongst the general public, business and government that the
environment needed to be protected.
11.8
The basic principles for environmental assessment originated with Directive 337,
issued by the European Community in 1985. These were confirmed in the
regulations published by the Department of the Environment in 1988.
11.9
These regulations were amended into highways legislation through the Highways
(Assessment of Environmental Effects) Regulations 1999 which were amended in
2007.
Assessment of Significance
11.10
Quantifying the environmental impact of traffic from a Proposed Development
depends on several key factors. In this instance the main factors influencing the
significance of the impact relate to the magnitude of change, (taking into account
the time frame of change) and the number, and sensitivity of any receptors in the
area of interest. Once the significance of the impact is understood then the correct
level of assessment can be undertaken, and mitigation can be considered where
necessary.
11.11
This is described within the Design Manual for Roads and Bridges (DMRB) Volume
11, Section 2, Part 5 (2008), which states:
“The significance of the effect is formulated as a function of the receptor or resource
environmental value (or sensitivity) and the magnitude of project impact (change). “
“The approach to assigning significance of effect relies on reasoned argument,
professional judgement and taking on board the advice and views of appropriate
organisations.”
11.12
The DMRB Volume 11, Section 2, Part 5 (2008) sets out a table for helping to
define the significance of change. This has been included below.
270
Table 11.1: Determining the Significance of Effects
Environmental Value (Sensitivity)
Magnitude of Impact (Degree of Change)
No
Change
Negligible
Minor
Moderate
Major
Very High
Neutral
Slight
Moderate
or Large
Large or
Very Large
Very
Large
High
Neutral
Slight
Slight or
Moderate
Moderate or
Large
Large or
Very
Large
Medium
Neutral
Neutral or
Slight
Slight
Moderate
Moderate
or Large
Low
Neutral
Neutral or
Slight
Neutral or
Slight
Slight
Slight or
Moderate
Negligible
Neutral
Neutral
Neutral or
Slight
Neutral or
Slight
Slight
Percentage Increases in Traffic
11.13
The IEA document “Guidelines for the Environmental Assessment of Road Traffic”
states that the following criteria should be adopted to determine the need for
environmental assessment of traffic impacts associated with a development:

“Include highway links where traffic flows will increase by more than 30% (or
the number of heavy goods vehicles will increase by more than 30%); and

Include any other specifically sensitive areas where traffic flows have increased
by 10%, or more.”
11.14
Increases in traffic flows of less than 10% have a negligible impact as daily variance
in traffic flows can be of equal magnitude. This is again stated within the IEA
document.
11.15
The 30% threshold relates to the level at which humans may perceive change and
there may therefore be an effect. Impacts above this level therefore do not suggest
that there is a significant impact, only that further consideration is required.
11.16
In this instance the site is located off key primary routes with direct links to the wider
highway and motorway network. Therefore the scope of this assessment includes
these key links that will be used to transport plant and material to the site.
11.17
The construction and operation impacts of the development are discussed
separately.
271
Existing Environment
11.18
To understand and quantify the future impacts of the Proposed Development, an
assessment of existing local highway characteristics and trends has been
undertaken.
11.19
The nature of the highways likely to be affected, the proximity of any residential
dwellings or receptors to the proposed construction traffic route, the local highway
accident record and the existing traffic levels on key links have been considered.
East Kent Access Road
11.20
Over the past number of years a number of significant highway projects have been
carried out in the vicinity of the site including the A256 and the Richborough
Roundabout. These works formed the East Kent Access Phase 1 & 2 which is
briefly discussed below.
11.21
The East Kent Access Road Phase 1 involved the improvement of the A256 from
the Richborough Roundabout south to the Sandwich bypass and also included a
link road around the south side of the BayPoint sports complex.
11.22
To the south of the upgraded Phase 1 section, the A256 Ramsgate Road continues
as a single carriageway towards Sandwich, while to the south of Sandwich, the
A256 forms a junction with the A2 at Dover.
11.23
As part of the improvement scheme works started in the 1980s, the A256 was
developed into a dual-carriageway and improved pedestrian, cycle and lighting
facilities were introduced.
11.24
As part of Phase 2, improvements have been undertaken along the A256 from the
Richborough Roundabout to a new roundabout located 400m to the north at
Ebbsfleet Lane.
11.25
Ebbsfleet Lane now forms two separately accessible sections, at A256 Sandwich
Road, and Grinsell Hill/Cottington Road. The road then continues north-east to
bridge Cottington Road and an adjacent railway line, before forming a new four-arm
roundabout approximately 400m north of Cottington Road (known as Sevenscore
Roundabout).
11.26
At Sevenscore Roundabout, the western arm is a single-carriageway link road
which provides access to residential properties via Cottington Road. The northern
arm of Sevenscore Roundabout continues northwards to connect to the A299
Canterbury Road West via a further three-arm roundabout (known as Cliffsend
Roundabout).
11.27
From here a new 8km, dual-carriageway link has been provided from the new
roundabout north to the A299. A key feature of this link is an underpass beneath
Foads Hill and a local railway line.
11.28
The purpose of the scheme is to improve accessibility and safety as well as support
the economy of east Kent connecting the ports of Dover and Ramsgate with Kent
International Airport. The East Kent Link Phase 2 opened in early 2012.
11.29
A plan showing the highways works in the vicinity of the site has been included as
Figure 11.1.
272
A256 Sandwich Road
11.30
The A256 Sandwich Road was previously the primary north-south route through
Cliffsend prior to the completion of Phase 2 of the East Kent Link. Sandwich Road
is a single carriageway, with one lane in each direction. The road extends from the
Lord of the Manor Roundabout to the north, passing through the Cliffsend
residential area and forming one arm of the new Ebbsfleet Roundabout to the
south.
11.31
The Lord of the Manor Roundabout has recently been remodelled as part of the
Stage 2 works, and now forms a large signalised junction linking the A299
Canterbury Road West, the A256 Haine Road, the A299 Canterbury Road East,
and the A256 Sandwich Road.
11.32
Sandwich Road between Cliffsend Road and Foads Lane is predominately a
residential area forming part of Cliffsend. To the south of the junction with Foads
Lane, there is a service station located on the south-eastern side of Sandwich
Road. A traffic calming measure which reduces the carriageway to one lane, giving
priority to traffic travelling northbound, has recently been installed immediately
south of this service station, as well as an additional installation to the north of
Cliffsend, between Cliffs End Road and Chalk Hill. This is to encourage non-access
traffic to use the new A256 to the west of Cliffs End, for routeing between Ramsgate
and Sandwich.
11.33
To the south of Cliffsend, Sandwich Road is more rural in character. The 1.2km
section between Cliffsend and the Ebbsfleet Roundabout provides access to
Pegwell Bay Country Park and a priority junction at Ebbsfleet Lane. Otherwise, this
section of the road is fronted by Stonelees Golf Centre on the north-western side,
and by Pegwell Bay Country Park on the southern side.
A299
11.34
The A299 Canterbury Road West connects to the new A256 link road to the north of
the proposed Interconnector site, and the M2 to the west, and is a primary
distributor link in the area. The route begins at Junction 7 of the M2 motorway, and
follows an alignment past Chestfield, Herne Bay, Hawthorne, St-Nicolas-at-Wade
and Manston Airport, and forms a roundabout junction with Royal Harbour
Approach to the west of Ramsgate, across a distance of approximately 35 miles.
11.35
The A299 is comprised of Canterbury Road West, and Canterbury Road East.
Canterbury Road West is a single carriageway road, which connects the Minster
Roundabout to the Lord of the Manor roundabout. The road is predominantly rural,
being mostly bound by open land.
11.36
At the double-roundabout junction with Haine Road and Sandwich Road the A299
continues eastwards along Canterbury Road East for approximately 750m and
connects to a four-arm roundabout with Windermere Avenue and Royal Harbour
Approach (known as the Royal Harbour Roundabout).
Existing Traffic Flows
11.37
Both the A256 and the A299 are designated as primary routes connecting to the
national road network and as such carry large volumes of traffic.
273
11.38
Annual Average Daily Traffic (AADT) flows have been obtained for the key links to
be used for access to and from the development during construction. These include
the following:




A299 West Canterbury Road;
A256 Richborough Road adjacent to the Interconnector site;
A256 Dover Road to the south of the site; and
Sandwich Road close to the Pegwell Country Park.
Table 11.2: Existing Traffic Flows
Location
AADT
% HGVs
A299 West Canterbury Road
A256 Richborough Road
A256 Dover Road
Sandwich Road
23,994
20,053
10,756
6,779
6%
4%
4%
4%
Personal Injury Accidents
11.39
An analysis of personal injury accident data has been undertaken in the vicinity of
the development to inform the baseline assessment of the local highway links.
11.40
Data was obtained for the following links:

The A256 from the location of the new Ebbsfleet Roundabout, south to the
A256 junction with Ash Road and the A257;

A section of Sandwich Road through Cliffsend; and

The A299 from the junction with A253/Minster Road/Tothill Street, to the
location of the new junction with the A256.
11.41
As the East Kent Phase 2 link was not opened until May 2012 no accident data was
available for the link.
11.42
Overall, the data contains 95 accidents within the study area in the 5 year period.
These were comprised of 1 fatal accident, 10 serious accidents 84 slight accidents.
11.43
During the assessment work undertaken as part of the East Kent Phase 2 project it
was identified that there was an unsatisfactory road safety record along the A256
and A299 through Cliffsend. This should be significantly improved due to the
creation and opening of the new link road as through traffic will avoid built up areas
and stick to primary routes designed for large volumes of traffic.
11.44
Overall, there were no correlations in the data to suggest that highway condition,
layout or design were significant contributory factors in the pattern of accidents. The
data instead suggests that pedestrian or driver behaviour were the primary
contributory factors in the accidents recorded.
274
Public Transport Facilities
11.45
The converter station and substation site is close to a number of existing bus routes
on the A526 Ramsgate Road. The nearest bus stops to the site are located on the
section between the Richborough Roundabout and the roundabout at Ebbsfleet
Lane constructed as part of East Kent Phase 2. The stops are situated adjacent to
the petrol filling stations on both sides of the carriageway, and are therefore also in
proximity to the site entrance.
11.46
Services 87, 88 and 88A all operate between Dover – Sandwich – Ramsgate, on
Mondays to Saturdays only. Service 87 operates 5 times per day; service 88
operates between 5 and 10 times per day (school term time dependent); and
service 88A operates up to 4 times per day (school term time only). Together, the
three services provide an approximately hourly service between Dover and
Ramsgate throughout the day.
11.47
Service 954 operates between Birchington-on-Sea and Sandwich, on school days
only, passing the site at approximately 08:10 in the direction of Sandwich.
11.48
Accessing the site outside of network peak times will minimise disruption to the
above services, as services are most frequent during morning and evening hours,
when there are sometimes additional term-time services.
Public Footpaths and Cycle Paths
Cycle Routes
11.49
Regional Cycle Route 15 “The Viking Coastal Trail” is located in the vicinity of the
site. The route has an extensive traffic-free section to the east of the site, following
a coastal route parallel to Sandwich Road and Cliff’s End to the north-east of the
site, and parallel to the A256 to the east of the site. The Viking Coastal Trail passes
through Pegwell Bay Country Park which is located to the east of the site.
11.50
The section of the Viking Coastal Trail passing Cliffsend, parallel to Sandwich
Road, exists as a shared footway/cycleway, which is surfaced in gravel and is
approximately 3m to 3.5m wide. The section of the Trail passing through Pegwell
Bay Country Park is also surfaced and is again approximately 3m to 3.5m wide
within the Country Parkit crosses over the car park access with give way markings
in place for cyclists.
11.51
To the south of Pegwell Bay Country Park, the Viking Coastal Trail bends and
follows an alignment parallel to the A256 Ramsgate Road. This section of the Trail
exists on a shared footway and cycleway, which is surfaced in asphalt, rather than
the gravel surfacing used on the northern section.
11.52
There is also a cycle route between Cliffsend and St Nicolas-at-Wade, Minster and
Sevenscore, which is also named as part of the Viking Coastal Trail. There is a
short section of shared footway/cycleway on Foad’s Lane, at the junction with the
A256 Sandwich Road, providing a connection to the coastal cycle track. The
remainder of the route between Cliffsend and St Nicolas-at-Wade is on-street where
cycles share space with general highway traffic.
275
Footpaths
11.53
There are a number of existing Public Rights of Way (PROWs) in the vicinity of the
site.
11.54
Footpath TE39, a PROW, is located to the north of the site, and connects Ebbsfleet
Farm to the south with a further footpath, TE37, to the north. Footpath TE37 is itself
another PROW and exists parallel to a railway line which crosses Ebbsfleet Lane.
11.55
Footpath EE26 is located to the south-west of the site, parallel to the Great Sour
River, on the northern side. The PROW exists between the water treatment works
off of Marsh Farm Road to the west, and a (wind turbine) which is located to the
west of the site.
11.56
Footpath EE42 is located close to the south-west of the site, however, the footpath
is located parallel to the southern side of the Great Sour River, and is not
accessible from the immediate vicinity of the site.
11.57
There are a number of footpaths through Pegwell Bay Country Park, which are not
registered PROWs, but which nonetheless provide potential routes between the
A256 and the coast, and which can be accessed from the park. The footpaths within
the park also connect to Saxon Shore Way, which passes through the park using
the same shared footway/cycleway as the Viking Coastal Trail cycle route. The
Saxon Shore Way extends across a total distance of 160 miles, from Gravesend in
North Kent, to Hastings in East Sussex.
Potential Local Receptors
11.58
As the Proposed Development is located on the site of the former Richborough
Power Station there are few receptors in close proximity.
11.59
The A526 which will provide access to the site is a key traffic link in the area and as
such it is currently used by large volumes of traffic.
Local Residential Dwellings
11.60
There are approximately seven residential dwellings, located close to the Ebbsfleet
Roundabout with access of Ebbsfleet Lane and Sandwich Road. These are located
around 100m from the new A256 and approximately 500m from the Proposed
Development site. These properties are set back from the highway with large
amounts of mature screening along the property boundaries.
The Stonelees Golf Centre
11.61
The Stonelees Golf Centre is north of Ebbsfleet Lane approximately 700m from the
site. Access to this facility is not from a primary highway link; access is from
Ebbsfleet Lane off Sandwich Road. The old A256 Sandwich Road forms the
facility’s eastern boundary as the golf centre extends away from the site towards
Cliffsend.
Pegwell Bay Country Park
11.62
Pegwell Bay Country Park covers an area of approximately 29 hectares, and is
open from 9am or dusk, to 9pm. The park is located within Sandwich and Pegwell
Bay National Nature Reserve, which covers an area totalling 628 hectares adjacent
276
to the coast. The Country Park is within the western part of the National Nature
Reserve (NNR), with the A256 Sandwich Road forming part of the western
boundary for the NNR.
11.63
Natural England’s website gives the following description of the NNR:
“Natural habitats include; eroding chalk cliffs and wave cut platforms to the north of
Pegwell Bay, intertidal mudflats, developing beaches, sand dunes and saltmarsh.
Semi-natural habitats include; ancient dune pasture and coastal scrubland while the
re-created grassland of the Pegwell Bay Country Park, along with ponds, dykes and
ditches are artificial habitats.
The intertidal mudflats support nationally and internationally important numbers of
waders and wildfowl, both on migration and over-winter. The sand dunes and
ancient dune pasture contain large numbers of southern marsh orchid, marsh
helleborine, pyramidal orchid and the occasional lizard orchid.”
11.64
The primary part of the NNR which could be affected would be the area comprising
Pegwell Bay Country Park, specifically around the existing traffic-free cycle route
(Viking Coastal Trail), under which the interconnector cable would be laid. This is a
small area of the overall NNR, and is close to the area’s boundary, being adjacent
to an existing highway, the A256.
Prediction and Assessment of Significance of Potential Impacts
Construction Methodology
Converter Station and Substation Construction
11.65
The converter station and substation will be on part of the site of the former
Richborough Power Station. Access to the site will be from an existing vehicular
access off the A256 at the Richborough Roundabout.
11.66
The Richborough Energy Park external estate road is subject to a recently
submitted and pending planning application submitted by Richborough A Limited.
Once constructed, this will enable access to the proposed converter station and
substation site via the A256 Richborough Roundabout.
11.67
Before construction of the proposed converter station and substation can
commence, re-profiling of the site is required which will involve the cutting and filling
of material to ensure the site is suitable for construction to commence.
11.68
The re-profiling of the site could take up to 12 months to complete and will generate
a number of heavy goods vehicle (HGV) movements associated with the removal of
material from the site.
11.69
Both the converter station and the substation will require the delivery of large
transformers, four for the converter station and two for the substation. It is proposed
that these will be delivered to the site by road and are anticipated to arrive by sea at
Dover.
11.70
These loads will constitute abnormal loads and the feasibility of delivery has been
considered in detail in a separate study included as Appendix 11.1.
277
11.71
It is anticipated that the largest transformers will weigh up to 260 tonnes while
others will weigh in the region of 183 tonnes.
11.72
All abnormal loads will be transported by specialist vehicles and haulage
contractors. Investigations to date have indicated a number of routeing options to
transport the transformers to the site. All construction traffic routeing has been
discussed in detail within this chapter.
11.73
New internal access roads will be constructed to access the proposed development
site and will allow the delivery of the transformers. Turning facilities for large
vehicles and parking areas will also be provided.
11.74
It is anticipated that the Proposed Development will take approximately 36-42
months to complete and the site will be operational by October 2018.
Onshore Cables Installation
11.75
The proposed route of the onshore cables is shown in Figures 2.1 and 2.5. The
cables will be installed by open trenching; the surface will be cleared of trees, scrub
and other vegetation prior to installation.
11.76
The trenches will be excavated by hydraulic excavators, except where it is
proposed close to existing underground services where excavation will be done by
hand. All excavated material will be stored on site for reinstatement following the
introduction of the cables. The excavated material will be used to ensure that the
profile of the trench is restored to the previous condition. Any unused excavated
material will be removed from the site.
11.77
To the south of the Country Park there is an area of known contaminated land.
Through this section the cables will be laid on top of the existing ground. A chalk
capping layer will then be built up on top of the cables. This will enhance the
vegetation and biodiversity of the interest of the Country Park and prevent the need
to disturb contaminated ground and risk opening up potential contamination
pathways during cable installation.
11.78
The cables will continue through the Country Park to the BayPoint sports complex
where Horizontal Directional Drilling (HDD) will be used to install the cables beneath
Minster Stream to the former Richborough Power Station site. This will also avoid
any disturbance to the new East Kent Link Road which has been described in detail
within this chapter.
11.79
During the laying of the cables a 10m – 15m working area will be required to
construct the trench and lay the cables. A temporary compound area will be
housed within the Country Park and will be used to deliver plant and materials
required for laying the cables as well as storing equipment. This area utilises an
existing vehicular access into the park and an area of vacant land adjacent to the
access. This area is shown in Figures 11.3 and 2.5.
11.80
As part of the construction compound an area will be provided for vehicles to be
able to turn within the site ensuring vehicles will be able to enter and exit the site in
forward gear. A parking area for a small number of vehicles will be provided.
11.81
The laying of the onshore cables and associated works is anticipated to take
approximately one to two months to complete. With regard to the phasing of the
Proposed Development, the site preparation works will occur first, followed by the
278
construction of the site access roads. After these have been constructed the
construction of the converter station and substation will begin.
11.82
The greatest number of vehicle movements is anticipated to occur at the start of the
construction works. The anticipated volume of vehicles required during construction
is detailed below.
Development Trip Generation
Construction Trips
11.83
These have been calculated for each of the four distinct phases of work as follows:




Site Preparation Works;
Site Access Road Construction;
Converter Station and Substation Construction; and
Cable Installation.
11.84
The total number of anticipated loads required for each phase of construction is
provided. These have been divided by the number of months construction is due to
occur and then divided by 20 to give an indication of the likely volume of loads, and
therefore trips required to access the site per day.
11.85
To ensure a robust assessment, 70% of the total loads anticipated to occur during
the construction of the converter station and the substation have been calculated to
occur within a six month construction period. However, the anticipated overall
construction period for the converter station and substation is approximately 24
months.
11.86
Table 11.3 below shows the anticipated peak number of HGV two-way trips
associated with each phase of construction per month and per day.
11.87
It is likely a number of the anticipated plant, equipment and material deliveries will
be by light goods vehicle (LGV), however, for this assessment all have been
assumed to be by HGV.
Table 11.3: Anticipated Two-Way HGV Trips
Development Phase
Total TwoWay HGV
Trips
Peak Two-Way
HGV Trips per
Month
Peak Two-way
HGV Trips per
Day
Site Preparations
5,417
903
45
Internal Access Road
Construction
8,765
1,461
73
Converter Station and
Substation Construction
8,425
982
49
HVDC Cable Installation
65
65
6
279
11.88
The above table indicates that during the peak phases of construction, a total of 73
two-way HGV trips will be generated per day.
11.89
In addition to the HGV deliveries anticipated during construction, it is envisaged that
30 two-way car trips and two bus/coach trips will be generated per day throughout
construction associated with staff accessing/egressing the site.
11.90
It is difficult to ascertain the exact number of construction trips as this is dependent
on the appointment of a contractor and any changes to the programme. Figures
provided are considered to represent a reasonable worst case scenario.
Operational Trips
11.91
Once constructed it is anticipated that the converter station will generate a small
number of vehicular trips. These types of facilities are typically unmanned, however,
if manned it is anticipated that six members of staff will be based at the site with two
people working shifts over a 24 hour period. This would result in approximately 12
two-way trips per day.
11.92
It is anticipated that there could be in the region of 28 two-way maintenance trips
per year. In some situations up to 20 members of staff may be present on site
during maintenance and there may be a number of deliveries made by HGV. This
may occur once or twice a year.
11.93
The substation will be unmanned. However, it will on average generate
approximately four staff trips a week made by car or Light Goods Vehicle (LGV).
Again a small number of trips may be generated during maintenance; however, this
is anticipated to occur infrequently.
Vehicle Routeing
General Construction Traffic
11.94
It is anticipated that all vehicles will access the site via the primary highway routes
in the region. These include the A256, the A299 the A2 and the M2.
11.95
Routeing agreements will be formally agreed with the construction contractor once
appointed. A plan showing the proposed access routes for construction vehicles is
included as Figure 11.2.
11.96
During the installation of the cables a small number of vehicles will be required to
access Pegwell Bay Country Park. To do this they will have to leave the primary
highway network and utilise the former A256 towards Cliffsend. It is anticipated that
all access to this site will be via the Ebbsfleet Roundabout to avoid the residential
areas of Cliffsend.
11.97
It is anticipated that only three HGVs will be required per day to access the park as
well as a small number of cars/LGVs associated with staff undertaking the laying of
the cables.
Abnormal Vehicle Routeing
11.98
A separate assessment has been undertaken by to identify suitable routes to
transport the required abnormal loads to the site. This has been included as
Appendix 11.1. Investigations are currently on-going, however, the following route
280
has provisionally been suggested for the transportation of the transformers to the
site:





Leave Dover Docks complex;
Join the A20 eastbound;
From the A20 access the A2;
Turn right onto the A256 and continue north to the site; and
Exit the A256 at the Richborough Roundabout.
11.99
The movement of abnormal vehicles is controlled by The Motor Vehicles
(Authorisation of Special Types) General Order 2003 and subject to management
and prior agreement with the Police, Highways Agency and Kent County Council.
11.100
It is envisaged that all abnormal vehicles would be escorted by a pilot car and
Police escort and be scheduled to travel during off-peak hours where possible. This
would ensure the safety of other road users and result in minimal disruption.
Construction Vehicle Impacts
11.101 To understand and quantify the future impacts of the Proposed Development a
number of potential transport effects have been considered.
Percentage Increase in Traffic
11.102
Total daily (all traffic), peak, two-way vehicle movements is likely to equate to 73
HGVs, 30 cars/LGVs and two bus movements during the construction programme.
11.103
It is only expected that 3 HGVs per day will be required to access the Country Park
form the Old A256 Sandwich Road plus a small number of staff in either cars or
LGVs.
11.104
Based on the existing traffic flows collected in the vicinity of the site, this would
result in the following percentage increase on key highway links during peak
construction activity.




A256 Ramsgate Road - 0.5% increase in total traffic and a 9% increase in HGV
traffic;
A299 Canterbury Road West – 0.4% increase in total traffic and a 5% increase
in HGVs;
A256 Dover Road – 0.9% increase in total traffic and a 17% increase in HGVs;
and
Old A256 Sandwich Road – 0.3% increase in total traffic and a 1.1% increase
in HGVs.
11.105 In each instance the percentage increase with regard to total traffic on each of the
routes assessed is under 1%.
11.106 The highest percentage increase in daily traffic is calculated to be 17% along A256
Dover Road. In all other instances the percentage increase in HGV traffic would be
under 10%.
11.107 To ensure a robust assessment, the above percentage impacts have been
calculated assuming that all vehicles will use the same highway link to access the
281
site. In all likelihood, a number of key local links will be used throughout the
construction period.
11.108 It is also commonly accepted that daily traffic flows can vary as much as 10%. As
such, given the temporary nature of the increases plus the existing high daily traffic
flows, the anticipated temporary increase in traffic is likely to be negligible.
Noise
11.109 The anticipated noise that will be generated by the traffic accessing the site is
expected to be negligible given the low percentage increase in vehicle volumes on
the proposed access routes to the site and the volume of existing vehicles utilising
the highway links. In addition, the scheduling of construction vehicles will ensure
that noise associated with site traffic will not occur before 07.00 or after 19.00.
Severance
11.110
Severance is the perceived division that can occur within a community when it
becomes separated by a major traffic artery. In this instance, due to the low
increase in daily traffic volumes and the low number of potentially sensitive
receptors separated by the main transport links proposed to be used for
construction traffic, the potential severance impacts associated with the
development are considered to be negligible.
Driver Delay
11.111 During the peak delivery period periods it is recognised that some small driver delay
may occur as an increased number of vehicles turn into and out of the site onto the
A256 Ramsgate Road. In addition, there may be some minor driver delay during the
delivery of the large transformers required on-site.
11.112 Due to the temporary nature of the increase in vehicle movements and the low
percentage increase in traffic the potential impacts on local road users is
considered to be minor.
Pedestrian and Cyclist Delay
11.113 Due to the low percentage increase in vehicles along the primary routes to be used
to access the site, and the temporary nature of the development, it is anticipated
that there will a negligible impact on pedestrians and cyclists crossing these links.
11.114 Furthermore there are signalised Toucan crossing facilities located across
Sandwich Road close to where the cycle route leaves the Country Park and also
across Ramsgate Road to the south of the Ebbsfleet Roundabout.
11.115 It is acknowledged that there will likely be some pedestrian and cyclist delay during
the laying of the cables through the Country Park.
11.116 To access the working area from the temporary construction compound within the
Country Park some vehicles may be required to cross over the cycle way in some
instances to turn and exit the park, or to gain access to the cable laying working
area. Where this occurs, it is envisaged that banks men with appropriate signage
will stop any pedestrian or cycle traffic to allow a vehicle to manoeuvre and exit.
282
11.117 In addition, a small number of footpaths (approximately five) will have to be
temporally closed for approximately one month while a section of the cable is laid.
This may lead to pedestrians having to find alternative routes to travel through the
park adding time to their journey.
11.118 The detailed route of the cables including where any footpaths will have to be
temporarily closed is shown on Figure 11.3.
11.119 Given that it is anticipated that the laying of the cables through the Country Park will
take approximately one month to complete, it is envisaged that any potential
impacts with regard to pedestrian and cyclist delay will be minor.
Fear and Intimidation
11.120
The scale, fear and intimidation experienced by receptors along the route is
subjective and influenced by the volume and type of vehicle but also the level of
protection available, such as having a property set back from the highway, or wide
footways.
11.121 There are no identified sensitive receptors aligning the A256 and the new East Kent
Phase 2 access road in the proximity of the site.
11.122 There are, however, a number of identified receptors along Sandwich Road leading
to the Country Park. These include a small number of residential dwellings as well
as the Stonelees Golf Centre and the Country Park itself.
11.123 In respect to the residential developments, these are set back from the highway
with large amounts of mature screening in place between the properties and the
highway.
11.124 There is also some significant screening between the Country Park and Sandwich
Road, however, some traffic will be required to enter the Country Park during
construction. This could result in impacts associated with fear and intimidation by
pedestrians and cyclists within the park.
11.125 There are patches of screening between Sandwich Road and the golf course;
however, for some small sections there is none.
11.126 Given the low volume of construction vehicles utilising this route and the short time
frame over which access to the Country Park is required, minor impacts are
anticipated during construction.
Accidents and Safety
11.127 An analysis of personal injury accident data has been undertaken in the vicinity of
the Proposed Development.
11.128 No correlations in the data suggest that highway condition, layout or design were
significant contributory factors in the pattern of accidents. It is therefore considered
that there is unlikely to be any increased risk of accidents along the proposed
routes that vehicles will take to access the works.
283
Air Pollution
11.129 Due to the daily increase in total vehicles being relatively low compared to existing
traffic flows and the short time frame of development, the level of pollution
surrounding the development is not anticipated to materially change as a result of
the development proposals.
11.130 A detailed assessment of the potential impacts of road traffic on air quality has been
undertaken. This is included as Appendix 11.2.
11.131 The air quality assessment identified that the anticipated road traffic associated with
the development will have a negligible impact on existing sensitive receptor
locations. Therefore, it is not considered necessary to recommend measures to
mitigate road traffic emissions.
Dust and Dirt
11.132 It is possible that some dust and dirt may collect on the wheels and chassis of the
vehicles making deliveries to the site. Without appropriate management, this could
lead to some minor environmental impacts on the surrounding local highway
network.
Construction Vehicle Impact Conclusions
11.133 Given the number of vehicles that will use the identified delivery routes to access
the works and the temporary nature of the traffic increase, it is considered that
although there is the potential for some temporary minor adverse impacts, the
majority of impacts associated with the development will be negligible.
Operational Vehicle Impacts
11.134 Once operational the development is anticipated to generate minimal vehicle trips.
As such, once constructed the impacts anticipated from the generated traffic are
likely to be imperceptible and therefore negligible.
Mitigation
11.135 A number of traffic management measures are proposed to minimise any potential
effects of construction traffic accessing/egressing the site and the Country Park.
11.136 Construction traffic is of a temporary nature and as a result it would be
inappropriate to provide permanent infrastructure as mitigation.
11.137 During construction, wheel washing facilities will be provided both at the main site
entrance and also the vehicular entrance to the construction compound located at
the Country Park. This will ensure mud/debris is not deposited on the surrounding
carriageway. In addition, all HGVs will be covered and sheeted as appropriate.
11.138 Mitigation measures will also include the introduction of delivery management
strategies to ensure that HGVs travel outside of peak periods where possible, avoid
sensitive residential areas and stick to agreed routeing plans.
11.139 In addition, appropriate road signage will be provided as required; suitable signage
will be placed within the Country Park to inform local users.
284
11.140 A number of additional mitigation measures will be introduced for abnormal load
movements. These include:



Police escorts and delivery programmes timed to cause minimal disruption;
Vehicles will be marked as abnormal or long vehicles and where necessary
temporary warning signs will be placed at required locations along the roads
being used by site traffic; and
It is also proposed to undertake a full condition survey before and after the
delivery of any abnormal load. The condition of the carriageway will be
reinstated to the same or better condition following the use of the route.
11.141 Details of the proposed mitigation strategy would be developed in detail during the
preparation of a Transport Management Plan.
Residual Impacts
11.142
It is anticipated that a number of potential minor environmental impacts would,
following the introduction of the mitigation measures detailed above, result in
negligible environmental impacts.
11.143
There are, however, likely to be a number of minor residual environmental impacts
that cannot be fully mitigated. These primarily include those relating to pedestrian
and cyclist delay. However, these impacts are only likely to be temporary during
the construction works and are not associated with the operation of the proposed
converter station and substation.
11.144
All anticipated environmental impacts are summarised in Table 11.4 and Table 11.5
below.
.
Table 11.4: Residual Construction Traffic Impacts
Potential Impact
Noise
Significance
of Impact
Negligible
Mitigation Measure
Severance
Negligible
Driver Delay
Minor
Signage and Delivery
Agreements - Timing
and Routeing
Negligible
Pedestrian and
Cyclist Delay
Minor
Signage and Delivery
Agreements - Timing
and Routeing
Minor
Fear and
Intimidation
Accidents and
Safety
Minor
Suitable signage
Minor
Negligible
Negligible
Air Pollution
Negligible
Signage and Delivery
Agreements - Timing
and Routeing
-
Dust and Dirt
Minor
Wheel Washing and
Vehicle Sheeting.
Negligible
Delivery Agreements
- Timing and Routeing
-
285
Residual Impact
After Mitigation
Negligible
Negligible
Negligible
Table 11.5: Residual Operational Traffic Impacts
Potential Impact
Significance of
Impact
Mitigation
Measure
Residual Impact
After Mitigation
Noise
Negligible
None Necessary
Negligible
Severance
Negligible
None Necessary
Negligible
Driver Delay
Negligible
None Necessary
Negligible
Pedestrian and
Cyclist Delay
Negligible
None Necessary
Negligible
Negligible
None Necessary
Negligible
Negligible
None Necessary
Negligible
Air Pollution
Negligible
None Necessary
Negligible
Dust and Dirt
Negligible
None Necessary
Negligible
Fear and
Intimidation
Accidents and
Safety
Cumulative Impacts
11.145 Potential cumulative effects on traffic and transport from the onshore elements of
the Nemo Link in combination with other components of the Project (i.e. UK, French
and Belgian subsea cables and Belgian onshore infrastructure) are described in
Chapter 16.
11.146 Potential cumulative effects of the Proposed Development in combination with the
connection required to facilitate the operation of the Nemo Link are described in
Chapter 17.
11.147 A number of unrelated developments are proposed in proximity of the works subject
to this planning application (see Table 1.2 in Chapter 1). These developments have
been briefly discussed below including any potential cumulative traffic impacts.
Richborough Energy Park Estate Road
11.148
A planning application has recently been submitted for a 2.60ha estate road
network and structural/estate landscaping around the perimeter of the former
Richborough Power Station site. The construction of the access roads and the
Proposed Development will not occur simultaneously.
11.149
The scheme would be expected to improve access to the site during operation, and
can therefore be viewed as a benefit to the Nemo Link scheme.
Peaking Plant Facility
11.150 A planning application has recently been submitted for a facility which will be
designed to provide top-up supply to the local electricity distribution network at short
notice; for example, during periods of high electricity demand or low energy
generation. This will comprise of 53 diesel fired generators, along with associated
286
fuel storage, parking and access, and will occupy an area of approximately 3.37
hectares.
11.151 It is possible that there may be some overlap in the construction of the peaking
plant facility and the site preparation works for the proposed substation and
converter station. The peaking plant facility is due to be operational in late 2014;
some of the site substation and converter station site preparation works may have
commenced at this time. As the construction of the peaking plant will be drawing to
a close, cumulative effects are anticipated to be minor.
11.152 The level of operational traffic at the peaking plant facility would be expected to be
low and infrequent due to the development’s nature as a “back up” facility.
Therefore, the cumulative operational impacts of both the peaking plant facility and
the onshore elements of the Nemo Link scheme are expected to be negligible.
Pegwell Bay Flood Defence Scheme
11.153 An application was submitted in September 2012 for the installation of a new
concrete wall to the north of Pegwell Bay Service Station and installation of an earth
embankment, to the south of the service station. Construction would be expected
during 2013.
11.154 Works on the onshore elements of the Nemo Link are scheduled to commence in
2015. Therefore, if the flood defence scheme is completed during 2013 as
expected, there would be no cumulative highways impact.
Waste Development
11.155 An application was approved by Kent County Council in July 2011 for a waste
related development on land west of Ramsgate Road, Richborough. This will
include the construction of a materials recycling facility, soil washing plant,
anaerobic digestion plant and inert materials processing facility plus construction of
a building to house the anaerobic digester.
11.156 The construction of the onshore elements of the Nemo Link and the waste facility
are not anticipated to overlap; therefore no cumulative impacts are anticipated.
11.157 Once operational, there will be some vehicular movements associated with the
waste development. However, combined with the very low operational vehicle
generation associated with the onshore elements of the Nemo Link, cumulative
effects are anticipated to be negligible.
Solar Farm
11.158 A future application is expected for a 5MW Solar Farm on land to the west of the
River Stour adjacent to the site, with an area of 13.36 ha. The proposals will include
rows of photovoltaic panels, ancillary equipment, security fencing and associated
landscaping.
11.159 The construction of the onshore elements of the Nemo Link and the solar farm are
not anticipated to overlap; therefore no cumulative impacts are anticipated.
11.160 Once operational, it is anticipated that vehicle movements associated with the solar
farm will be very low; cumulative effects are anticipated to be negligible.
287
Glasshouses, Three Water Storage Tanks and Pack House
11.161 An application was submitted in October 2012 for the erection of glasshouses, three
water storage tanks and a pack house at Ebbsfleet Lane, Ebbsfleet, Ramsgate.
11.162 While there would be trips associated with the construction, they are anticipated to
be low; therefore the potential cumulative impact would be expected to be
negligible.
Overall Cumulative Impacts
11.163 In the one instance where the construction of a neighbouring development (the
Peaking Plant Facility) may overlap with the construction of the Nemo development
the cumulative impacts are expected to be minor.
11.164 Careful consideration of all construction programmes will be required to keep all
impacts associated with the construction of the two developments to a minimum.
11.165 With regard to operational traffic, all of the sites described above have a relatively
low operational traffic generation. Therefore, the combined traffic generation of all
proposed works is anticipated to negligible and as such no significant cumulative
effects are anticipated.
References

Department for Transport, 2007. Guidance on Transport Assessment. London:
Department for Transport.

Department for Transport, 2008. Design Manual for Roads and Bridges.
London: Department for Transport

Highways Act 1980. s.105. London: HMSO.

Highways (Assessment of Environmental Effects) Regulations 1988. London:
HMSO.

Highways (Assessment of Environmental Effects) Regulations 1994. London:
HMSO.

Highways (Assessment of Environmental Effects) Regulations 1999. London:
HMSO.

Highways (Environmental Impact Assessment) Regulations 2007. London:
HMSO.

Institute of Environmental Assessment, 1993. Guidelines for the Environmental
Assessment of Road Traffic. London: Institute of Environmental Assessment.
288
289
290
12.0
NOISE AND VIBRATION
Introduction
12.1
This chapter considers the potential noise and vibration effects of the Proposed
Development i.e. the UK onshore elements of the Nemo Link (see Chapter 2 –
Project Description) on noise sensitive receptors. The assessment identifies,
establishes and quantifies expected noise and vibration emissions associated with
the installation of the onshore cables and the construction and operation of the
converter station and substation. The operation of the onshore underground cables
and the subsea cables from mean low water has been scoped out of the
assessment, as they will not generate noise or vibration. There will be no vibration
from the operation of the substation and converter station; this has also been
scoped out of this assessment
12.2
The assessment is generated from the results of baseline noise monitoring and
predictive calculations of noise impact. The chapter identifies mitigation measures
that will be incorporated into the construction and operation of the development to
avoid, reduce or offset potential effects.
Legislation and Planning Policy Context
12.3
The National Planning Policy Framework (NPPF) has replaced Planning Policy
Guidance (including PPG 24 Planning and Noise), as the means by which noise is
considered in the planning regime. The NPPF does not contain assessment criteria
but instead provides a series of policies giving local authorities flexibility in meeting
the needs of local communities. The NPPF states:
‘The planning system should contribute to and enhance the natural and local
environment by […] preventing both new and existing development from
contributing to or being put at unacceptable risk from, or being adversely affected
by unacceptable levels of […] noise pollution.
Planning policies and decisions should aim to […]




12.4
avoid noise from giving rise to significant adverse impacts on health and quality
of life as a result of new development;
mitigate and reduce to a minimum other adverse impacts on health and quality
of life arising from noise from new development, including through the use of
conditions;
recognise that development will often create some noise and existing
businesses wanting to develop in continuance of their business should not
have unreasonable restrictions put on them because of changes in nearby land
uses since they were established; and
identify and protect areas of tranquillity which have remained relatively
undisturbed by noise and are prized for their recreational and amenity value for
this reason.’
Guidance outlined in Table 12.1 is generally used by local authorities to determine
the acceptability of noise associated with developments.
291
Table 12.1: Legislation and Policy Context
BS7445:2003 - Description and measurement of environmental noise - guide to quantities
and procedures
BS 7445 provides the framework within which environmental noise should be quantified.
Part 1 provides a guide to quantities and procedures and Part 2, a guide to the acquisition
of data pertinent to land use. Part 3 provides a guide to the application of noise limits. The
standard also refers to BS EN 61672, which prescribes the equipment necessary for such
measurements.
BS 5228-1:2009 - Calculation for noise from open and construction sites - Part 1: Noise
Construction noise impacts arising from equipment, vehicular movements and processes
related to the construction phase of a development are assessed by calculating the
change in ambient noise level (LAeq,1hr) resulting from such processes with methods
described in BS5228-1.
The assessment predicts noise emissions from various construction activities, which are
then compared against background noise levels at residential receptors. Full details of the
process are contained in Section E.3 of this standard.
Annex E of the standard also provides criteria for the assessment of significance.
Exceedances of threshold levels trigger a responsibility on the developer to provide noise
insulation or a scheme to facilitate temporary rehousing. The standard suggests that noise
insulation should be provided if trigger levels are predicted to be exceeded for a period of
ten or more days of working in any fifteen consecutive days, or for a total of days
exceeding 40 in any 6 month period.
BS 5228-2:2009 - Calculation for noise from open and construction sites - Part 2: Vibration
BS 5228-2 describes methods of mitigation that can be employed for construction groundborne vibration and provides historical library data of vibration levels measured during
various activities on various ground types.
BS 5228-2 reiterates the transient vibration guide values in the 4 – 15 Hz and 15 Hz and
above frequency bands that lead to cosmetic damage of BS 7385. BS 5228-2 also
discusses the assessment of the vulnerability of ground-related structures and services
-1
concluding that a maximum PPV for intermittent or transient vibration of 30 mms and a
-1
maximum PPV for continuous vibration of 15 mms . BS 5228 also discusses the
vulnerability of building contents and activities within buildings to vibration, concluding that
they too should be assessed on an individual basis.
BS 4142: 1997 - Method for rating industrial noise affecting mixed residential and
industrial areas
Comparison of the difference between the industrial noise level including any rating
penalty (the rating level) and the background noise level indicates the likelihood of
complaint. The greater the difference, the greater the likelihood of complaints arising.
A difference of around +10 dB or more indicates that complaints are likely.
A difference of around +5 dB is of marginal significance.
A difference of -10dB indicates that complaints are unlikely.
BS 4142 is not suitable for use in situations where both the industrial noise and the
background noise are very low (below 35 and 30 dB(A) respectively). Where this occurs,
a suitable alternative assessment method (such as criteria based on WHO guidelines)
should be utilised.
World Health Organisation Night Noise Guidelines for Europe 2009
Provides a target night-time noise level of 40 dB(A) outside of bedrooms in order to
protect the public.
292
Calculation of Road Traffic Noise (CRTN) & Design Manual for Roads and Bridges
(DMRB)
The ‘Calculation of Road Traffic Noise’ (CRTN) produced by the Department of Transport /
Welsh Office provides a method for the prediction of noise from road traffic. The Highways
Agency Design Manual for Roads and Bridges, Volume 11, Section 3, Part 7 Had 213/11
Noise and Vibration, provides guidance on the assessment of noise impacts from roads
and contains guidance for assessing the likely impact of noise generated by road traffic.
The criteria from DMRB for short-term effects have been used in the assessment of
changes to traffic noise as a result of proposed construction HGV traffic.
12.5
National Grid policy requires that the Rating Noise Level from their development
should not exceed the background noise level (LA90) at residential receptors. The
lowest background noise level measured at the nearest residential receptor has
therefore been used as a target for noise emissions. For the purposes of this
assessment, the noise level target is:

Assessed levels of cumulative noise from 1) the Proposed Development and 2)
from other proposed industrial developments, should not exceed the lowest
existing background noise levels;
Or, if the other (item 2 above) proposed assessed level of industrial noise is
predicted to exceed the lowest existing background noise levels and would not
be considered very low in accordance with BS4142 (i.e. very low Rating Level
equating to <35 dB(A)),

Noise from the Proposed Development should not contribute to total noise
levels at receptors from these other proposed industrial developments.
Method
Establishment of Baseline Environment
12.6
Environmental Health Officers at Thanet District Council and Dover District Council
agreed with the proposed monitoring methods and monitoring locations.
12.7
Monitoring locations were selected to measure ambient noise levels at sensitive
receptors (e.g. residential receptors and outdoor activity places) that might be
exposed to noise from cable installation works and the operation of the converter
station and substation. These locations are representative of other sensitive
receptors around the proposed substation and convertor station and cable route.
12.8
Monitoring and receptor locations are described in Table 12.2 and presented on
Figure 12.1. The monitoring location P4 represents receptors near to the junction
between Ebbsfleet Lane and Sandwich Road. Receptor points at R4a and R4b face
in the direction of the converter station and substation (and are used to assess
noise from the construction and operation of these aspects), while receptor point at
R4c faces the cable route (and is used to assess noise from cable installation).
12.9
Noise measurements were undertaken at eight agreed locations along the
proposed cable route and in the vicinity of the proposed converter station and
substation sites on 2nd May 2012 during day and night-time periods.
293
Table 12.2: Baseline Noise Monitoring Locations
Receptor
R1
R2
Monitoring Associated Aspect of
Location
Assessment
P1
Operation of converter
station and substation
P2
Operation of converter
station and substation
R3
P3
Operation of converter
station and substation
R4a
R4b
12.10
R4c
R5
P5
R6
P6
R7
P7
R8
P8
Construction of
converter station and
substation. Operation of
converter station and
substation
Cable installation
Construction of
converter station and
substation and
installation of cables
and operation of
converter station and
substation
Operation of converter
station and substation
Construction of
converter station and
substation and cables
installation. Operation
of converter station and
substation
Operation of converter
station and substation
Residential property to the
north of Kings End farm
house
Residential property to the
north east of Richborough
Roman Fort and
Amphitheatre.
Residential property on
Ramsgate Road, at Stonar
Cut adjacent to Stevens &
Carlotti Ltd
Residences near to the
junction of Sandwich Road
and Ebbsfleet Lane
Ebbsfleet Farm, Ebbsfleet
Lane
Entrance of Pegwell Bay
Country Park off Sandwich
Road
Residential property
opposite Jet Garage to the
west of St Augustine’s Golf
Course, approximately 129,
Sandwich Road
Entrance of BayPoint sports
complex
Sound level measurements were made with the following equipment:


12.11
P4
Monitoring Location
Description
Norsonic Nor-118 (serial number 31677) with pre-amplifier and microphone
protected by the manufacturers approved foam windshield;
and
Norsonic acoustic calibrator type 1251, serial number 037732.
Measurements were taken in free-field conditions, i.e. 1.5m above the ground and
away from reflective building facades.
Microphones were fitted with foam
windshields to protect against extraneous wind noise. Weather conditions at the
time of survey were noted as being dry and calm during the night-time
measurements, but with elevated wind speeds during the daytime measurements.
294
12.12
Wind speeds during measurements at location P2 were unsuitable for purpose (>
5m/s). This measurement has been excluded.
12.13
Field calibration checks of the sound level meter were made before and after each
measurement session using an acoustic calibrator. No significant calibration drift
was noted.
12.14
The sound level meter used conforms to the requirements of BS EN 61672-1: 2003
Electroacoustics, Sound level meters, Specifications and the calibrator conforms to
the requirements of BS EN 60942: 2003 Electroacoustics, Sound calibrators. The
equipment used has a calibration history that is traceable to a certified calibration
institution.
Construction
12.15
Noise levels from the construction elements of the Proposed Development have
been calculated based on the method set out in BS5228: 2009. This method uses
information on the plant and equipment used during the construction phase to
predict noise levels at the sensitive receptors.
12.16
Noise levels at receptors as a result of construction are affected by the distance
between the source and receiver, the presence of noise screening (whether
inherent or purposely provided), meteorological conditions, and the duration of
activity. For the purposes of predicting noise from construction work the following
have been considered:



12.17
Soft ground condition between source and receiver;
No screening; and
Continuous operation of all equipment throughout the day.
The impact of the construction noise levels is determined by comparing total noise
levels (ambient plus predicted plant noise) with existing ambient noise levels,
having due regard to the predicted duration of the construction activities.
Operation
12.18
Noise levels from the operation of the proposed converter station and the substation
have been calculated based on the method set out in ISO 9613. This methodology
uses information on the plant and surrounding environment to calculate noise levels
at sensitive receptors within the CadnaA (4.2.140) software.
12.19
CadnaA software predicts noise using industry standard propagation method ISO
9613, which takes into account intervening screening and atmospheric and ground
absorption. The parameters used within the model for these aspects were:



Screening = No screening considered due to the flat terrain surrounding the
substation locations;
Air Absorption = 10C / 70% Relative Humidity; and
Ground absorption = 0.1 coefficient for site (hard) ground, 0.7 coefficient for
surrounding (soft) ground.
295
12.20
The impacts of the operational aspects of the proposed development on residential
receptors have been determined with reference to the guidance set out in BS4142:
1997. This method compares the predicted ‘industrial’ noise assessment level to the
existing background level, to determine the likelihood of complaints
12.21
For the assessment of the effect of plant noise on leisure areas, a comparison
between the LAeq of the plant noise and the LAeq measured during the daytime at
leisure areas has been made and the resulting difference assessed with reference
the criteria provided in Tables 12.3-12.5.
Assessment of Significance
12.22
The significance of noise effects from construction and operation has been
assessed using the criteria outlined in Table 12.3 and Table 12.4. A combination of
receptor sensitivity and magnitude of effect has been used to determine the overall
significance of the effect (Table 12.5).
Table 12.3: Sensitivity of Noise Receptor
Receptor
Sensitivity
Description
High
Residential area.
Medium
Area formally designated for leisure activities (in this case
the golf course, BayPoint sports complex and Country
Park)
Low
Area not formally designated for leisure activities (for
example most countryside and land remote from
habitation)
Negligible
All other areas such as those used primarily for industrial
or agricultural purposes.
Table 12.4: Magnitude of Effect
Magnitude
Examples
Large
Construction noise levels predicted to exceed BS 5228 levels to a
degree and for a duration triggering noise insulation requirements
or temporary re-housing.
Increase in short-term traffic noise from construction at residential
receptors >5 dB(A).
Construction vibration levels persistently exceed 10 mm/s ppv at
the nearest houses.
Complaints considered likely from operation in accordance with
BS4142 or predicted rating noise levels exceed 35 dB(A) if
receptor background levels are <=30 dB(A).
Intrusive increase in noise at non-residential receptors.
296
Magnitude
Examples
Medium
Construction noise levels predicted to exceed BS 5228-1
threshold values, but not trigger noise insulation or temporary rehousing requirements.
Increase in short-term traffic noise from construction at residential
receptors 3-4.9 inclusive dB(A).
Construction vibration levels occasionally exceed 10 mm/s ppv at
the nearest houses.
Complaints considered of marginal significance from operation in
accordance with BS4142 and above National Grid criteria of no
increase above the background noise.
Clearly perceptible increase in noise at non-residential receptors.
Small
Noise levels will cause some minor temporary disturbance, but
noise levels do not exceed BS 5228-1 threshold values.
Increase in short-term traffic noise from construction at residential
receptors 1-2.9 inclusive dB(A).
Minor perceptible vibration below 10 mm/s ppv at the nearest
houses.
Complaints not considered likely from operation.
Just perceptible increase in noise at non-residential receptors.
Negligible
Construction noise levels unlikely to cause any disturbance.
Increase in short-term traffic noise from construction at residential
receptors <1 dB(A).
No perceptible vibration at the nearest houses.
Complaints unlikely from operation in accordance with BS4142 or
predicted rating noise levels are <= 35 dB(A) if receptor
background levels are <=30 dB(A).
Imperceptible increase in noise at non-residential receptors.
Table 12.5: Overall Significance
Magnitude
Sensitivity
High
Medium
Low
Negligible
Large
Significant
Significant/
Moderate
Moderate
Neutral
Medium
Significant/
Moderate
Moderate
Moderate/Minor
Neutral
Small
Moderate /
Minor
Minor
Minor/Neutral
Neutral
Negligible
Minor/Neutral
Minor/Neutral
Neutral
Neutral
297
Existing Environment
12.23
Attended measurements were obtained at selected monitoring locations during day
and night time periods. Noise measurements are summarised in Table 12.6.
Table 12.6: Summary of Attended Measurements
Time
Period
Day
Duration
Dominant Noise
Time (minutes) LAeq, T dB LA90, T dB Source
Location
Date
P1
02/05/2012
P2
During the daytime, the exposed nature of this location meant that wind
speed was too high to obtain representative results.
P3
02/05/2012 10:20 30
70.3
60.9
Road traffic noise
P4
02/05/2012 10:59 30
66.6
55.8
Road traffic noise
P5
02/05/2012
12:15 30
50.5
44.1
Road traffic noise
and car park noise
P6
02/05/2012
12:52 30
53.8
47.7
Road traffic noise
and birdsong
P7
02/05/2012
13:33 30
64.2
52.5
Road traffic noise
and birdsong
P8
02/05/2012
P1
02/05/2012
P2
02/05/2012
09:21 30
48.2
40.3
11:36 20
55.6
53.4
Road traffic noise,
shorter measurement
taken due to high
wind speed
00:47 15
31.5
27.3
Industrial noise from
the north
01:09 15
34.1
27.6
Distanced Road
traffic noise
01:40 15
52.2
32.5
Industrial noise
('hum') from existing
substation
02:14 15
52.0
32.9
Road traffic noise
and air traffic noise
Night
P3
02/05/2012
P4
02/05/2012
Agricultural noise and
nature
12.24
The general noise climate at sensitive receptors along the proposed cable route
and in the vicinity of the proposed converter station and substation is primarily
affected by road traffic noise, existing industrial noise, noise from agricultural
activities and birdsong.
12.25
Given the distance to the substation and converter station site, receptors
represented by measurement P7 would be only potentially affected by the
installation of the cable (assumed to be daytime only near to this location); therefore
a night-time measurement was not taken at this location.
12.26
P6 and P8 represent leisure areas, users of which would only be affected during the
day by noise from the construction and operation of the Proposed Development;
therefore night-time measurements were not taken at these locations. Noise levels
at location P2 during the night are considered representative of a worst-case noise
environment at location of P5.
298
12.27
Measurements were taken during times when wind speeds would be considered
acceptable for a noise survey, however at P2 (during the daytime), wind speeds
were above 5m/s which was likely due to be the exposed nature of this location.
Noise levels at location P1 during the day are considered representative of a worstcase noise environment at location of P2.
Prediction and Assessment of Significance of the Potential Impacts
Construction
12.28
The target threshold levels at locations referred to in Table 12.2 for the assessment
of construction noise (based on proximity to works and sensitivity of receptor) have
been identified based on measured ambient noise levels using the method set out
in Annex E of BS5228:2009. The thresholds are presented in Table 12.7.
Table 12.7: Target Threshold Levels for Construction Noise
Location
P4
P5
P7
Measured Ambient Noise
Levels dB(A)
Day
Night
67
52
51
64
-
Target Threshold Levels,
dB(A)
Day
Night
72
57
65
69
-
Construction Noise – Cable Installation
12.29
Equipment that will be used during cable installation is shown in Table 12.8. Noise
level data has been taken from Annex C of BS 5228-1: 2009. All sound pressure
levels are given at a distance of 10m from the measured plant.
Table 12.8: Noise Levels of Construction Equipment – Cables Installation
Plant
No#
BS5228
ref.
Operational A-weighted
Hours
SPL (dB(A)
at 10 m
Tracked excavator (22t)
2
C.2.3
90 %
73
Dozer
3
C.2.1
90 %
75
Construction of Wheeled backhoe loader (8t) 1
temporary site Dumper (5t)
2
access road
Vibratory roller (3t)
1
C. 2.8
90 %
68
C. 4.7
90 %
78
C. 2.40
90 %
73
Activity
Topsoil strip
Trench
excavation
Tracked excavator (16t)
1
C. 2.5
90 %
76
Tracked mobile crane
1
C.3.29
90 %
70
Sheet Piling – Hydraulic
jacking
1
C.3.9
Power Pack
1
C.3.10
3
C.3.28
1
C. 4.88
Side boom (Use tracked
Lower and lay mobile crane data)
Water pump
299
90 %
90 %
90 %
90 %
63
68
67
68
Activity
Backfilling
trench
Reinstatement
BS5228
ref.
Operational A-weighted
Hours
SPL (dB(A)
at 10 m
Wheeled backhoe loader (8t) 1
C. 2.8
90 %
68
Wheeled backhoe loader (8t) 1
C. 2.8
90 %
68
Tracked excavator (16t).
1
C. 2.5
90 %
76
Dumper (5t)
2
C. 4.7
90 %
78
Vibratory roller (3t)
2
C. 2.40
90 %
73
Dumper (5t)
2
C. 4.7
90 %
78
Wheeled backhoe loader (8t) 1
C. 2.8
90 %
68
Welding generator
3
C. 3.32
90 %
73
Welder
3
C. 3.31
90 %
73
3
C. 4.94
90 %
75
2
C. 4.93
90 %
80
Plant
No#
Transition Joint Generator
Pit
Angle grinder
Cable pulling
Horizontal
Directional
Drilling
12.30
Side boom (Use tracked
mobile crane data)
90 %
1
C.3.28
Conveyor drive unit
1
C.10.20
90 %
77
Field conveyor (rollers)
2
C.10.23
90 %
53
Power Auger (Crawler
Mounted Rig)
1
C.3.21
67
100 %
79
Noise levels at the nearest sensitive receptors have been calculated according to
the method presented within BS 5228. Based on plant type, number and forecast
operational time of the equipment, Tables 12.9-12.11 provide calculated ‘worstcase’ construction noise levels for each aspect of cabling installation works (with the
exception of horizontal directional drilling (HDD) during the day at the nearest
receptors to the works. The ‘combined noise level’ is derived by logarithmically
adding the construction noise level to the ambient noise level.
Table 12.9: Predicted Construction Noise at Receptors near to the Junction
of Ebbsfleet Lane and Sandwich Road (R4c), 45m from Onshore Underground
Cable Route
Construction
Aspect
Topsoil strip
Construction of
temporary site
access road
Trench excavation
Predicted
Construction
Noise Level
dB(A)
65.3
Ambient
Noise
Level
dB(A)
Target
Threshold
Level
dB(A)
Combined
Noise
Level
dB(A)
69.3
Increases
over
Threshold
dB
-3
67.7
70.4
-2
65.9
69.5
-3
67.9
-4
Lower and lay
60.7
Backfilling trench
Reinstatement
Pipe welding
Cable pulling
Horizontal
Directional Drilling
69.3
66.6
70.7
65.2
71.3
69.8
72.2
69.2
-1
-2
0
-3
67.2
70.1
-2
67
300
72
Table 12.10: Predicted Construction Noise at R7, 78m from Onshore
Underground Cable Route
Construction
Aspect
Topsoil strip
Construction of
temporary site
access road
Trench
excavation
Lower and lay
Backfilling
trench
Reinstatement
Pipe welding
Cable pulling
Predicted
Construction
Noise Level
dB(A)
59.4
Ambient
Noise
Level
dB(A)
Target
Threshold
Level
dB(A)
Combine
Noise
Level
dB(A)
65.3
Increases
over
Threshold
dB
-4
66.0
-3
65.4
-4
64.5
-5
63.4
66.7
-2
60.7
64.7
59.3
65.7
67.4
65.3
-3
-2
-4
61.8
59.9
54.7
64
69
Table 12.11: Predicted Construction Noise at R5, 580m from Onshore
Underground Cable Route
Construction
Aspect
Topsoil strip
Construction of
temporary site
access road
Trench
excavation
Lower and lay
Backfilling
trench
Reinstatement
Pipe welding
Cable pulling
Predicted
construction
noise level
dB(A)
37.6
Ambient
noise
level
dB(A)
Target
threshold
level
dB(A)
Combined
noise
level
dB(A)
51.2
Increases
over
threshold
dB
-14
51.3
-14
51.2
-14
51.1
-14
41.6
51.5
-14
38.9
42.9
37.5
51.3
51.6
51.2
-14
-13
-14
40.0
38.1
32.9
51
65
12.31
The results show that noise levels are predicted not to exceed target threshold
levels during the day at nearby residential receptors. As noise is attenuated with
distance, noise levels at receptors further away from the construction than those
identified at R4, R5 and R7 would also not be anticipated to exceed threshold
levels. Results in Tables 12.9 to 12.11 represent the highest predicted noise levels,
which will only be temporarily at this level, decreasing as the cable installation
passes by.
12.32
HDD will be used to install cables between BayPoint sports complex and the
proposed converter station and substation site. The nearest receptors to the HDD
301
works are residences at the junction of Sandwich Road and Ebbsfleet Lane (R4c).
Technical requirements associated with HDD operations mean that the installation
of each cable will likely need to take place continuously to remove the risk of hole
collapse. Installation is anticipated to consist of a maximum of 33 hours for each
cable (reasonable worst case which also allows for any unforeseen complications
during drilling). There are 3 cables in total and there will be a day of no drilling
whatsoever between each of the 3 cable installation phases. Based on the
predicted plant type, number and forecast operational time of the equipment, Table
12.12 provides a calculated construction noise level for HDD during the day and
night at R4c.
Table 12.12: Predicted HDD Noise at Receptors at the Junction of Ebbsfleet
Lane and Sandwich Road (R4c)
Time
Day
Night
Predicted
Construction
Noise Level
dB(A)
67.2
67.2
Ambient
Noise
Level
dB(A)
67
52
Target
Threshold
Level
dB(A)
72
57
Combined Increases
Noise
over
Level
Threshold
dB(A)
dB
70.1
-2
67.4
+10
12.33
Results show that HDD noise levels are predicted to exceed the target threshold
levels during the night at R4a and R4b. However, HDD is anticipated to be for a
maximum of 2 days and 1 night for each cable (3 cables, maximum of 3 nights of
HDD works).
12.34
The time over which these worst-case noise levels would be experienced at an
individual receptor is likely to be 3 nights. This period of time is less than that which
needs to be exceeded for residential receptors to be eligible for sound insulation
(within the criteria suggested by BS5228). However, National Grid will implement
mitigation measures during HDD works (see mitigation section below) to ensure
noise is minimised.
12.35
Worst-case noise levels from the cable installation would result in a small and
medium magnitude of effect on receptors of high sensitivity for excavated cable
installation and HDD respectively.
Construction Vibration – Cable Route
12.36
All residential properties are greater than 10m from the onshore underground
cables route and the converter station and substation site. The nature of the
construction equipment used means that, where works occur more than 10m from
buildings, the risk of construction vibration generating significant impacts is
negligible for receptors of high sensitivity.
Construction Noise – Substation and Converter Station
12.37
The noise levels of equipment anticipated to be used for the construction of the
substation and converter station are shown in Table 12.13.
302
Table 12.13: Noise Level of Construction Equipment – Substation and
Converter Station
Plant
No#
Front end loaders (wheeled)
Tracked excavator
Wheeled backhoe loader
Wheeled loader
Dozer
Articulated dump truck
Road roller
Graders
Material Handling
Cement mixer truck
Truck mounted concrete pump and
boom arm
Wheeled mobile telescopic crane
Diesel generator for site cabins
1
1
1
1
1
1
1
1
1
1
1
1
1
Operational
hours
A-weighted SPL
(dB(A) at 10 m
90 %
90 %
90 %
90 %
90 %
90 %
90 %
90 %
90 %
90 %
90 %
82
77
68
79
80
74
80
75
86
75
90 %
100 %
78
65
80
12.38
Noise emission levels at the nearest residential receptor from the construction work
of the substation and converter station have been calculated according to the
method presented within BS 5228.
12.39
The closest residential receptor is 340m to the northeast of the proposed substation
and converter station site boundary. Resultant worst-case noise levels would be
54 dB(A). This is below the BS5228 target threshold of 72 dB(A), and as such
would result in a small impact on receptors of high sensitivity.
Construction Vibration – Substation and Converter Station
12.40
The large distance between the converter station and substation site and sensitive
receptors means that there is no potential for vibration from these works to affect
sensitive receptors. The impact of vibration will therefore be negligible on receptors
of high sensitivity.
Construction Noise and Vibration – Traffic
12.41
There will be a small number of traffic movements (Heavy Goods Vehicle)
associated with the construction of the substation and converter station and cable
route. For a significant impact to occur, traffic noise levels would have to increase in
the short-term by >1 dB(A), which would result from an approximate 25% increase
in traffic. As construction traffic flows would be well below this level, the impact from
traffic noise would be negligible on receptors of high sensitivity.
303
Operation
Operational Noise – Substation and Converter Station
12.42
The proposed substation and converter station have been modelled using CadnaA
noise prediction software (version 4.2.140) based on an indicative layout. The
components to be installed, which are potential sources of noise, are listed in Table
12.14. The location of the noise sources are described in Chapter 2 (Project
Description) and shown on Figure 12.2.
12.43
A 5 dB ‘rating penalty’ has been applied to the modelled noise levels of
transformers and reactors to account for their tonality. Cooling fans (including air
handling unit (AHU) fans) produce a broadband noise and therefore do not have a
tonal penalty applied. Based on a careful consideration of likely operational
requirements, it is assumed that Super Grid Transformer coolers would only be
required in emergency situations and that MSCDNs are only operational during the
day. A full list of equipment details and assumptions are presented in Appendix
12.1.
Table 12.14: Modelled Sound Power Levels of Major Equipment within the
Proposed Substation and Converter Station (No Mitigation Measures)
Sound Power
Level [for
individual plant
items] including
tonal penalty (5
dB(A)) where
appropriate
Plant Name & Quantity
SUBSTATION SITE
1 x Static Compensator Transformer (SCT)
1 x SCT Cooler
9 x valve cooling fans for Static Variable Compensator (SVC)
2 x Super Grid Transformers (SGT)
1 x Thyristor Controlled Reactor set (TCR)
1 x Substation Mechanically Switched Capacitor with
Damping Network set (MSCDN)
2 x Harmonic Filter set
CONVERTER STATION SITE
3 x Converter Station Transformer
3 x Converter Station Transformer coolers
1 x Converter station 200MVA Shunt Reactor
1 x Converter Station Shunt Reactor cooler
40 x Converter Station Valve Cooling Fans
1 x Converter Station Mechanically Switched Capacitor with
Damping Network set (MSCDN)
3 x Converter Station Air Handling Units (AHU)
12.44
100 + 5
90
80
90 + 5
105 + 5 per set
85 + 5 per set
85 + 5 per set
90 + 5
90
91 + 5
84
80
85 + 5 per set
87
Resultant noise levels from the substation and converter station at residential
locations and BS4142 assessment are presented in Table 12.15.
304
Table 12.15: Converter Station and Substation BS4142 Assessment (dB) at
Residential Receptors [No Mitigation]
Location
Background
Level (LA90) dB
Day
R1
R2
R3
R4a
R4b
R5
R7
40
40
61
56
56
44
53
Rating Level, dB
Night
Day
Night
27
28
33
33
33
28
33
29
29
32
47
44
38
30
29
29
32
47
44
38
30
Assessment level
(Difference of Rating
Level over LA90, dB)
Day
Night
-11
-11
-29
-9
-12
-6
-23
+2
+1
-1
+14
+11
+10
-3
12.45
Results show that complaints would be considered likely at three locations (R4a,
R4b and R5) in accordance with BS4142 as a result of cumulative unmitigated
noise levels from both the substation and converter station. This would represent an
operational noise impact of large magnitude on receptors of high sensitivity.
12.46
Resultant noise levels from the substation and converter station at locations used
for leisure activities and a comparison assessment with the existing noise levels is
presented in Table 12.16 based on daytime LAeq noise levels.
Table 12.16: Plant Noise at Locations used for Leisure (dB)
Location
R6
R8
Baseline Level (LAeq)
dB
54
56
Plant Noise
Level dB
38
46
Assessment Level
(Difference of Rating
Level over LAeq, dB)
-16
-10
12.47
Results show that noise levels would not have an effect on the existing baseline.
This level of effect would be considered of negligible magnitude on receptors of
medium and low sensitivity.
12.48
The noise models are ‘worst case’ because they assume that plant is operating
continuously on full load (with the exception of the SGT coolers and MSCDNs). This
will not be the case at all times. For example, the plant will not be 100% utilised for
all of the time and because ambient temperatures will be lower during the night and
in winter; therefore cooling plant that is in service may not need to operate at full
capacity.
Significance
12.49
The assessment of the significance of potential impacts is summarised in Table
12.17.
305
Table 12.17: Significance of Impact of Noise Effects (No Mitigation)
Aspect
Sensitivity*
Magnitude
Significance
Construction Noise – Cable route
excavation
High
Small
Moderate
Construction Noise – HDD
High
Medium
Moderate
Construction Noise – Substation
and converter station
High
Small
Moderate
Construction Noise (substation,
converter station and cable) –
Traffic
High
Negligible
Minor
Construction (substation and
converter station) - Vibration
High
Negligible
Neutral
Operation Noise (substation and
converter station) - Residential
High
Large
Significant
Operation Noise (substation and
converter station) – Formal leisure
areas
Medium
Negligible
Neutral
Operation Noise (substation and
converter station) – Informal leisure
areas
Low
Negligible
Neutral
*Where receptor type unspecified, highest sensitivity chosen
Mitigation
Construction
12.50
Best practice construction noise methods will be used to minimise noise associated
with cables installation and construction of the substation and converter station.
Such best practice measures include:




12.51
Site vehicles will not be over revved, or left with engines idling in close
proximity to residential neighbours; and
All plant and machinery to be properly maintained and silenced in accordance
with manufacturer's instructions;
Development of a Construction Management Plan detailing the mitigation to be
used throughout each stage of construction; and
Regular communication with residents living close to the cable route and
converter station and substation site. The communication will include details of
expected work schedules and activities taking place, and contact details in
case of query or complaint.
In addition the following measures will be used to ensure that disturbance due to
construction noise is minimised:

Screening of HDD noise emission points at HDD using layout of temporary
structures (such as site offices) and hoarding; and
306

Although the assessment of vibration effects from cables installation at a
distance of 10m or more has been assessed as negligible, where cabling works
pass within 20m of properties pre and post construction building surveying will
be undertaken. This would be used to demonstrate no adverse effect have
occurred or, very unlikely, would inform any future assessments for making
good any damage caused by vibration. In addition, vibration monitoring will be
undertaken at the start of the construction works in order to more accurately
quantify the risk of vibration generated by each stage of the works giving rise to
a significant impact at varying distances. This data will be used, if necessary,
to modify the distance from the route at which building surveys are triggered.
Operation
12.52
Without mitigation, there is potential for the operation of both the converter station
and substation to give rise to complaints from neighbouring properties. Mitigation
will be incorporated into the design of the converter station and substation to ensure
that the noise target (assessed noise levels of the proposed converter station and
substation are no higher than the background noise levels) is achieved. This
assessment will be based on, in many cases, worst case operational scenarios;
therefore it is considered to be appropriately conservative.
12.53
Prior to commencement of works on the converter station and substation, modelling
will be undertaken on the final design and layout of the plant to verify that the above
noise target is met. Sound power levels can be reduced through design, selection
of equipment and by employing mitigation measures, which, as examples, could
include:
For Substation:




TCRs housed within noise shields or a full noise enclosures;
Noise shields to Harmonic Filters;
Enclosures around the SCT and SGTs; and
Low noise fans, silencers on cooling fans or barriers around cooling fans.
For Converter Station:


Enclosures around the Shunt Reactor and Converter Station transformers
Low noise fans, silencers on cooling fans or barriers around cooling fans
Residual Impacts
12.54
Residual noise levels from the substation and converter station and a BS4142
assessment are presented in Table 12.18.
Table 12.18: Converter Station and Substation BS412 Assessment (dB) at
Residential Receptors with Mitigation
Location
R1
R2
R3
Background Level
(LA90) dB
Rating Level, dB
Day
40
40
61
Day
19
19
16
Night
27
28
33
307
Night
19
19
15
Assessment level
(Difference of Rating
Level over LA90, dB)
Day
Night
-21
-8
-21
-9
-45
-18
Location
Background Level
(LA90) dB
Rating Level, dB
R4a
R4b
R5
Day
56
56
44
Day
30
26
23
Night
29
25
22
Assessment level
(Difference of Rating
Level over LA90, dB)
Day
Night
-26
-4
-30
-8
-22
-6
R7
53
12
11
-41
Night
33
33
28
33
-22
12.55
The above results show that complaints as a result of substation and converter
station noise would not be considered likely, after mitigation is applied.
12.56
The maximum noise effect would be considered of small magnitude on receptors of
high sensitivity.
12.57
Table 12.19 shows a summary of the residual impacts after mitigation has been
taken into consideration.
Table 12.19: Residual Impacts
Potential Impact
Significance of
Impact
Mitigation
Measure
Residual
Significance of
Impact After
Mitigation
Moderate
Best practice
techniques,
communications
with residences
Minor
Moderate
Best practice
techniques,
communications
with residences,
screening
Moderate
Construction
Noise –
Substation and
converter station
Moderate
Best practice
techniques,
communications
with residences
Minor
Construction
Noise (substation,
converter station
and cable) –
Traffic
Negligible
N/A
Minor
Neutral
Potential
measurements if
properties within
20 m
Neutral
Construction
Construction
Noise – Cable
route excavation
Construction
Noise – HDD
Construction
Vibration
308
Operation
Operation Noise
(substation and
converter station)
-Residential
12.58
Significant
Operation Noise
(substation and
converter station)
- Formal leisure
areas
Neutral
Operation Noise
(substation and
converter station)
- Informal leisure
areas
Neutral
Minor
Reduction of
sound power at
source by design
or by application
of mitigation
measures
Neutral
Neutral
With the identified measures in place it has been shown that all significant impacts
would be appropriately mitigated such that the overall effect of the Proposed
Development is not considered significant.
Cumulative Impacts
12.59
The following planned or permitted industrial developments have the potential to
contribute to total noise levels in combination with predicted noise from the
proposed substation and converter station plant:



Richborough Energy Park Peaking Plant (PP);
Thanet Waste Recycling Sites (TWS); and
CHP Plant at the Ebbsfleet Farm Anaerobic Digestion Plant (CHP)
Site Descriptions
12.60
A planning application including a supporting Environmental Impact Assessment
was submitted in December 2012 for a ‘peaking plant’, comprised of 53 diesel
generators (50 generators assumed to be running at any one time), which will be
used to provide peak electricity supplies to the local distribution network This
peaking plant is expected to run for 100-300 hours per year (4 to 12.5 days).
12.61
The existing Thanet Waste site at Richborough Hall on Ramsgate Road is to be
expanded with an additional location developed on land to the north of Stevens and
Carlotti off Ramsgate Road. Proposals include the construction of a materials
recycling facility on the existing site and the construction of an inert waste materials
recovery and processing facility and a soil washing plant on the new site. TW
Services appointed SLR Consulting Limited to undertake the noise assessment for
the site.
12.62
The Ebbsfleet Farm Anaerobic Digestion Plant is planned for the area of land
between the Minster Stream and the recently built A256 bypass, north of the
proposed converter station. The notable noise source within the Anaerobic
Digestion Plant is the Combined Heat and Power (CHP) Plant. Laurence Gould
309
Partnership prepared a supporting statement for the site, including a noise
assessment.
Construction
12.63
It is likely that construction of the three sites considered above would occur only
during normal daytime working hours.
12.64
Detailed information on construction of the peaking plant is not available at present.
The supporting statement for the Ebbsfleet Farm Anaerobic Digestion Plant does
not include an assessment of noise from the construction of the site. If it were
assumed that the construction plant and methods for these sites would be similar
to, and occur simultaneously to those of the Proposed Development, construction
noise levels would be 59dB(A) at the closest property to the substation and
convertor station site (R4).
12.65
The cumulative construction noise from both of the Thanet Waste sites was
predicted by SLR as 57 dB(A)1 at the nearest residential receptor on Ramsgate
Road, R3 within this assessment. Based just on distance attenuation, the predicted
noise level from the construction of the Thanet sites would be 53 dB(A) at the
closest property to the substation and converter site, R4. Based just on distance
attenuation, the predicted noise level from the construction of the Proposed
Development, CHP and peaking plant at receptor R3 would be 53 dB(A). The
resulting cumulative noise at R3 and R4 would be 60 dB(A) and 59 dB(A)
respectively, both below the target threshold levels for the daytime. This would
result in a small, but not significant impact.
Operation
12.66
An indicative layout (spread equally throughout the peaking plant site as shown on
Figure 12.2) of 50 generators has been modelled using CadnaA noise software with
a sound power level of 87 dB(A) for each generator (including a 5dB tonal penalty).
Peaking plant use will be during times of the day of peak energy demand (for
instance, during breakfast and early evening).
12.67
Predicted operational noise from both Thanet Waste sites at the nearest residential
receptor, R3, is a Rating Level (including a 5 dB penalty) of 54 dB(A).2 Noise levels
at other receptors identified within this assessment have been predicted by
adjusting the noise level of 54 dB(A) according to the difference in distances
between the sites to R3 and the sites to other receptors.
12.68
The noise level from the CHP is stated as 65 dB(A)2 at 10m. The CHP has been
modelled as a point source within CadnaA software based on the sound pressure
level at 10m and an indicative sound spectrum based on RSK [the author]
experience of similar CHP equipment.
12.69
Resultant noise levels and BS4142 assessment for the substation, converter
station, peaking plant, Thanet Waste Sites and the Ebbsfleet Farm CHP at
residential locations are presented in Table 12.20.
1
SLR Consulting Limited, Noise Assessment, Sept 2010 (Ref: 409-03301-00001),
https://shareweb.kent.gov.uk/Documents/environment-and-planning/planning-and-land-use/Thanet%20waste%20services%20%20major%20proposal/application%20documents/Environmental%20statements/noise-assessment.pdf
2
Laurence Gould Partnership Ltd, Ebbsfleet Farm Anaerobic Digestion Plant Supporting Statement (Feb, 2012)
310
Table 12.20: Cumulative Mitigated Converter Station and Substation BS4142
Assessment (dB) at Residential Receptors
Loc.
R1
R2
R3
R4a
R4b
R5
R7
Background Level
(LA90) dB
Day
40
40
61
56
56
44
53
PP (Day)
Night
27
28
33
33
33
28
18
19
26
29
26
21
33
16
Rating Level, dB(A)
TWS
CHP
(Day)
(Day &
Night)
40
15
42
15
54
22
42
46
42
40
38
29
34
18
Day
40
42
54
48
44
39
Total +
NEMO
Night
20
20
23
46
40
30
34
19
Assessment level
(Difference of Rating Level
over LA90, dB)
Day
Night
0
-7
+2
-8
-7
-10
-8
+13
-12
+7
-5
+2
-19
-14
12.70
Results show that the cumulative noise from all planned and permitted industrial
developments would exceed the target level during the day at R2 and during the
night at R4 (a & b) and R5. Noise levels at R5 during the night would be considered
very low in reference to BS4142; therefore this exceedance by the cumulative noise
would be an impact of negligible magnitude and not significant.
12.71
At those locations where the cumulative noise assessment level exceeds the
background noise level (and where the cumulative and background noise are not
considered very low in BS4142), the predicted Proposed Development noise would
not contribute to total noise levels as Proposed Development noise would be 10 dB
less than the cumulative noise from other sites (i.e. if the planned and permitted
industrial developments were operational, the target noise level would be exceeded
regardless of whether the Proposed Development was operational or not). This
relationship is shown in Table 12.21. Therefore the cumulative noise impact of the
Proposed Development would be considered small and not significant.
Table 12.21: Differences between Proposed Development Rating Level (dB(A))
and Other Planned and Permitted Industrial Noise Sources in the Area
Loc.
R2
R4a
R4b
12.72
Background Level
(LA90) dB
Proposed
Development Rating
Level, dB(A)
Cumulative Rating
Level, dB(A) Of
Other Noise
Sources
Difference Between
Proposed Development
Rating Level & Other
Noise Sources, dB(A)
Day
Night
Day
Night
Day
Night
Day
Night
40
56
56
28
33
33
19
30
26
19
29
25
42
48
44
15
46
40
-23
-18
-18
+4
-17
-15
Table 12.21 shows that Proposed Development Rating Noise Levels would not
significantly contribute to other proposed industrial noise sources in the area where
these would result in exceedances of existing background noise level. At location
R2 during the night, where Proposed Development Rating Noise Levels are 4 dB
higher than other proposed industrial noise sources, the Proposed Development
noise level is 9 dB lower than the existing background level, which would be
considered an impact of small magnitude and minor significance.
311
12.73
Resultant noise levels from the substation and converter station at locations used
for leisure activities and a comparison assessment with the existing noise levels is
presented in Table 12.22 based on daytime LAeq noise levels.
Table 12.22: Cumulative Plant Noise at Locations used for Leisure with
Mitigation (dB)
Location
12.74
Ambient
Noise Level
(LAeq) dB
Rating Level, dB(A) Daytime
PP
TWS
CHP
Total +
Proposed
Development
Assessment
Level
(Difference of
Rating Level
over LAeq, dB)
R6
54
23
39
30
40
-14
R8
56
30
40
45
46
-10
Results above show that noise levels would not have an effect on the existing
baseline. This level of effect would be considered of negligible magnitude on
receptors of medium and low sensitivity and not significant.
References





BS 4142: 1997 - Method for rating industrial noise affecting mixed residential
and industrial areas
BS 5228-1:2009 - Calculation for noise from open and construction sites - Part
1: Noise
BS 5228-2:2009 - Calculation for noise from open and construction sites - Part
2: Vibration
BS7445:2003 - Description and measurement of environmental noise - guide to
quantities and procedures
Siemens report ‘Audible Noise Study Report – Grain Converter Station’ (E T
PS/P-100010/ED1.088.G-B)
312
313
314
13.0
AIR QUALITY
Introduction
13.1
This chapter provides an assessment of the potential impacts on air quality during
the construction of the Proposed Development (i.e. the UK onshore elements of the
Nemo Link - see Chapter 2, Project Description).
13.2
The Proposed Development will make no emissions to air during operation and as
such is not included in this assessment. This approach was detailed in the EIA
scoping report and agreed by the Local Planning Authorities as appropriate to be
scoped out.
13.3
The potential construction effects arise from two sources which are considered in
this chapter: construction traffic including the operation of motor vehicles and plant;
and dust arising from construction works.
13.4
An air quality assessment of the effects arising from construction traffic has been
undertaken and is included as Appendix 11.2 to be read in conjunction with the
Traffic and Transport Assessment (Chapter 11).
13.5
Effects on air quality from emissions of onsite plant such as generators, excavators
and trucks were scoped out from further assessment at the EIA scoping stage due
to the small numbers of plant distributed across a large area. This approach was
also detailed in the EIA scoping report and agreed by the Local Planning Authorities
as appropriate to be scoped out.
Legislation and Planning Policy Context
National Legislation
13.6
The principal air quality legislation within the United Kingdom is the Air Quality
Standards Regulations 2010 which transpose the European Directive 2008/50/EC
in relation to limit values for air quality.
13.7
This legislation is further supported by the Air Quality Strategy for England,
Scotland, Wales and Northern Ireland (Defra, 2007) which provides the overarching strategic framework for air quality management in the UK with quality
standards and objectives designed to protect human health. The standards apply to
outdoor locations which have regular use. Local Authorities have a duty to
undertake a tiered appraisal of air quality to establish compliance with the
standards. Where the limits set out in the standards are likely to be exceeded, the
Local Authority must designate an Air Quality Management Area (AQMA) and
establish an Air Quality Action Plan (AQAP).
National Planning Policy Framework (NPPF)
13.8
Section 11 of the NPPF refers to the conservation and enhancement of the natural
environment and states policies should:
“…sustain compliance towards EU limit values or national objectives for pollutants,
taking into account the presence of Air Quality Management Areas and the
cumulative impacts on air quality from individual sites in local areas”
315
13.9
Planning decisions in an Air Quality Management Area will need to adhere to the
local air quality plan by ensuring that any new development does not produce
emissions which exceed local limits.
Local Planning Policy
13.10
The site to which this application relates includes land in the Thanet District Council
(TDC) and Dover District Council (DDC) administrative boundaries. TDC is in the
process of producing its Core Strategy; until this is adopted decision making will be
based on the saved policies from the adopted 2006 Local Plan. DCC Core Strategy
was adopted in February 2010 although there are no specific policies addressing air
quality.
Thanet District Adopted Local Plan 2006
13.11
Saved policy EP5 - Local Air Quality Monitoring states that:
“Proposals for new development that would result in the national air quality
objectives being exceeded will not be permitted….development proposals that
might lead to such exceedance…will require the submission of an air quality
assessment…”
13.12
Thanet District Council(TDC) began the review and assessment procedure of air
quality in 1998. TDC have undertaken three detailed assessments, declaring two
AQMAs in the process, for exceedances of the annual mean objective for NO 2 and
PM10. In 2011, both AQMAs were revoked and replace by a single Thanet Urban
AQMA.
13.13
The 2012 Air Quality Updating and Screening Assessment (USA), the most recent
available from TDC, considers monitoring data since the previous report in 2011.
The USA concluded that although there had been exceedances of the annual mean
objective of both NO2 and PM10, these were within the existing AQMA. Mitigation
measures to reduce concentrations were therefore included in the new Air Quality
Action Plan (AQAP).
13.14
TDC undertakes air quality monitoring within the area, operating four continuous
analysers and approximately 22 diffusion tubes in both background and roadside
locations.
The background monitoring locations are not considered to be
representative of the Proposed Development site.
Background pollutant
concentrations have therefore been obtained from Defra maps. There are no
representative roadside locations within the vicinity of the Proposed Development
and it is therefore not possible to undertake verification.
13.15
The site also lies on the boundary of Dover District Council (DDC). There are three
AQMAs located within the jurisdiction of DDC; however none of these are located
within the vicinity of site. DDC undertakes air quality monitoring within the area,
operating three continuous analysers and approximately 11 diffusion tubes. The
monitoring locations are not considered representative as they are not located
within the vicinity of the site.
Method
13.16
Nitrogen dioxide and oxides of nitrogen (NOX) gases are formed as a by-product of
temperature combustion of fossil fuels (such as petrol and diesel) by the oxidation
of nitrogen in the air. NOX primarily comprises nitrogen oxide(NO) and NO2. Once
316
emitted the former can be oxidised in the atmosphere to produce further NO2.NO2 is
associated with health impacts, which can affect lung function and airway
responsiveness and may also increase reactivity to natural allergens.
13.17
PM10, size fractions are defined as particulate matter with an aerodynamic diameter
of less than 10 microns (µm). The full extent of health impacts of fine particulate
matter is currently unclear. However research has found that exposure to increased
levels of matter is associated with respiratory and sustained cardiovascular illness
and mortality.
13.18
Dust is defined as all particulate matter up to 75μm in diameter as set out in BS
6069 and comprises both suspended and deposited dust.
13.19
The assessment of air quality effects arising from construction traffic includes 3
representative existing sensitive receptor locations referenced as ESR1 (Ebsfleet
House - 633657, 162412), ESR2 (16 Canterbury Road West – 634624, 165055)
and ESR3 (67 Sandwich Road – 634869, 164166) (see Appendix 11.2). NO2 and
PM10 concentrations at these sensitive receptors have been predicted for 1) a 2012
base year, 2) 2014 without the Proposed Development and 3) 2014 with the
Proposed Development.
13.20
The air quality significance criteria (taken from Environmental protection UK (EPUK)
document ‘Development Control: Planning for Air Quality’ relate only to NO2 and
PM10as these are the pollutants most likely to exceed the air quality objectives. The
EPUK document indicates that the concentration at the receptor locations should be
taken into account in combination with the magnitude of change. This approach is
appropriate for the assessment of annual mean concentrations of NO2 and
PM10where the objective concentration is 40μg/m3.
13.21
The assessment of potential effects arising from construction activities has referred
to experience of similar construction and cables installation projects.
Existing Environment
13.22
It has not been possible to undertake verification of the NO or PM10 concentrations
as there is no representative data available from a location close to the Proposed
Development. In the absence of such data, background concentrations for the 3
receptor locations have been obtained from the latest 2010 Defra Background Maps
which provide an estimate for PM10 concentrations of between 15.55 and
16.14μg/m3 and concentrations of NO2 of between 12.84 and 14.33μg/m3.
13.23
In the absence of monitoring data for dust deposition, it is assumed to be absent
from the local environment (this is a very conservative assessment because dust
deposition will be occurring naturally in the surrounding environment).
Prediction and Assessment of Significance of Potential Impacts
Construction Traffic
13.24
Pollutants associated with exhaust emissions from construction equipment and
vehicles have the potential to impact on local air quality during the construction
phase.
13.25
The full results of the potential air quality effects of construction traffic are shown at
Appendix 11.2.
317
13.26
The 2014 ‘with development’ annual mean NO2 concentrations (uncorrected) are
predicted to range between 16.14 to 23.67µg/m3 for the 3 existing sensitive receptor
locations modelled. Exceedance of the annual mean objective concentration for
NO2 (40µg/m3) is not predicted to occur.
13.27
The 2014 ‘with development’ annual mean PM10 concentrations (uncorrected) are
predicted to range between 16.70 to 17.99µg/m3 for the 3 existing sensitive receptor
locations modelled. Exceedance of the annual mean objective concentration for
PM10 (40µg/m3) is not predicted to occur.
13.28
All of the existing sensitive receptor locations are considered moderately sensitive.
When the magnitude of impact is considered along with the sensitivity of the
receptor, all existing receptor locations are predicted to experience a ‘negligible/not
significant’ impact as a result of the Proposed Development. Such effects will be of
a temporary nature during the construction phase of the proposed works only.
Dust
13.29
Dust also has the potential to affect local air quality during construction. The
potential for dust nuisance is most likely to arise from topsoil stripping and storage,
trench digging and storage of excavated subsoil, material transfers to and from
lorries and material spills during transportation and handling, particularly during
prolonged periods of dry weather.
13.30
Dust will be a short-term nuisance caused by the deposition of dust settling on
properties, vehicles, street furniture and nearby crops. Construction traffic leaving
the site may also bear dust and mud from the working areas which can be spread
as vehicles move along the local highway network, causing increases in dust and
debris along the adjacent roads.
13.31
The number of potential sensitive receptors has already been minimised by the
avoidance of urban areas and residential properties during the cable routeing
process. The laying of cables is relatively short-term and there are less than 10
properties within 100m of the cable route, converter station and substation site. For
these properties a negligible impact would be expected due to dust in the
construction phase.
Mitigation
13.32
The construction of the Proposed Development is a rolling process of site
preparation, excavation, cable installation and remediation over short periods of
time. To minimise potential impacts from dust and air quality emissions during
these periods, a range of mitigation measures will be considered and implemented
where appropriate. These include:



Restriction of site vehicle speeds. All vehicles will be required to adhere to site
speed limits which will be designed to minimise on site dust generation;
Limitation of vehicle movements during cables installation to the working width
wherever possible;
All plant equipment will be correctly adjusted and maintained to minimise
emissions;
318












Materials recycling will reduce the extent of off-site disposal and the use of
fresh materials, thus reducing the need to load, unload and transport potentially
dust gathering materials.
Minimisation of dust generation from the loading of trucks. The potential for
dust generation associated with the transfer of materials on to vehicles can be
controlled by the wetting of very fine or dry materials and the minimisation of
drop heights;
Covering lorries carrying potentially dust generating materials;
Where necessary, materials stored on site will be wetted, covered or profiled to
minimise dust generation by the wind. Storage areas will be sited away from
potentially sensitive receptors where practicable;
Stationary equipment with the potential for dust generation (such as soil sieving
equipment) will be sited away from sensitive receptors. Where dust generating
operations are near to sensitive receptors, enclosures will be provided if
appropriate;
Access roads and crossing points of highways along the route will be swept
periodically to remove dust from hard surfaces;
Unsurfaced working areas will be watered when necessary (such as during
prolonged periods of dry weather) to maintain moisture content and hence
reduce dust generation;
Vehicle wheel washes will be used at the site exits. Water from wheel washes
will be collected and appropriately disposed of.
Visual site inspections carried out by responsible staff to ensure that the buildup of materials with the potential to generate dust on site is prevented;
Prompt reinstatement of topsoil and vegetation upon completion of construction
to minimise risk of windblown dust;
Limited predetermined areas for construction workers parking, from which
workers will be transported to the active construction section; and
All plant will be switched off when not in use for long periods.
Residual Impacts
13.33
Following the implementation of mitigation measures, effects on air quality resulting
from construction traffic and dust generating activities will be negligible.
Cumulative Impacts
13.34
Potential cumulative effects on air quality from the onshore elements of the Nemo
Link in combination with other components of the Project (i.e. UK, French and
Belgian subsea cables and Belgian onshore infrastructure) are described in Chapter
16.
13.35
Potential cumulative effects of the Nemo Link UK onshore infrastructure in
combination with the grid connection required to facilitate the operation of the Nemo
Link are described in Chapter 17.
13.36
There is the potential for cumulative air quality effects to arise during the
construction phase of the proposed works due to the construction and operation of
other developments as detailed in Table 1.2.
13.37 The majority of the other unrelated developments are scheduled to have been
completed before site preparation works for the substation and converter station are
due to commence in late 2014. However, traffic levels are anticipated to be
relatively low for all developments for both construction and operation phases and
319
effects on air quality are anticipated to be minor. Where overlap of the construction
traffic associated with the onshore elements of the Nemo Link may occur with
construction and operation traffic associated with other projects, significant air
quality effects can be avoided through the implementation of industry standard
mitigation measures as detailed above.
13.38
All cumulative effects will be of a temporary nature during the construction phase of
the Proposed Development.
References

2012 Air Quality Updating and Screening Assessment: Dover District Council

http://www.dover.gov.uk/environment/environmental_health/air_quality.aspx

DEFRA. (January 2000, Addendum 2003 and 2007). The Air Quality Strategy
for England, Scotland, Wales and Northern Ireland. Working Together for Clean
Air

DEFRA. (2009). Local Air Quality Management Guidance LAQM.PG (09)

Dover District Council (2010) Core Strategy

National Planning Policy Framework (NPPF) Paragraph 124


Office of Public Sector Information (OPSI). (2010). The Air Quality Standards
(England) 2010 Regulations. Statutory Instrument No. 1001. London

Thanet District Council (no date) Core Strategy (online) Available at:
http://www.thanet.gov.uk/environment__planning
320
321
322
14.0
COASTAL TOURISM, RECREATION AND SOCIO-ECONOMICS
Introduction
14.1
This chapter presents a high-level appraisal of the potential effects arising from the
construction and operation of the Proposed Development (i.e. the UK onshore
elements of the Nemo Link Project: see Chapter 2 Project Description) on coastal
tourism, recreation and socio-economics. Mitigation measures that will be adopted
to avoid or reduce potential adverse effects are also described.
14.2
This assessment acknowledges that there is the potential for effects to arise on
coastal tourism and recreation due to part of the Proposed Development taking
place in areas of public open space used for tourism and leisure activities. These
effects would be temporary and short-term and were identified as not significant at
the Environmental Statement Scoping Stage.
14.3
The assessment also acknowledges that there would be a very small number of
permanent employment opportunities resulting from the Proposed Development
and that these are likely to be recruited from existing skilled persons in the
electricity industry. These effects were identified at the Scoping Stage as not
significant.
14.4
There would be a large number of construction jobs which would be temporary and
short-term. These will be valuable to the local economy and it is inherent in the
nature of the construction industry that each project comprises a temporary and
short-term opportunity. There will be secondary effects anticipated because of
accommodation and other services required by construction employees. These
would be positive and welcome contributions to the local economy. However these
benefits to the local economy will not endure beyond the construction of the
Proposed Development and at the Scoping Stage were identified as not significant.
14.5
The assessment undertaken is a high-level appraisal of anticipated effects to
demonstrate that the relevant issues have been considered.
Method
14.6
This assessment of potential effects draws on experience from the similar converter
station construction and cables installation project of the BritNed Interconnector
between the Isle of Grain, Kent and the Netherlands which was commissioned in
2011.
14.7
Effects were assessed by predicting changes in baseline conditions that would be
caused by the construction and operation of the proposed converter station and
substation site and the installation of the onshore underground cables.
14.8
Effects on communities arising from environmental aspects and activities including
landscape and views, traffic and transport, and noise are reported in other relevant
parts of the ES (Chapters 10, 11 and 12 respectively).
Existing Environment
14.9
Land use within the development area and surrounding area is described in
Chapter 5 - Land Use.
323
14.10
The main tourist destinations in Thanet District include the coastal towns of
Ramsgate, Broadstairs and Margate. Sandwich and Deal are important tourist
destinations in Dover District. Richborough Fort (see Chapter 9, Archaeology and
Cultural Heritage) is a Scheduled Monument promoted as a tourist attraction.
14.11
A number of recreational activities take place along the Thanet and Dover coast
including bathing, beach and water sports, sea angling, bird watching and
appreciation of the natural environment.
14.12
As described in Chapter 8 - Ecology, Pegwell Bay is subject to several conservation
designations and parts of the Sandwich Bay and Pegwell Bay National Nature
Reserve are accessible to the public. The main recreational activities at Pegwell
Bay include bird watching, bait digging at low tide and kite surfing at high tide.
Pegwell Bay also attracts visitors with a special interest in geology because of its
chalk cliffs.
14.13
Other activities in Pegwell Bay and Sandwich Bay include walking and dog walking
along the coast as well as cycling along the Viking Coastal Trail. Pegwell Bay
Country Park offers facilities including parking, refreshments, toilets and a picnic
area.
14.14
The subsea cables route between low water and the transition joint pit (TJP) is part
of the very large extent of Pegwell Bay and mainly comprises inter-tidal mudflats
and a small area of saltmarsh as shown on Figure 2.7. This is part of the area used
for bait-digging, walking and birdwatching although the opportunities it offers for
these activities are not distinguished from other very large areas of the Bay. The
Thanet Coastal Trail long distance footpath and the Viking Coastal Trail Sustrans
Route 15 runs through this area to the west of Pegwell Bay Country Park.
14.15
The TJP would be installed in an area of poor quality saltmarsh close to the Pegwell
Bay Service Station. This area is used for casual access to the inter-tidal area and
(as for the subsea cables route above) is not materially distinguished from other
adjacent areas which offer this access.
14.16
The onshore underground cables route between the TJP and the stile entrance to
Pegwell Bay Country Park includes a strip of land used for casual access along
desire line footpaths on the shore side of the tarmacadam surfaced footpath and
cycleway. This strip of land is used by pedestrians including dog walkers as an
alternative to sharing the relatively narrow footpath and cycleway with cyclists.
14.17
In Pegwell Bay Country Park, through which the proposed cable routes run, there
are footpaths separate from the footpath and cycleway which allow pedestrians
(including those with dogs and children) to be sufficiently remote from cyclists, risk
of collision is very low. Along the footpath and cycleway between the Country Park
and Pegwell Bay Service Station, the single shared path gives a perception of risk
of collision which means that pedestrians have created a ‘desire line’ path on the
lower land to the shore side of the footpath and cycleway. This is used by walkers
although it has led to degradation of vegetation in this area.
14.18
Pegwell Bay Country Park has a car park, toilets and refreshments facilities. It is
used for walking and casual recreation and as the ‘base’ for walks in the wider area
along the shoreline and beach. The footpath and cycleway runs through the Park,
parallel with the A256 Sandwich Road although separated from it by planting which
screens users from some of the views and some of the traffic noise from the road.
324
There are a number of footpaths in the Country Park offering pedestrians walking
routes separate from the cycleway.
14.19
The onshore underground cables route runs through Stonelees Nature Reserve
which is used by those on the footpath and cycleway. This route runs through the
majority of the site parallel to the A256 before turning to run directly alongside the
road opposite Ebbsfleet Lane. Walkers and visitors use the Stonelees Nature
Reserve site for appreciation of nature including bird watching.
14.20
The onshore underground cables route passes through part of the BayPoint sports
complex which has playing fields, tennis courts a bowling green and buildings
including changing rooms and a social club. The cables route passes through an
area presently used as a football pitch.
14.21
The onshore underground cables will be installed by horizontal directional drilling
from the BayPoint sports complex to the converter station site. The land above
which the onshore cables will pass is not publicly accessible beyond the A256 and
has no role in tourism or recreation. This land is not included in the assessment of
potential effects on coastal tourism and recreation.
14.22
The converter station and substation site is a private site to which there is no public
access. It has no coastal tourism or recreation functions and is not included in the
assessment of potential effects on coastal tourism and recreation. The former
Richborough power station site (and the surrounding area) is allocated in the Kent
Waste Local Plan as suitable in principle for waste uses.
14.23
The visual effects of the development of the former Richborough Power Station site
have been addressed in Chapter 10 - Landscape and Views.
Prediction and Assessment of Potential Impacts
Coastal Tourism and Recreation
Construction
14.24
During the installation of the subsea cables there will be restricted access to a small
area of the mudflats and salt marsh area. Activities such as bait digging, walking
and bird watching in this area will be restricted for the duration of cable installation
works which is anticipated to be approximately 4 weeks, although the wider area of
the bay provides undisturbed opportunities.
14.25
Between the intertidal area and TJP is the main area that will be impeded during
construction. The onshore underground cables route will be installed close to the
route of the Thanet Coastal Trail and the Viking Coastal Trail. There will be clearly
signed temporary diversions in place to ensure the cycle route remains open
throughout the duration of the installation works. The cycleway diversion will be
diverted onto the A256 Sandwich Road with robust ‘Heras’ fencing or similar
delineating the cycle route. Temporary traffic management will be installed at each
end of the diversion with cyclists separated from motor vehicle traffic. Further
information on Traffic and Transport is presented in Chapter 11. Disruption could
be significant between the TJP and the stile into Pegwell Bay Country Park if not
appropriately mitigated. However, access from adjacent areas to the Country Park
will be possible throughout the duration of the works.
325
14.26
The construction works to install the cables are similar to those carried out by any
utility company in its day-to-day business and would be of short duration
(approximately 12 weeks) and limited in geographic effect. The proposals are
unlikely to have the potential to adversely affect coastal tourism or recreation due to
their temporary nature.
14.27
Disruption to traffic may also be experienced during the installation of onshore
underground cables. These effects are discussed in detail in Chapter 11 - Traffic
and Transport.
14.28
There will be temporary disruption to users of the BayPoint sports complex facilities
during installation of the onshore underground cables which will have an adverse
effect for users of the BayPoint sports complex. The duration of construction works
at the Sports Ground is expected to be approximately 2 weeks.
Operation
14.29
The siting of the proposed converter station and substation on the former
Richborough power station site has the potential to result in adverse effects on
tourism and recreation during its operation, largely due to any effect the presence of
relatively large scale infrastructure may have on the attractiveness of the area for
locals and visitors.
14.30
However, the previous occupation of the site by the former power station (a
prominent and well-known structure of which the cooling towers were only recently
demolished in March 2012) together with the wider proposals to develop the site as
the Richborough Energy Park has established the site and the surrounding area for
such industrial uses both historically and for the foreseeable future. In addition, the
presence of other similar industrial infrastructure in the surrounding area currently
under construction or awaiting planning permission has further established the area
for such industrial uses. There will be no permanent direct effects on recreation
areas. Therefore, potential adverse effects on tourism and recreation are
considered unlikely to occur.
Economic Activity
14.31
The potential beneficial impacts from the construction of the Proposed Development
will depend largely on the location of prefabrication activities and resourcing of a
skilled workforce. Awards of contracts for construction and cables supply and
installation will be subject to competitive tendering under the European procurement
legislation, following receipt of the required consents and approvals.
Construction
14.32
Construction works on the converter station and substation will fall into two broad
categories: civil engineering; and technical works of fit-out, equipment installation
and commissioning.
14.33
Civil engineering works for the converter station and substation such as site
levelling, construction of foundations and main engineering structures are likely to
be sourced by the main contractor via sub-contracts with suppliers within the local
area or sub-region because the skills required are those generally available within
the construction industry. An important consideration will be cost-effective supply
and it is likely that locally sourced materials and labour will be most cost-effective.
326
In this phase of the work there is likely to be the greatest direct effect from
employment within the sub-region comprising likely ‘travel-to-work’ area.
14.34
Staff employed will use local goods and services during the construction period
which will be provided by local businesses, catering or hotel facilities. The
purchase of materials, equipment and services during the construction phase may
have a minor beneficial effect on the creation of temporary and permanent jobs
locally and nationally within the supply chain.
14.35
During technical fit-out, installation and commissioning of the converter station and
substation, there are likely to be relatively few opportunities for local construction
staff because the work is highly skilled and the persons involved would travel long
distances, within the UK and from elsewhere, to apply specialist skills and
experience to tasks. In this phase of work there is likely to be relatively low direct
effect on employment from the local area but there would remain positive effects
from indirect activity including accommodation and services for workers, particularly
those staying locally who live elsewhere.
Operation
14.36
The converter station is likely to operate with approximately 6 personnel per day
divided between 3 shifts over a 24 hour period. The substation will operate
unmanned with only occasional inspection and maintenance required. Converter
station and substation staff are skilled workers and are likely to be recruited from
existing workers in the electricity industry which will assist job retention.
14.37
On completion of cables installation, the present land uses above the cables will
resume as previously, with the exception of a restriction on planting trees along the
cable route.
14.38
The former Richborough power station site is allocated in the Kent Waste Local
Plan as suitable in principle for waste uses whilst the Proposed Development
consists of sui generis energy-related infrastructure. However, as detailed in
Chapter 4 of this ES (Planning Context) and the Planning Statement, the site is not
exclusively reserved for waste–related development and due to the similarity of the
Proposed Development to waste uses in terms of type and scale, is not considered
to cause substantial harm to such waste allocations. Therefore significant adverse
effects on economic activity are not anticipated.
Mitigation
14.39
During installation of the onshore underground cables, access to the Viking Trail
and Thanet Coastal Path will be retained. Where there is a Health and Safety
requirement to prevent or reduce access, appropriately signed diversions will be put
in place. Any restriction on access will be minimised and limited only to periods of
major construction activity such as earthworks.
14.40
Temporary signage advising visitors of construction activities will be erected. This
will include signs within the car park of Pegwell Bay Country Park to ensure that
visitors are aware of construction activities being undertaken.
14.41
To minimise construction disturbance, working hours during periods where
recreational activity is greatest (i.e. evenings and weekends), will be limited as
much as possible.
327
14.42
All land take associated with cables installation will be reinstated following
completion of cable laying activities so will not adversely affect future recreational
land use.
14.43
Creation of chalk grassland habitat within Pegwell Bay Country Park will enhance
botanical biodiversity and increase the wildlife amenity for visitors.
14.44
During the works at the BayPoint sports complex, it may be possible to re-orientate
affected sports pitches that would be affected by the works so that use is not
impeded. Works will take place as quickly as possible and reinstatement will be to
a high standard. If appropriate, the applicant would fund the use of an alternative
available pitch during the works to allow team fixtures to be fulfilled.
Residual Impacts
14.45
With the implementation of mitigation measures, there will be no significant adverse
effects on tourism, recreation and socio-economic. The Proposed Development will
bring benefits to the area during construction through some direct employment and
through use of local businesses.
Cumulative Impacts
14.46
Potential cumulative effects on coastal tourism, recreation and socio-economics
from the onshore elements of the Nemo Link in combination with other components
of the Project (i.e. UK, French and Belgian subsea cables and Belgian onshore
infrastructure) are described in Chapter 16.
14.47
Potential cumulative effects of the Nemo Link UK onshore infrastructure in
combination with the grid connection required to facilitate the operation of the Nemo
Link are described in Chapter 17.
14.48
There is little scope for cumulative effects on coastal tourism, recreation and socioeconomics arising from the UK onshore elements of the Nemo Link in combination
with unrelated planned developments described in Table 1.2, Chapter 1.
14.49
The construction phases of all other projects are anticipated to be complete before
the proposed onshore elements of the Nemo Link are scheduled to commence
construction. Continued cumulative construction effects from all developments i.e.
construction duration effects for individual projects following on from one another
increasing the overall estimated duration of generic construction works in general
has been considered. Although there are likely to be effects associated with
general disturbance and associated recreation (namely through the use of Public
Rights of Way), such cumulative effects are not anticipated to be significant due to
the projects being located in different geographic locations and their temporary
nature during construction.
14.50
During operation, cumulative effects on costal tourism and recreation are not
anticipated to arise. The site and the surrounding area (which includes other
unrelated developments detailed at Table 1.2) is a well-established industrial area
consisting of the former power station, a previously dominant and well-known
structure of which the cooling towers were recently demolished in 2012. No direct
effects on recreation areas are anticipated from any of the unrelated developments
together with the Proposed Development.
328
14.51
During operation, cumulative effects on economic activity are not anticipated to
arise. The presence of other industrial uses, some of which are also on land
allocated as suitable in principle for waste uses is not expected to be detrimental to
such waste policies; indeed some of the unrelated developments detailed at Table
1.2 are for waste uses and as such will likely result in a beneficial economic impact
in accordance with local planning policy
14.52
The presence of the proposed onshore elements of the Nemo Link together with
other unrelated development as detailed in Table 1.2 is not anticipated to result in
any significant cumulative effects on coastal tourism, recreation and socioeconomics during construction or operation.
329
330
15.0
ELECTRIC AND MAGNETIC FIELDS (EMF) AND
ELECTROMAGNETIC COMPATIBILITY (EMC)
Introduction
15.1
This assessment considers electric and magnetic fields (EMFs) produced by the
Proposed Development which consists of a converter station and onshore high
voltage direct current (HVDC) bipole cables and a 400kV alternating current (AC)
substation. This development forms the onshore elements of the Nemo Link
Project – see Chapter 2 (Project Description). The new 400kV substation will be a
gas insulated switchgear (GIS) design, with associated reactive compensation
equipment. The converter station will be voltage source converter (VSC) technology
and operate using both direct current (DC) and AC frequencies. The HVDC cables
will operate in a bipole arrangement at 400kV carrying 1000 Megawatts (MW) of
power.
15.2
All equipment that generates, distributes or uses electricity produces EMFs. The
power frequency of alternating current equipment in the UK is 50 Hz, and AC
equipment will produce electric and magnetic fields with a principal frequency of
50Hz. These EMFs are known as Extremely Low Frequency (ELF) EMFs. DC
equipment produces steady state electric and magnetic fields and these are
referred to as static fields.
15.3
All static and alternating fields can have different effects, but in both cases, there
are exposure limits set by independent organisations, designed to prevent all
established effects of EMFs on people.
15.4
The Nemo Link uses both AC and DC technology, so both static and alternating
electric and magnetic fields will be produced. The effects are discussed in this
chapter.
15.5
The electric and magnetic fields produced by transmission assets may potentially
interfere with other electronic or electrical products in close proximity, such as
pacemakers and visual display units. These potential electro magnetic compatibility
(EMC) issues, or indirect effects, are discussed in relation to the Proposed
Development.
Electric Fields
15.6
Electric fields depend on the operating voltage of the equipment producing them.
They are measured in V/m (volts per metre). The operating voltage of the
equipment is a relatively constant value. Electric fields are shielded by most
common building materials, trees and fences. Electric fields diminish rapidly with
distance from the source.
15.7
As a consequence of their design, some types of equipment do not produce an
external electric field. This applies to underground cables (both AC and DC) and
gas insulated switchgear (GIS), which are enclosed in a metal sheath (a protective
metal layer within the cable) and have solid metal enclosures respectively. This
equipment will be used for the Nemo Interconnector.
331
15.8
The converter station may have some bare conductors in the central portion of the
site. These will produce an electric field which drops quickly with distance. The
palisade security fencing and buildings, however, will screen the electric field at the
boundary of the site. These types of bare conductors have been demonstrated to
be inherently compliant with exposure guideline. Evidence for this is maintained at
http://www.energynetworks.org/electricity/she/emfs.html. As such, electric fields
have not been considered further in the assessment.
Magnetic Fields
15.9
Magnetic fields depend on the electrical currents flowing and these vary according
to the electrical power requirement at any given time. Magnetic fields are measured
in µT (microteslas). They are not significantly shielded by most common building
materials or trees but they diminish rapidly with distance from the source.
15.10
AC magnetic fields arising from electric cabling and equipment are found in all
areas where electricity is in use (e.g. in offices and homes). In UK houses, typical
AC magnetic fields will be in the range of 0.01 – 0.2 µT, with higher values in
localised areas close to electrical appliances.
15.11
The earth also produces its own DC magnetic field, which in the UK is around 48
µT, but this can vary due to geomagnetic material such as rocks.
Legislation and Policy Guidance
15.12
There are no statutory limits on EMFs in the UK. It is the responsibility of the Health
Protection Agency (HPA) to recommend guidelines for exposure to EMFs. In 2004
it recommended that the UK adopt the 1998 guidelines from the International
Commission on Non-Ionizing Radiation Protection (ICNIRP, 1998) which cover 50
Hz frequencies. The Government accepted this recommendation, stating that the
guidelines should be applied in the terms of EU Recommendation 1999/519/EC.
The EU recommendation also includes guidance on static field exposure limits,
taken from ICNIRP’s guidance on static magnetic fields (1994). These are the
guidelines that currently apply in the UK.
15.13
The 50 Hz guidelines and their application are explained in the Code of Practice,
‘Power Lines: Demonstrating compliance with EMF public exposure guidelines – a
voluntary Code of Practice’ (DECC, 2011c) published by the Department of Energy
and Climate Change (DECC). It is the electricity industry’s policy to comply with
Government guidelines on EMF, and this Code of Practice forms an integral part of
this policy. This application does not include new overhead lines. However, this
assessment has been performed in line with the principles of the Code of Practice.
This Code of Practice covers 50 Hz fields specifically, but the overall principles of
demonstrating compliance have been applied to the DC assessment also, using the
appropriate exposure limits.
15.14
There is also a second Code of Practice, Optimum Phasing of high voltage doublecircuit Power Lines (DECC, 2011d), which sets out the principles for optimum
phasing of overhead lines. The application is not proposing a new overhead line,
so an assessment against the optimum phasing code of practice is not required.
332
15.15
There has been extensive research to establish whether or not long term exposure
to fields at lower levels than the ICNIRP guidelines might be a cause of ill health in
humans, and this research has been extensively reviewed by bodies such as the
HPA and the World Health Organization (WHO). There is some evidence to
suggest that high magnetic fields may be associated with an increased risk of one
particular disease, childhood leukaemia. However, the weight of scientific evidence
is against electric and magnetic fields causing ill health in humans at levels below
the ICNIRP guideline limits. The government has addressed this uncertainty by
adopting precautionary measures set out in the Code of Practice ‘Optimum
Phasing of high voltage double-circuit Power Lines’ (DECC, 2011d), which the
electricity industry follows, where appropriate.
15.16
The evidence that leads to some health concerns about EMFs from electric power
systems is specific to AC fields, at 50 Hz, and does not apply to DC fields. The fact
that humans have evolved in the Earth’s DC magnetic field makes it unlikely that
there are any adverse health effects from any sources of fields at levels below the
guideline limits.
15.17
The policies followed in this chapter result from a comprehensive risk assessment
performed at a National Level. The Codes of Practice (DECC, 2011c, d) effectively
represent the conclusions of a health impact assessment conducted nationally and
applied generically to all power lines, cables and substations.
Method
Study Area
15.18
The assessment included all areas where the magnetic fields could potentially
extend from the electrical assets proposed by the Project. Extensive operational
experience has shown that equipment operating at this voltage and rating will not
produce magnetic fields greater than background levels at distances of more than
100m. 100m corridors around the substation, converter station and HVDC cables
were defined as an appropriate assessment area.
15.19
All magnetic fields were calculated at 1m above ground level as set out in the Code
of Practice (DECC, 2011c).
15.20
As external electric fields are not produced by equipment enclosed in metal sheaths
or which have solid metal enclosures, the assessment does not consider electric
fields from the GIS substation, fenced converter station, HVDC cables or bare
conductors within the substation due to the reasons set out in section 15.7.
Assessment of Significance
15.21
The assessment considers magnetic fields produced by the proposed 400 kV GIS
substation and associated reactive equipment, the HVDC converter station and the
onshore HVDC cables. The final asset configuration and manufacturer for the
substation and converter station equipment are not finalised, so the worst case
assumption in terms of magnetic field exposure has been considered for this
assessment.
15.22
Magnetic fields have been assessed as per the conditions set out in the Code of
Practice (DECC, 2011c) and compared with UK Government exposure guideline
levels. The onshore underground HVDC cables are a bipole design with a
maximum cable rating of 1000 MW. The cables will be installed onshore in three
333
distinct ways along the length of the route and each of these configurations has
been considered separately. These are:



Trough installation - Cables buried at 1m depth with cables 500mm apart;
Surface laid with capping - Cables will be a minimum of 1m from the closest
possible point, and installed with 500mm cable centres. Capping will include a
1:5 sloped approach meaning that the effective worst case will be standing
directly on top of the cables, In magnetic field terms this assessment is the
same as for the trough installation;
Horizontal directional drilling (HDD) - Cables will be installed at 2.5m apart, and
the depth will vary between approximately 1.2m and 10m. The worst and best
case depths of 1.2m and 10m were used for the calculations giving the
potential range of exposures.
15.23
The 1998 ICNIRP guidelines are based on the avoidance of known adverse effects
of exposure to EMF at frequencies up to 300 GHz, which includes the 50 Hz EMF
associated with electricity transmission. This equates to public exposure limit for
uniform AC magnetic fields exposure of 360 µT (DECC, 2011c).
15.24
For static magnetic fields, the recommended exposure limit used in the EU
recommendation is 40 000 µT (40 millitesla). However ICNIRP’s 1994 guidance
(ICNIRP, 1994) states that there are potential indirect effects, such as injuries due
to flying ferromagnetic objects and potential interactions with implantable medical
devices which could occur at the levels below the exposure limits. Therefore a lower
restriction of 500 µT should be considered where indirect effects may be an issue.
The assessment would demonstrate a significant impact if non-compliance with the
EMF exposure limits was demonstrated using the principles set of in Codes of
Practice ‘Power Lines: Demonstrating compliance with EMF public exposure
guidelines – a voluntary Code of Practice’ (DECC, 2011c).
Assessment of Significance of Potential Impacts
Alternating Current 400kV Substation
15.25
The proposed substation is a 400kV GIS design with associated air-cored reactive
equipment.
15.26
Due to its design, GIS equipment does not produce an external electric field,
therefore electric fields were not considered further.
15.27
It has been reported that magnetic fields produced by GIS are 20 to 60 % smaller
than those of an equivalent air insulated design (Electric Power Research Institute,
1999). The metallic grounded GIS enclosures carry currents that oppose those of
the high voltage conductors inside, so offer a degree of cancellation.
15.28
As part of the Code of Practice (DECC, 2011c), the Energy Networks Association
maintains a list of types of equipment where the design is such that it is not capable
of exceeding the ICNIRP exposure guidelines, i.e. a list of equipment that is
therefore compliant with the guidelines. GIS substations without reactive equipment
are deemed compliant with the exposure limits. Evidence for the demonstration of
compliance
with
exposure
guidelines
is
maintained
at
http://www.energynetworks.org/electricity/she/emfs.html.
334
15.29
The new GIS components of the substations will not result in a measurable change
in the background magnetic field (see above) at the nearest residential properties
located over 100m away. This is due to the rate at which magnetic fields reduce
with
distance
from
electrical
transmission
assets
(see
http://www.energynetworks.org/electricity/she/emfs.html for evidence).
15.30
At this stage the detailed configuration for the air-cored equipment cannot be
confirmed until a supplier has been contracted and therefore a full assessment for
the reactors cannot be performed. However, the configuration of this equipment
during project implementation will ensure that the ICNIRP public exposure limit is
not exceeded at the perimeter of the substation.
Converter Station
15.31
The proposed converter station will be VSC technology. Until a manufacturer for the
equipment has been appointed and the detailed configuration for the equipment
confirmed a full assessment cannot be performed. However, specific EMF design
criteria will be incorporated into the proposed converter station’s technical
specification to ensure that the finalised design is compliant with public exposure
limits at and beyond the converter station boundary. These specifications will
ensure the following criteria are employed in the design:

Static magnetic fields at the boundary fence of the proposed converter station
site will not exceed the ICNIRP public exposure limits defined above; and
AC magnetic fields at the boundary fence of the proposed converter station site
shall not exceed the general public exposure limit defined above.

High Voltage Direct Current Cables
15.32
The onshore underground HVDC cables will be installed using three separate
techniques described in section 15.22. As the cables operate as a bipole system,
the current in each cable runs in opposition leading to a significant cancellation of
the magnetic field. The magnetic field for each design has been calculated at 1m
above ground using the maximum current rating of the cable. Table 15.1 and Table
15.2 show the calculated magnetic field in the 3 different cable installations,
including the maximum field and the field at perpendicular distances from the centre
of the cables. All of the calculations are independent of the Earth’s geomagnetic
field.
Table 15.1: Calculated Magnetic fields for Trough and Surface Installed HVDC
Cables
Calculated DC Magnetic Field 1 m above Ground
Cable Burial
Depth
Maximum
Calculated
Field
10m from
Centre of
Cables
50m from
Centre of
Cables
100m from
Centre of
Cables
1m
17.7 µT
1.47 µT
0.06 µT
0.02 µT
335
Table 15.2: Calculated Magnetic Fields for Horizontal Directional Drilling
(HDD) Installed HVDC Cables
Calculated DC Magnetic Field 1 m above Ground
Cable burial
depth
Maximum
Calculated
field
10m from
Centre of
Cables
50m from
Centre of
Cables
100m from
Centre of
Cables
1.2 m
67.8 µT
7.34 µT
0.32 µT
0.08 µT
10.0 m
5.50 µT
3.27 µT
0.30 µT
0.08 µT
15.33
The calculations of magnetic fields demonstrate that the highest field produced by
the onshore HVDC cables would be 67.8 µT when the cables are installed via HDD
and at the minimum depth of 1.2m. At a burial depth of 10m, the maximum
calculated magnetic field would be 5.5 µT. The closest residential property to the
HDD installation is 80m away where the magnetic field is calculated to be 0.13 µT.
All calculations were performed in accordance with the conditions set out in the
Code of Practice (DECC, 2011c); using the maximum rating of the cables at 1 m
above ground and ignoring harmonics.
15.34
The calculated magnetic fields for all installation methods are all below the
precautionary level of 500 µT for static fields and are therefore compliant with
exposure limits and present no indirect effects.
Indirect Effects including EMC
15.35
Magnetic fields can affect Active Implantable Medical Devices (AIMDs), such as
pacemakers, insulin pumps and defibrillators if the field strength exceeds the
immunity of the device. All modern AIMDs should operate unaffected in field levels
below the General Public Reference Levels (100 µT at 50 Hz) of 1999/519/EC and
500 µT static fields, where the AIMD has been implanted and programmed in a
standard manner.
15.36
EU directive 90/385/EEC states that ‘Devices must be designed and manufactured
in such a way as to remove or minimise as far a possible…risks connected with
reasonably foreseeable environmental conditions such as magnetic fields, external
electrical influences …’
15.37
The maximum magnetic fields in a public area will be below 500 µT for static fields
and the ICNIRP public exposure reference levels for 50 Hz will not be exceeded in
areas where the public would frequent. Therefore, no interference with Active
Implantable Medical Devices is expected. The Department of Energy and Climate
Change (DECC) document National Policy statement for electricity infrastructure
(EN-5, DECC, 2011b) states that “The Department of Health’s Medicines and
Healthcare Products Regulatory Agency (MHRA) does not consider that
transmission line EMFs constitute a significant hazard to the operation of
pacemakers”.
15.38
One potential EMC issue arising from magnetic fields is the potential distortion of
images on Cathode Ray Tube Visual Display Units (VDU) screens although these
are less commonly used with modern television and computer equipment. The
distortion to Cathode Ray Tube VDUs may occur, depending on the design and
336
orientation, in magnetic fields greater than 0.5µT. Liquid Crystal Displays (LCD)
and plasma VDUs are immune to this interference. It is unlikely that VDU
interference will occur, given the distance to the nearest business premises and
properties.
Mitigation
15.39
No mitigation is required for the proposed substation, converter station or cables as
the assessment has demonstrated EMFs are within UK Government guideline
levels.
15.40
If VDU interference is reported, it will be investigated and remedied if found to be
due to the project.
15.41
There is potential for induction effects to arise on other metallic infrastructure from
the magnetic fields of underground electricity cables. In the case of the HVDC
onshore underground cables, there will be relatively weak magnetic fields and low
probability of such effects arising. Where there are other installations such as
cables and pipes which may run near or be crossed by the onshore underground
cables, the Nemo Link developers will liaise with the owners and operators of these
services to ensure that no adverse effects arise. This liaison and subsequent
mitigation of potential effects by separation or other measures is standard practice
for utility installations.
Cumulative Impacts
15.42
Potential cumulative effects of EMF produced from the onshore elements of the
Nemo Link in combination with other components of the Project (i.e. UK, French
and Belgian subsea cables and Belgian onshore infrastructure) are described in
Chapter 16.
15.43
Potential cumulative effects of the Nemo Link UK onshore infrastructure in
combination with the grid connection required to facilitate the operation of the Nemo
Link are described in Chapter 17.
15.44
In relation to potential cumulative effects from unrelated planned developments
described in Table 1.2, Chapter 1, fields produced from the onshore infrastructure
will combine with the fields already present in the area from other sources, which
will vary with time depending on electricity usage. The way in which the fields
combine with each other is complex; however, in this situation, where all the fields
are well below guideline levels, it is not necessary to assess this in more detail as
the combined field will also be well below guideline levels.
Conclusion
15.45
The new 400kV GIS substation and converter station will be designed to ensure
that both are compliant with ICNIRP public exposure guidelines for EMFs. The
proposed substation’s GIS design already meets the Government adopted
exposure limits demonstrated using the DECC code of practice. With all three
installation techniques, it has been demonstrated that the HVDC cables would be
compliant with exposure limits so there will be no significant EMF effects resulting
from the Nemo Link. There is some scientific evidence of possible effects at lower
levels, and the electricity industry takes this evidence seriously and recognises that
it can generate public concern however the evidence has been extensively
337
reviewed, and the UK Government have not considered it appropriate to implement
any restrictions or guidelines on the basis of this evidence.
EMF Advice
15.46
National Grid takes the concerns of the public seriously, and operates a team of
EMF Advisers to answer questions and address any concerns. The EMF Unit can
be contacted on 0845 702 3270. Members of the public can speak to an EMF
adviser directly on this number, and if necessary a home visit can be arranged to
discuss queries and take measurements of electric and magnetic fields. The
company also maintains a website with further information on all aspects of EMFs:
www.emfs.info
References

International Commission on Non Ionising Radiation Protection (1998)
Guidelines for Limiting Exposure to Time-Varying Electric, Magnetic and
Electromagnetic Fields, Health Physics

EU Council (1999) Recommendation of 12 July 1999 on the limitation of
exposure of the general public to electromagnetic fields (0 Hz to 300 GHz)
(1999/519/EC)

International Commission on Non Ionising Radiation Protection (1994)
Guidelines on limits of exposure to static magnetic fields, Health Physics

Department of Energy and Climate Change (2011c) Power Lines:
Demonstrating compliance with EMF public exposure guidelines. A voluntary
Code of Practice

Department of Energy and Climate Change (2011d) Optimum Phasing of high
voltage double-circuit Power Lines. A voluntary Code of Practice

Electric Power Research Institute (1999) Electric and magnetic fields
management reference report TR-114200, 1st Edition

Department of Energy and Climate Change (2011b) NPS for Electricity
Network Infrastructure (EN-5)
338
339
340
16.0
PROJECT-WIDE ASSESSMENT OF EFFECTS
Introduction
16.1
The Proposed Development for which planning permission is being sought forms
part of a wider project known as the Nemo Link. The elements of the Project that fall
outside the jurisdiction of the local planning authorities in Kent comprise high
voltage direct current (HVDC) subsea cables passing through UK, French and
Belgian waters, and onshore infrastructure in Zeebrugge, Belgium consisting of a
converter station, substation and onshore cables (see Figure 1.1 and Chapter 2
Project Description).
16.2
Applications for consent for the other elements of the Project are being submitted to
the relevant national authorities and each element has been subject to
environmental assessment.
Non-technical summaries of the environmental
assessment documents for the other elements of the Project are appended to this
ES (see Appendix 16.1. Please note the NTS documents for the marine cable in
French waters is currently in the original language; a translation will be made
available on the project website). The full environmental assessment documents
for
all
elements
of
the
Project
can
be
viewed
at
http://www.nationalgrid.com/uk/Interconnectors/Belgium/Nemo+interconnect
or/index.htm
16.3
This chapter summarises, for all technical areas, the likely significant effects that
may arise from the construction and operation of these other components of the
Nemo Link. This chapter also considers potential cumulative effects which may
arise from construction and operation activities of the Proposed Development with
any other element of the Nemo Link detailed above.
Assessment of Potential Environmental Effects
UK Subsea Cable
16.4
A summary of the effects of the UK subsea cable on the physical, biological and
human environment is provided below.
Physical Environment
16.5
The EIA considered impacts on geology, bathymetry & seabed processes and
water quality with the conclusion that installation of the subsea cable would have no
significant impacts.
16.6
The key sensitive and important geological area identified in the Sandwich Bay to
Hacklinge Marshes Site of Special Scientific Interest (SSSI) will be avoided and
therefore effects on geology are considered minor. Any effects of construction on
bathymetry and water quality are also minor and not significant as the seabed will
recover quickly with no long term effects predicted.
Biological Environment
16.7
There are several conservation sites of importance within the subsea cable
installation area, including Thanet Coast and Sandwich SPA, Sandwich Bay SAC,
Thanet Coast SAC and the Thanet Coast and Sandwich Bay Ramsar Site. Effects
on these designated sites and ornithology have been limited by routing the subsea
341
cable to avoid areas of greatest sensitivity. Effects will be further reduced by
avoiding installation works within the intertidal areas during periods of greatest
sensitivity to birds.
16.8
To avoid disturbance of areas of Ross worm Sabellariaspinulosa, the subsea cable
has been routed away from Sabellariaspinulosa aggregations at distances agreed
by Natural England.
16.9
Rock replacement at cable crossings will be limited so as to avoid substrate change
however, where rock placement is necessary it is likely to have a beneficial effect
on the local abundance and diversity of fish species.
16.10
Herring spawning areas may be moderately affected by subsea cable installation
works however, as herring only spawn upon gravel seabed sediments for three
months of the year, the key spawning period (November to January) will be
avoided.
16.11
The subsea cable will not result in any significant effects on marine mammals.
Human Environment
16.12
A 500m by 1000m safety zone will be established around installation vessels and
the spread will be assigned two guard vessels to reduce any effects on shipping
and navigation.
16.13
Vessels will comply with Collision Regulations lighting and marking requirements.
There is potential for moderate impacts/risks upon shipping and navigation from
vessel anchors snagging the subsea cable. The subsea cable will be adequately
buried and the location of the cable will be marked on navigational charts.
16.14
All known wrecks have been avoided by the subsea cable route. Limited prehistoric
material of interest has been identified. Where practicable temporary exclusion
zones will be placed around important geophysical anomalies during construction
and buffers with a radius of 100m will be placed around wrecks of archaeological
potential. An archaeological reporting protocol will ensure that any material
discovered during construction will be reported, recorded, stabilised and conserved.
16.15
During subsea cable installation, a Fisheries Liaison Officer will be employed to
ensure that interactions between cable installation vessels, personnel and
equipment and fishing activity are appropriately managed.
16.16
Effects on commercial fishing may occur from the use of rock placement that
prevents the use of fishing gear at the seabed. Rock placement will be required at
one crossing in the UK therefore the effect will be localised.
16.17
The subsea cable installation is not expected to have any impacts on
socioeconomics offshore beyond those discussed in relation to commercial
fisheries, recreation and tourism and other sea users.
16.18
There will be some temporary, site specific disturbance to recreation and leisure
activities such as sailing, kite surfing and bird watching. There will also be some
temporary, local impacts upon the natural character and visual amenity of the
landfall area due to the presence of installation vessels and equipment.
342
French Subsea Cable
Physical Environment
16.19
In France, the cable route crosses the borders of two of the sandbanks forming part
of the area known as ‘Bancs des Flandres’. The sandbanks are composed of fine
and gravelly sand, similar to that found in the Belgian and UK sections of the cable
route. Although the cable route only crosses the borders of the sandbanks, the
changes in the seabed processes could influence the movement of sediments
around the borders or on the summits of the sandbanks. However, the terrain will
quickly return to its natural state once cable laying activities are completed.
Consequently there will be no long term change to the topography of the seabed.
Biological Environment
16.20
In France it is recognised that the diversity of fish species is greater towards the
south of the North Sea than in the central areas. The species found along the cable
route are a heterogeneous coastal mix and it is difficult to identify with precision the
exact species that could be impacted by the cable.
16.21
The effect on benthic organisms, one of the main food sources for the fish
population, will be temporary, with the area quickly being recolonised post-cable lay
by the surrounding communities. The cable route also avoids the most sensitive of
the fish feeding and breeding areas as well as the zones frequented by protected
marine mammals.
16.22
The cable route passes to the north of the protected Natura 2000 zone of the
‘Bancs des Flandres’. This is designated an area of importance by Directive 79/409
as a bird feeding zone, a passage of migration and an area of hibernation. The
vessels linked to both installation and operation should not however have any more
impact on the migration or feeding habits of birds than the vessels routinely using
this area.
16.23
With regard to the Habitats Directive, the impacts on the flora and fauna will be
temporary and localised. No protected marine mammal species frequent the
sandbanks of this area.
Human Environment
16.24
In France the cable route crosses an important navigational channel used to
separate the vessels entering and leaving the Belgian ports. The impacts on
shipping traffic are linked to the presence of cable laying vessels which have
restricted capacity for manoeuvre and travel at low speeds crossing the path of
vessels using the navigational channel. The presence of vessels could therefore
create a temporary disruption to the control of shipping traffic in this area, both
during the cable laying process with slow moving vessels crossing the path of
navigation and during operation when maintenance vessels will be stationary with a
safety zone of 2km.
16.25
This impact will be reduced by ensuring that cable joints, which will require the
presence of stationary vessels for connection and maintenance, are not placed in
the navigational channel. In addition, shipping routes are submitted in advance to
CROSS Gris-Nez and the Préfecture Maritime de Cherbourg; during cable laying
operations this information can be used to redirect marine traffic.
343
16.26
As with the navigational channel, the presence of installation or maintenance
vessels may cause a temporary disruption to vessels accessing commercial fishing
zones. The distribution of fishing zones is however vast and local fishing has a
tendency to be situated in coastal areas. In addition, the season with the greatest
fishing activity tends to be between October and December (inclusive), whereas the
most favourable period for cable laying is from April to October. The impact on
fishing will therefore depend upon whether the cable laying activities can be limited
to a timescale outside the main fishing season.
Belgian Subsea Cable
Physical Environment
16.27
In Belgium, sand waves are located at several locations along the route, rising up to
6m above the surrounding seafloor. The sand waves are usually covered with
smaller ripples. Pre-sweeping will result in an increased turbidity and sedimentation
in the vicinity of the works. Due to the limited volume of sand to be moved and
because of the high mobility and dynamics that sand waves already naturally
exhibit, the impacts on sediment from pre-sweeping is considered small.
16.28
At crossings with other cables and pipelines, protective measures and bridges are
proposed. In Belgian waters five existing cables and one pipeline need to be
crossed. The protective measures disturb the original geological structure.
However, given the very limited size of the protective measures, this effect is very
limited.
16.29
No effect is expected on sediment quality from accidental discharges from ships
and machinery during construction or due to loss of pollutants from the cables or
from crossing infrastructures.
16.30
During pre-sweeping operations for cable burial and cable burial itself, there is
potential for an impact on water quality arising from the release of existing heavy
metals and organic pollutants within the sediment. As the pre-sweeping involves
removal of coarse sediments with a low percentage of fine and organic material and
consequently low concentrations of heavy metals, this effect is considered
negligible. A temporary increase in localised turbidity will also arise from these
activities. No long term effects are expected and this will be minimised by carrying
out installation in quiet (low flow) weather when the natural turbidity is low and
which will allow for quicker sedimentation of the disturbed seabed material.
16.31
As part of the overall safety system, there will be a clear procedure available which
defines the roles and responsibilities and actions to be taken if an emergency
should arise during installation, operation or decommissioning that could adversely
affect water quality (e.g. oil spill).
Biological Environment
16.32
In Belgium, both during the preparatory work and during cable laying the impacts
upon the benthic habitat is considered negligible due to the size of the area affected
and the temporary nature of the activities. Permanent habitat loss is unlikely to
occur as the cables are entirely laid below the seabed at a minimum depth of 1 m
and the benthic communities mainly occur in the first 20 cm of the sediment. It is
anticipated that following construction, a natural recovery of the benthic community
will occur in areas where there has been small scale disturbance. The effects on
344
fish in relation to ground disturbance are less pronounced due to the mobility of the
species.
16.33
The potential effects of localised and temporary increases in turbidity upon benthic
communities and habitat are considered negligible due to the existing ecosystem
being well adapted to a sandy surface that is naturally in motion, the high mobility of
fish species present and the limited size of the impact zone. Local seabird
populations are accustomed to foraging in turbid water, and most species feed
close to the surface. The effects of increased turbidity and sedimentation on birds
are considered to be small.
16.34
There are considered to be no significant impacts upon benthic species and the
surrounding seabed due to warming of the cable during operation due to the burial
depth and, as the majority of benthic species reside within 20 cm of the surface of
the seabed, the cooling effects of the seawater.
16.35
During the operational phase, an electromagnetic field (EMF) will be generated
around the HVDC interconnector. The effects of EMF on the benthos is largely
unknown. EMF can be detected by and affect certain sensitive species, but the
extent of the impacts are not yet fully understood and there are thought to be
variations at the individual level within species. Given the very local nature of the
generated EMF during operation, the rapid decrease of field strength in relation to
distance from the cables and the reduction of exposure of sensitive species as a
result of cable burial (which creates a physical barrier of some thickness), the
potential effects are considered to be negligible.
16.36
The increased presence of vessels and machinery can cause a temporary
disturbance of birds, especially at the landfall. Due to the proximity of the port of
Zeebrugge to the landfall area, the area already contains a relatively high
activity/disturbance level primarily from busy shipping traffic. The effects upon birds
are thought to be negligible.
16.37
No long term effects due to disturbance or noise are anticipated upon marine
mammals or their migratory patterns in Belgian waters. It is expected that marine
mammals will temporarily avoid the area during construction. Short term effects
from this avoidance of the area are considered minor to negligible.
16.38
No significant impacts are predicted on the special protection areas SPA3 and
SPA2 or the future SAC ‘VlaamseBanken’. Similarly no significant impacts on the
quality of the habitat of porpoises are predicted during the construction, operation or
decommissioning phases.
Human Environment
16.39
In Belgium during the preparation work and the actual installation of the HVDC
interconnector there will be a short term visual change of the seascape due to
passage of several vessels and a temporary landscape change at the landfall. The
perception of these activities can be assessed as negative (disturbance) or positive
(point of interest). Both impacts are temporary and the impact is therefore
considered to be negligible. Methods of communication with the public are to be
explored to provide informative information regarding construction activities.
16.40
The positions of known wrecks were avoided during cable routing following
consideration of the available data. Existing data was verified against the Side Scan
Sonar data originating from the geophysical surveys which also served to identify
345
previously unknown wrecks to maximize avoidance of these historic features and
minimise any potential impacts. If a previously unidentified wreck is discovered
during construction, the competent authorities will be informed as soon as possible.
16.41
Disturbance to fishing grounds during construction is considered to be limited and
temporary during the construction phase. Fishing grounds will be inaccessible
during construction within a given distance from installation activity and associated
works.
16.42
Potential damage to the cable caused by use of fishing gear is considered to pose a
minimal risk at the burial depths anticipated. The Project is located in an area with
existing subsea cables present.
16.43
No safety risks arising from damage to the cables are expected given the small risk
of occurrence and the security mechanisms within the converter station.
16.44
Only minor negative effects are anticipated on tourism and recreation offshore
during construction. The use of safety zones during construction means that a short
term disturbance to recreational sea users may be experienced. The effects of this
disturbance will be temporary and are considered to constitute a minor impact. The
safety zones will be actively monitored during construction and communication with
the coastguard will be maintained.
16.45
Communication will be maintained with the maritime agencies during the installation
of the HVDC interconnector in the vicinity of the designated military areas.
16.46
If necessary, out of service telecommunication cables may be cut to allow for cable
installation during construction. If this occurs, the appropriate health and safety and
environmental precautions will be taken.
Belgian Onshore Infrastructure
16.47
A summary of the effects of the Belgian onshore infrastructure on the physical,
biological and human environment is provided below.
Physical Environment
16.48
There will be no significant soil profile degradation in the area of the cable trenches.
During construction, the top layer of soil will be removed and stored for later re-use.
Once the trench is filled in, the top layer will be restored. No significant effects are
expected at the converter station site. The site is, for the most part, already paved
and the only soils present are of anthropogenic origin.
16.49
The re-use of excess soil from the trenches will be recorded in a Technical Report
to avoid the risk of spreading any soil that is subsequently identified as being
polluted. Any soils previously identified as being polluted will be decontaminated
before work commences.
16.50
The site for the proposed converter station is mostly paved. The proposed
development will result in an increase in permeable hard landscaping and
consequently, the proposed development will lead to an increase in infiltration and a
decrease in surface area run-off. The proposed development will meet the urban
regulation on rain water wells, infiltration facilities, buffer facilities and separate
discharge of sewage and rain water.
346
16.51
Groundwater drainage is necessary while making open trenches and can have an
effect on the groundwater level and groundwater flow. The influence on pools and
low-lying grounds is relatively small because of the low permeability.
16.52
The proposed route of the cables lies in a zone with shallow salinized groundwater
(0-2m ground level). The duration and depth of the expected drainage is not of the
nature that salinity will increase. A contribution to increased salinity can occur
indirectly if freshwater is pulled from under the nature reserve, de Fonteintjes. Poor
hydraulic contact between GraafJansader and the dunes to the north could cause
significant groundwater and surface water reduction in the nature reserve.
Considering the natural characteristics of de Fonteintjes, this should be avoided and
any necessary mitigation measures will be applied.
16.53
Groundwater fluctuations during the exploitation phase can be avoided by the use
of dolomite fragmentation and the application of clay stops. Consequently,
significant effects to the groundwater level and groundwater flow will be avoided.
16.54
For the cables that are laid through directional drilling, the risk of impacts on
archaeological heritage is deemed quite limited. An archaeological investigation will
be carried out for the part of the HVDC cable that will be installed in an open trench.
The archaeological investigation will be conducted in consultation with the Heritage
Agency.
16.55
As a result of the previous activities pursued at the site where the converter station
is proposed, it is expected that the soil has already been quite disturbed, which
further reduces the likelihood of an impact on archaeological potential. No
archaeological investigation is deemed necessary at this location.
Biological Environment
16.56
The proposed development will cause temporary habitat loss as a result of the
temporary storage of the cable ducts, creation of the construction area, excavation
of the trenches for the HVDC cables, and construction of the underground jointing
pits.
16.57
When drilling from the land, the ducts bundle would not be temporarily stored
onshore, but would prepared at sea or installed on the beach. This would ensure
only a temporary loss of habitat.
16.58
The HVDC cable will be installed through directional drilling underneath the beach,
the special habitat protection area, the nature reserve and the ‘De Fonteintjes’ and
‘Oudemaarspolder’ ecological network. Directional drilling will not cause a loss of
habitat within these protected areas.
16.59
Because of the temporary nature of the loss of habitat, and the restoration of habitat
upon the completion of these works, significant effects will not occur.
16.60
Permanent loss of habitat occurs only as a result of the construction of the
underground jointing pits and the converter station.
16.61
Because of the minimal area of permanent loss, the impact of the construction of
the jointing pits is considered negligible. At the converter station, there is only
permanent loss of the biologically less-valuable habitats.
347
16.62
Lowering of the groundwater level during drainage may have a drying-out impact on
the local groundwater-dependent vegetation and species habitats. Increased
salinity of shallow ground water is also a possible effect to be taken into account.
The establishment of a dolomite base may also have a draining, and therefore
drying-out effect. This effect might reach as far as into the De Fonteintjes nature
reserve.
16.63
With regard to the possible effects to groundwater, additional investigations (which
will include an Appropriate Assessment for the Natura 2000 areas), will be
undertaken; appropriate mitigation measures will be identified to prevent significant
adverse effects on the natural characteristics of these areas.
Human Environment
16.64
The audible noise impact of the converter station (including the recommended
mitigation measures) on the original ambient audible noise is negligible throughout
the daytime and the evening. During the night, an increase in ambient audible
noise perceptible by the human ear may occur at one measuring point. It can be
concluded that during the day and the evening the total audible noise impact of the
converter station (including the recommended mitigation measures) and the
substation is negligible.
16.65
The HVDC cables will generate electric and magnetic fields. The electric field is
completely screened by the metal sheath on the outside of the insulation around
each conductor. Magnetic fields, however, are not screened by the metal sheath.
16.66
The magnetic fields produced by each cable have a cancelling effect as a result of
laying the two cables close to one another. Because of the opposite flow direction of
the two separate cables, the magnetic fields are also opposite and largely cancel
out each other. In this way, the field strengths remain of the same order of
magnitude as the earth's natural magnetic field.
16.67
Magnetic and electric fields will be produced by the converter station and substation
equipment. At the site perimeter, the magnetic and electric field reduced reply from
their sources and will comply with Government exposure limits set out in Chapter
15. No impact is expected as a result of the combination of the converter station
and the substation.
16.68
The visual disruption during the construction phase is caused by the presence of
temporary site buildings and soil storage. Upon completion of the work, the surface
will be restored to its original condition. Because of the temporary nature of the
impact, this is not considered significant. The work may cause disruption for people
spending their leisure time on the beach, cyclists using the coastal cycle route,
people living along Evendijk West, and residents of Veerbootstraat. The impact is
considered limited due to the temporary nature of the works.
16.69
The jointing pits are constructed completely underground. The inspection pit will
however be visible. As the size of the pit and the height of the structure above
ground level are limited, there will be no significant visual disruption.
16.70
The trench itself and the construction area will take up land. After the trench has
been backfilled, farming activities can be resumed, for both grazing and crop
cultivation. Because of the temporary nature of this claim on land, this impact is
considered limited.
348
16.71
The former military area has an industrial character, which is further enhanced by
the presence of the harbour infrastructure and activities in the surrounding area. It is
expected that the erection of a converter station in this area will have little impact on
the character of the surrounding landscape. The architectural and landscaping
design of the converter station is however being developed to fit the building into
the landscape as naturally as possible.
Cumulative Effects
Land Use
16.72
There is no potential for cumulative effects on land use to arise from the UK
onshore elements and any other aspect of the Nemo Link (subsea cables and
Belgium onshore elements). Subsea cables are in the marine environment, rather
than the land environment and in any case, once installed land and marine cables
will have no cumulative effects on land use.
Ground Conditions, Contamination and Hydrology
16.73
There is limited potential for cumulative effects on ground conditions or
contamination effects; however, there is the potential for cumulative contamination
effects during the installation of the onshore cables in the intertidal area and the
subsea cables close to the foreshore through the release of contaminants into the
water environment. Subsea cable installation procedures such as cable route
clearance, sweeping and excavation have the potential to result in contamination
effects.
16.74
Industry standard mitigation measures will be adopted during both installation
phases to ensure individual and cumulative effects are not significant. For the
intertidal cable, secure bunded areas for fuels, lubricants and chemicals as part of a
detailed Construction Environmental Management Plan for the cables in the
intertidal area will be implemented. For the subsea cables, effects are likely to be
small in scale and localised; the potential for contamination affecting water quality
has been assessed as not significant.
16.75
There is unlikely to be any significant cumulative effects on ground conditions,
contamination and hydrology resulting from the UK onshore elements and the
subsea cable works of the Nemo Link.
Ecology
16.76
There is an area of overlap within the intertidal zone between the elements
assessed under the UK Onshore Infrastructure and UK Subsea Cable elements.
Ecological impacts within the intertidal zone during the construction phase are
therefore included in both onshore and subsea assessments but as they only occur
once, do not constitute cumulative impacts. No operational impacts are anticipated
in the intertidal zone.
16.77
The onshore and intertidal construction and operational phases of the UK Onshore
Infrastructure element of the scheme are not anticipated to impact upon any of the
receptors including Sabellariaspinulosa reefs due to their physical isolation within
subsea areas. No S. spinulosa reefs were identified within the intertidal zone during
survey or consultation. No impacts are anticipated for herring spawning grounds or
marine mammals due to physical isolation of the onshore works from the subsea
habitats.
349
16.78
The geographical isolation of the UK onshore construction and operational
components of the Nemo Link will ensure that there is no scope for significant
cumulative impacts with construction and operational impacts of the French Subsea
Cable, Belgian Subsea Cable and Belgian Onshore Infrastructure elements.
Archaeology and Cultural Heritage
16.79
There is very limited potential for cumulative effects on archaeology and cultural
heritage. The design of the cables includes mitigation through avoidance of known
heritage assets to reduce direct impacts as far as reasonably possible. It is,
however, likely that each element of the project could have physical impacts on
geographically distinct non-designated heritage assets. While it is acknowledged
that a documentary record is not as valuable as retaining the asset, these effects
can be mitigated. The overall cumulative effect is therefore no greater than each
individual residual effect, which is neutral assuming that suitable mitigation
measures are implemented.
16.80
There is a recorded findspot of a Roman cup in the foreshore. The heritage asset
does not indicate archaeological potential, and since it has already been removed,
the site is considered of low importance. No effects are anticipated. All known
wrecks have been avoided during subsea cable routeing; an archaeological
reporting protocol will ensure that any material discovered during the installation will
be reported, recorded, stabilised and conserved.
16.81
No significant cumulative effects on archaeology and cultural heritage are
anticipated.
Landscape and Views
16.82
Temporary cumulative landscape and visual effects are anticipated during
installation of the underground cable (proposed as part of the UK onshore
components) and the subsea cable works proposed within the UK intertidal area.
The contractor’s compound, temporary fencing, construction plant and equipment
(e.g. a winch), vehicle movements and cable trenching will be visible on shore,
along with construction activity at the Transition Joint Pit (TJP). Large vessels
required for laying and burying the subsea cable will be visible from the shore, and
the sea where recreational sea users have views. Construction activities will
temporarily disrupt landscape character and will reduce the visual amenity of the
area. The significance of these temporary cumulative effects on landscape
character and views will be minor adverse. On completion there will be negligible
cumulative effects on landscape and views as proposed cables would not be visible
in the landscape/seascape.
16.83
There will be no cumulative effects on landscape and views during construction and
on completion of the UK onshore components and the subsea cable works within
French and Belgian waters, and with Belgian onshore components, due to distance
and no intervisibility between these development proposals.
Traffic and Transport
16.84
Construction traffic will be localised and distant from traffic associated with other
elements of the Nemo Link. During operation, traffic impacts on the local highway
networks in Belgium and the UK are not significant. The geographical separation of
350
the UK and Belgium operational components will also ensure that there is no scope
for significant cumulative impacts.
Noise and Vibration
16.85
The operation of the converter stations and substations in both the UK and Belgium
are not predicted to give rise to significant adverse noise or vibration effects. Noise
and vibration during the construction phase (both UK and Belgium) are also not
predicted to give rise to significant adverse effects. Their geographic isolation
ensures that cumulative effects are unable to occur.
16.86
There may be temporary cumulative noise and vibration effects associated with the
installation of the UK cables in the intertidal area (installation plant and machinery)
and the installation of the subsea cables close to the intertidal area (installation
plant and machinery and marine vessels). Such effects will however be of a
temporary nature, localised and highly unlikely to result in significant cumulative
effects.
Air Quality
16.87
There is the potential for cumulative effects arising from construction traffic and
plant and machinery associated with the UK intertidal and land cable installation
works and marine vessels associated with the subsea cable installation works close
to the intertidal area. Dust and vehicle emissions will be controlled during
construction; none of the components of the Nemo Link will result in significant air
quality impacts during operation as effects are temporary, of very low quantities and
localised. No significant cumulative impacts on air quality will occur.
Socio-Economics, Tourism and Recreation
16.88
The combination of the onshore UK intertidal cable installation works and the
subsea cable installation works close to the intertidal area has the potential to give
rise to cumulative effects on socio-economics, tourism and recreation. The main
potential effect is likely to result from temporary disturbance to activities such as
water sports and recreational activities including bird watching.
16.89
With the implementation of mitigation measures, there will be no significant adverse
effects on tourism, recreation and socio-economic associated with the UK onshore
works. The addition of the subsea cables installation is highly unlikely to result in
adverse effects above the UK onshore effects due to their temporary nature.
EMFs and EMCs
16.90
All components of the Nemo Link project will operate below public exposure
guidelines for EMFs. There will be no individual or cumulative EMF effects resulting
from the Nemo Link project as a whole.
Conclusion
16.91
No significant cumulative adverse effects resulting from any aspect of the UK
onshore elements with any other aspect of the Nemo Link are anticipated to arise
during the construction or operation phases.
351
352
17.0
ASSESSMENT OF EFFECTS OF THE NATIONAL ELECTRICITY
TRANSMISSION SYSTEM CONNECTION
Introduction
17.1
This chapter provides an assessment of the potential effects of the connection of
the Nemo Link to the national electricity transmission system (NETS). It also
includes an assessment of the potential cumulative environmental effects arising
from the UK onshore elements of the Nemo Link and the NETS connection.
17.2
A connection is required to enable the 1000MW capacity of the Nemo Link to be
connected to the existing NETS. A site has been selected by NGNLL at
Richborough for the proposed converter station and substation. There is no
existing National Grid Electricity Transmission plc (NGET) 400kV infrastructure in
the area surrounding Richborough to enable a connection to be made. There is
therefore a requirement for a high voltage connection from the proposed substation
to the existing NETS.
17.3
The NETS connection is required as a direct result of the Nemo Link; therefore it is
appropriate to consider its isolated effects and cumulative effects with the UK
onshore elements of the Nemo Link as part of this Environmental Statement (ES).
17.4
The NETS connection is the responsibility of NGET. NGET has a duty to connect
electricity generators to the NETS and providing a connection is part of its statutory
function as the holder of a licence to transmit electricity under Section 6(1)(b) of the
Electricity Act 1989.
17.5
The form (type of technology) and route of the NETS connection are not yet known,
do not form part of this planning application under the TCPA 1990, and will be
promoted separately by NGET in due course. The type of consent required will
depend on the type(s) of technology proposed for the connection. If an overhead
line is proposed for all or part of the connection, a development consent order
(‘DCO’) will be required under the Planning Act 2008. If an underground cable is
proposed for all of the connection, the proposed installation would be undertaken as
permitted development under Part 17, Class G of the Town and Country Planning
(General Permitted Development) Order 1995. Should an underground cable be
proposed for part of the connection however, it would form part of a DCO
application.
17.6
In developing the NETS connection, NGET assesses and examines strategic
options and, based on this, develops route corridor options before the selection of
the preferred route corridor option. As part of developing the NETS connection,
NGET would carry out appropriate consultation and environmental studies. If an
application for development consent under the Planning Act 2008 is required,
NGET would undertake the consultation process prescribed under the Planning Act
2008 and Environmental Impact Assessment as set out in the Infrastructure
Planning (Environmental Impact Assessment) (EIA) Regulations 2012. NGET
anticipates that, if a DCO application is required, it will be submitted to the Planning
Inspectorate in the third quarter of 2015. Should a proposed connection consist
entirely of underground cables installed as permitted development, EIA would not
be an automatic statutory obligation. In those circumstances, NGET would come to
a view as to whether an EIA was required under the Town and Country Planning
(Environmental Impact Assessment) Regulations 2011. Appropriate consultation
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and environmental studies would be undertaken in the event that EIA was not
applicable for underground cables.
17.7
Although the consortium promoting the Nemo Link includes a National Grid group
company, it is important to understand that NGNLL and NGET are separate legal
entities and their statutory roles in relation to the Nemo Link and the NETS
connection are clearly segregated under the Electricity Act 1989. The operation of
an electricity interconnector is a separately licensable activity under section 6(1)(e)
of the Electricity Act 1989. The Act expressly provides that the same person (which
includes a company) may not hold an interconnector licence and a transmission
licence. NGET is obliged to enter into a Bilateral Connection Agreement with
NGNLL as would be the case for all other customers seeking a NETS connection.
Connection Options
17.8
The NETS connection is required to be made at a point on the system where
capacity is either available or can be achieved and can be made in accordance with
NGETs statutory obligations under the Electricity Act 1989. NGET’s obligations
under Section 9 and Schedule 9 of the Electricity Act 1989 respectively are:
‘Develop and maintain an efficient, co-ordinated and economical system of
electricity transmission’; and
‘To have regard to the desirability of preserving natural beauty, of conserving flora,
fauna and geological or physiographical features of special interest and of
protecting sites, buildings and objects of architectural, historic or archaeological
interest’.
17.9
The proposed substation from which the NETS connection is to be made is part of
the Proposed Development the subject-matter of this application and is to be sited
adjacent to the proposed converter station at the former Richborough Power Station
site. Due to the lack of existing high voltage electricity infrastructure in the area
surrounding the proposed Nemo Link substation, NGNLL considers that it is likely
that the NETS connection could be made between the proposed substation at
Richborough and one of the following three existing high voltage NGET substations
on the NETS (see Figure 17.1):



Canterbury North;
Cleve Hill; or
Kemsley.
17.10
NGNLL understands that all three connection options would offer the appropriate
capacity for the required connection and that if any additional reinforcement work is
required for any option, it would be limited to localised works.
17.11
The NETS connection could be made using a variety of technology options as
follows:



17.12
AC overhead line;
AC underground cable (cross linked polyethylene - XLPE); or
AC gas insulated line (GIL).
The NETS connection could be made using one of the technology options detailed
above for its entirety, or a combination of two or all three technology options.
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Method of Assessment
17.13 As stated above, the NETS connection could be made via AC overhead line, AC
underground XLPE cable or AC underground GIL. An overhead line would likely
consist of a 400kV double circuit connection using pylons approximately 50m high
and spaced approximately 360m apart. An XLPE underground cable would
typically comprise a construction swathe for two AC circuits, consisting of two
cables per phase, between 35-50 m wide. Underground GIL is a new technology
option not yet installed as part of the UK transmission system other than for very
short lengths in substations. It would also consist of a trench installation, using a
slightly smaller trench than the underground XLPE cable. There would be little
difference between the two types of underground technology in terms of potential
environmental effects (both during construction and operation). For the purpose of
this assessment, reference from this point forward is made to a potential overhead
line or underground NETS connection option; the latter may be by XLPE
underground cables or GIL.
Assessment of Potential Environmental Effects of NETS Connection Options
17.14
This section provides an assessment undertaken by NGNLL of the potential
environmental effects of the NETS connection options detailed above.
Land Use
17.15
Effects on land use (regardless of the connection option selected) during
construction will be localised and temporary. Any land temporarily affected during
construction would be reinstated to enable previous land uses to continue. Whilst
there would be some permanent land take associated with overhead line
connection options, this would be insignificant in terms of the local land resource.
Permanent land take associated with an underground option would also be very
small; most existing land uses above the completed works would be able continue
including farming, roads, open space and public rights of way.
17.16
An underground installation would, in some circumstances result in permanent
constraints to future land uses. The permanent easement above would need to be
kept clear of buildings and structures to allow access for repairs or maintenance.
Careful routeing could ensure minimal impact on existing and future land uses.
Specific land uses within employment and housing sites (such as open spaces and
footpaths) would be able to be accommodated above an underground connection.
Significant land use effects are considered unlikely to occur.
Ground Conditions and Contamination
17.17
There are no sites designated nationally for their geological/geomorphological
interest in the area and the local geology and soils pose no particular constraint to
either underground options or the construction of an overhead line. There is a
Regionally Important Geological site north of the former power station site but there
should be no effects on it from the NETS connection (regardless of the connection
option selected)). Contamination risk will be very low and could be addressed
through the adoption of typical construction mitigation measures. Significant effects
on ground conditions and contamination are considered unlikely to occur.
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Hydrology and Flood Risk
17.18
Once operational, neither underground cables nor overhead line options are
anticipated to have significant effects on water resources or flood risk.
Underground technologies will be installed below ground and overhead line tower
foundations would occupy a very small footprint; therefore the potential for adverse
effects on surface water run-off is low. Whilst there is the potential for different
effects on surface water and groundwater during construction, depending on the
nature and extent of construction activity a number of pollution prevention, flood
protection and attenuation mitigation techniques can be implemented in accordance
with policy and guidance notes to ensure no significant risks occur.
Ecology
17.19
There is the potential for all potential connection options (whether by overhead line
or underground) to have the following effects on nature conservation designations:
17.20
Thanet Coast and Sandwich Bay SPA and Ramsar - Potential for disturbance of
breeding and overwintering bird species and potential for bird collision risk through
construction and operation of overhead lines.
17.21
Stodmarsh SAC and Blean Complex SAC - There is the potential for habitat
impacts arising from loss of Annex I habitats. There is also the potential for impacts
on Annex II species through direct construction activities, habitat loss and habitat
alteration resulting from changes in hydrology.
17.22
Stodmarsh SPA – There is potential for disturbance of breeding and overwintering
bird species and potential loss of habitats supporting breeding and overwintering
birds. Potential collision risk through construction and operation of overhead lines
only.
17.23
Stodmarsh Ramsar Site - Potential loss of wetland habitats affecting wetland
invertebrates. Potential changes in habitats through direct impacts and changes in
hydrology. Potential disturbance of breeding and overwintering bird species and
potential loss of habitats supporting breeding and overwintering birds. Potential
collision risk through construction and operation of overhead lines only.
17.24
East Blean Woods SSSI - Potential loss of areas of primary deciduous woodland
in the Blean Woods complex north of Canterbury. This may also impact insect
fauna.
17.25
West Blean and Thorndon Woods SSSI - Potential loss of ancient semi-natural
woodland and conifer plantation; also potential impacts on breeding birds and
invertebrates.
17.26
Stodmarsh SSSI - Potential loss of wetland habitats, impacting invertebrate fauna
and nationally significant breeding bird populations.
17.27
Sandwich Bay to Hacklinge Marshes SSSI - Potential temporary loss and
disturbance of mudflats, saltmarsh and grassland habitats. Potential disturbance of
migrating birds and wintering populations of waders.
17.28
Preston Marshes SSSI - Potential loss of fen vegetation.
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17.29
Chequers Wood & Old Park SSSI – Potential loss of woodland and unimproved
acidic grassland.
17.30
There is the potential for four potential connection options (Cleve Hill and Kemsley;
overhead line or underground) to have the following effects on nature conservation
designations:
17.31
The Swale SPA – Potential for disturbance of breeding and overwintering bird
species and potential loss of habitats supporting breeding and overwintering birds.
Potential for bird collision risk through construction and operation of overhead lines
only.
17.32
The Swale Ramsar - The potential loss of wetland habitats affecting wetland
invertebrates. Potential changes in habitats through direct impacts and changes in
hydrology. Potential disturbance of breeding and overwintering bird species and
potential loss of habitats supporting breeding and overwintering birds. Potential
collision risk through construction and operation of overhead lines only.
17.33
The Swale SSSI - Potential loss of areas of freshwater grazing marsh notable for
the internationally important numbers of wintering and passage wildfowl and
waders, important breeding populations of a number of bird species and
outstanding assemblages of plants and invertebrates.
17.34
Church Woods, Blean SSSI - This site is one of the most extensive areas of
broadleaved woodland remaining in the Forest of Blean. No direct impacts
anticipated.
17.35
Ellenden Wood SSSI - Potential loss of ancient woodland.
17.36
Careful route alignment would likely ensure that the potential for significant adverse
effects on such designated nature conservation areas could be avoided or
minimised as far as possible (subject to detailed routeing at a later date).
Archaeology and Cultural Heritage
17.37
Careful route alignment (both overhead line and underground) and the siting of
towers would minimise effects to the extent that significant effects on archaeology
and cultural heritage could likely be avoided (to be determined at detailed routeing
stage). The following potential environmental effects have been identified.
Canterbury North Overhead Line and Underground Connection
17.38
There is the potential for adverse permanent (overhead line) and temporary
(underground construction) effects on the setting of the World Heritage Site of
Canterbury, the Schedule Monument (SM) of Richborough Castle and the Sarre
Anglo-Saxon Cemetery SM. There is also the potential for adverse permanent and
temporary effects on the setting of a number of Conservation Areas, Listed
Buildings and as yet unidentified below ground archaeology.
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Cleve Hill Overhead Line and Underground Connection
17.39
There is the potential for adverse permanent (overhead line) and temporary
(underground construction) effects on the setting of the World Heritage Site of
Canterbury, the SM of Richborough Castle, the Sarre Anglo-Saxon Cemetery SM,
the Thornden Wood Bowlbarrows SM and the Graveney Marshes Medieval
Salterns SM. There is also the potential for permanent and temporary adverse
effects on the setting of a number of Conservation Areas, Listed Buildings and as
yet unidentified below ground archaeology.
Kemsley Overhead Line and Underground Connection
17.40 There is the potential for adverse permanent (overhead line) and temporary
(underground construction) effects on the setting of the World Heritage Site of
Canterbury, the SM of Richborough Castle, the Sarre Anglo-Saxon Cemetery SM,
the Thornden Wood Bowlbarrows SM, the Graveney Marshes Medieval Salterns
SM and the Castle Rough Medieval Moated Site SM. There is also the potential for
permanent and temporary adverse effects on the setting of a number of
Conservation Areas, Listed Buildings and as yet unidentified below ground
archaeology.
Landscape and Views
17.41
Adverse effects on landscape and views could be mitigated by the careful siting of
towers and overhead lines at the detailed design stage. The following potential
environmental effects have been identified.
Overhead Line Connection
17.42
The main designations in the area are the Kent Downs AONB, the North Kent Plain
National Character Area and the North Downs National Character Area; the Greater
Thames Estuary National Character Area is in the area around a connection option
to Cleve Hill and Kemsley. There is the potential for the overhead line (all
connection options) to be viewed from within the AONB; however, the OHL would
not be routed directly through it and would be unlikely to affect its wider setting.
There is the potential for effects on landscape and views, including from nearby
settlements; the extent of adverse visual effects would be greater for a Cleve Hill
connection and greater still for a Kemsley connection due to the increased length of
the overhead line. The loss of woodland would be difficult to avoid near Canterbury
(Cleve Hill and Kemsley connection options only) (subject to detailed design).
Underground Connection
17.43
An underground connection is not likely to have any landscape or visual effects on
the North Downs AONB, the North Kent Plain National Character Area, the North
Downs National Character Area or the Greater Thames Estuary National Character
Area (the latter relevant to Cleve Hill and Kemsley connection options only). There
would be temporary effects on landscape character and views during the
construction phase; there is also the potential for additional effects associated for
example with the loss of trees.
Traffic and Transport
17.44
Once operational, the effects on traffic and transport will be negligible for all options
as traffic movements would only be required for infrequent routine repair and
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maintenance. Construction works will involve the transport of plant and machinery
and work personnel to sites. The effects will be temporary and such movements
are not expected to result in increases in traffic on the local highway network above
thresholds where significant effects are considered to occur. Traffic during
construction can be appropriately managed via the production and implementation
of a Transport Management Plan. Significant traffic and transport effects are
considered unlikely to occur.
Noise and Vibration
17.45
Underground options would not give rise to noise and vibration during operation.
The National Policy Statement for Electricity Networks (EN-5) states that noise from
overhead lines is unlikely to lead an application to be refused as a variety of
mitigation measures are possible, such as the positioning of lines and the design
and maintenance of conductors.
Noise during the construction phase for
underground and overhead options would be temporary and localised and is
capable of mitigation using well established industry-standard techniques.
Significant noise and vibration effects are considered unlikely to occur.
Air Quality
17.46
Neither underground nor overhead line options would have any effects on air quality
during the operational phase. During construction, both cable laying and the
construction of an overhead line have the potential to generate dust and emissions
from plant and machinery and associated traffic movements. These effects
however would be temporary and localised. Dust and other emissions are capable
of mitigation using well established industry-standard techniques. Significant air
quality effects are considered unlikely to occur.
Coastal Tourism, Recreation and Socio-Economics
17.47
None of the connection options would affect any major areas of economic activity or
tourist assets of national importance. During the detailed design stage for the
connection, any effects on recreation areas during construction (e.g. temporary
closure and diversion of footpaths) will be appropriately managed to ensure
disturbance and inconvenience is kept to a minimum. Effects will be localised and
temporary and are considered unlikely to result in significant adverse effects. There
may be some temporary beneficial effects during the construction period; personnel
employed will use local goods and services which will be provided by local
businesses, catering or hotel facilities. The purchase of materials, equipment and
services during the construction phase may have a minor beneficial effect on the
creation of temporary and permanent jobs locally and nationally within the supply
chain.
Electric and Magnetic Fields
17.48
Electric and magnetic fields from overhead or underground connections will
combine with the fields already present in the area from other sources, which vary
with time depending on electricity usage. The way in which the fields combine with
each other is complex, however, in this situation, where all the fields are well below
guideline levels, it is not necessary to consider the details of this, as the combined
field will also be below guideline levels.
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Assessment of Cumulative Potential Effects of the UK Onshore Elements of
the Nemo Link and the NETS Connection
17.49
Project related cumulative impacts have been considered in this section; these are
the combined potential impacts that may occur between the UK onshore elements
of the Nemo Link to which this application relates with the NETS connection project.
The construction of the NETS connection is anticipated to take place in 2017 at
which point the construction of the converter station and substation will either be
complete or largely complete. The extent of construction overlap is therefore
anticipated to be small.
Land Use
17.50
There is little potential for cumulative effects on land use during any simultaneous
construction of both developments. The onshore cable route, converter station and
substation site associated with the Nemo Link have been carefully selected to
minimise disruption on the future use of land. The proposed Nemo Link assets
comprise underground cables that would be installed in land distinct from and
without any substantial relationship with the land which may be affected by the
NETS connection. The other Nemo Link assets would be constructed on the site of
the former Richborough Power Station which is distinct and does not have any
material land use relationship with land outside of the site which may be affected by
an NETS connection.
17.51
There would be some permanent land take associated with NETS overhead line
connection options (comprising the land at the base of the pylons) although this
would be insignificant in terms of the local land resource. Permanent land take
associated with an underground connection would also be very small; generally
existing land uses above the completed works would be able to continue including
roads, open space and public rights of way. An underground installation would, in
some circumstances result in permanent constraints to future land uses. A
permanent easement above the cables would be required to enable equipment to
be accessed for repair or possible maintenance. A permanent easement would
prevent buildings or structures being installed above the cables. Careful routeing
should ensure minimal impact on existing and future land uses (including land
allocated for development). Some land uses in employment and housing sites
(such as some open spaces and footpaths) would be able to be provided where
underground cables have been installed, subject to appropriate masterplanning.
17.52
Effects on land use from the Nemo Link and from the NETS connection would be
low in magnitude and importance and would be localised. Cumulative effects on
land use are not anticipated as there is little ‘overlap’ or relationship between the
land which would be affected in each case.
Ground Conditions and Contamination
17.53
There is little scope for any cumulative effects arising from ground conditions and
contaminated land associated with construction of the NETS connection and
construction of the Nemo Link.
17.54
There are no sites designated nationally for their geological or geomorphological
interest in the surrounding area or on the former power station site and the local
geology and soils pose no particular constraint to installation of underground
options or the construction of an overhead line. There is a Regionally Important
Geological site north of the former power station site but there should be no direct
360
or indirect effects on it from the Proposed Development of the Nemo Link or the
NETS connection.
17.55
There will be a small part of the NETS connection (the connection to the proposed
substation, relevant to all connection options) at the former power station site that
could theoretically give rise to cumulative effects if contamination was encountered
during those works whilst works on the Nemo Link also encountered contamination.
Contamination risk in this area will however be very low and is capable of being
addressed through the adoption of typical construction mitigation measures as
detailed at Chapter 6.
17.56
Outside of the former power station site, there is no known pathway or mechanism
by which there would be interaction between works required for a connection and
the works for the Nemo Link. When the route of the NETS connection is known, an
assessment will be undertaken of the potential for contamination and mitigation
measures will be identified where appropriate.
17.57
As the Nemo Link will not adversely affect soils, geology and contamination and
there is little scope for the connection to result in adverse effects, cumulative effects
are not anticipated.
Hydrology and Flood Risk
17.58
There is the potential for cumulative effects on surface water, groundwater and
flood risk, depending on the nature and extent of construction activities associated
with the connection options. It is considered that cumulatively the effects will be
insufficient to result in adverse effects on water resources as appropriate mitigation
measures will be implemented during construction to prevent the occurrence of
adverse isolated and cumulative effects.
17.59
Current planning policy, government and EA guidance (National Planning Policy
Framework, National Policy Statements and EA Pollution Prevention Guidance)
control development in terms of attenuation, flood protection levels and discharge
quality. Additionally, the quality standards of the Water Framework Directive quality
standards are being introduced through legislation and the pending introduction of
the National SUDS Standards.
17.60
Upon completion of the NETS connection, underground cables and the foundations
of overhead line towers occupy a relatively small footprint and are very unlikely to
result in significant flood risk due to loss of flood storage.
17.61
As both the NETS connection and Nemo Link development will pose no significant
effects in relation to flooding, drainage and water quality to the surrounding area
(assuming construction standard mitigation measures are implemented correctly –
see Chapter 7 for further details of mitigation measures), no cumulative effects are
predicted to occur during construction or operation.
Ecology
17.62
Potential impacts on Natura 2000 sites from works relating to the onshore elements
of the Nemo Link and the different NETS connection options are identified in
paragraphs 17.19 – 17.36 above, ES Chapter 8 (Ecology) and ES Appendix 8.9
(Information for Habitats Regulations Assessment).
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17.63
Although the sites are generally designated for different habitats and species,
Thanet Coast and Sandwich Bay, Stodmarsh and The Swale Natura 2000 sites all
support important populations of breeding and overwintering birds. There is
therefore potential for habitat loss and disturbance impacts at multiple sites (from
any of the potential connection options) resulting in a greater cumulative impact on
birds using these sites and moving between them. Such effects could be mitigated
by careful routeing of the NETS connection to avoid such direct and indirect effects.
Installation works could also be timed to be undertaken outside of the main
migratory periods. Assuming such mitigation can be implemented, there are no
anticipated cumulative effects on Natura 2000 sites.
17.64
Sandwich Bay to Hacklinge Marshes SSSI is the only nationally designated site that
may potentially be affected by both the UK onshore elements of the Nemo Link and
NETS connection options.
17.65
Due to the proximity of Sandwich Bay to Hacklinge Marshes SSSI to the former
power station site, the installation of overhead lines or underground cables (for any
of the potential connection options) has the potential to adversely impact on this
site; however direct effects are considered unlikely to occur. The Nemo Link HVDC
underground cable would pass through a separate part of this designated area
bringing potential for cumulative effects. Additionally the HVDC underground cable
passes through the Sandwich Bay to Hacklinge Marshes SSSI within the intertidal
area of Sandwich Bay and Stonelees Nature Reserve, and will result in temporary
losses of saltmarsh and grassland habitats. It is considered that with careful
routeing, the connection route could avoid the SSSI, avoiding risk of cumulative
effects occurring on this site.
17.66
The connections options are a separate project to the Nemo Link and appropriate
consents will be sought separately by NGET if required under the relevant
legislation. NGET’s proposed connection (once selected) will be subject to similar
environmental assessments to the UK onshore elements of the Nemo Link; this will
also enable effects on localised flora and fauna to be assessed and mitigation
measures to be identified where appropriate. Significant impacts on the identified
receptors will be avoided through design and mitigation, without which the
necessary consents for the works will not be obtained.
Following the
implementation of mitigation measures, potential cumulative effects are considered
to be of negligible significance.
Archaeology and Cultural Heritage
17.67
For all connection options, it is assumed that an overhead connection would leave
Richborough and head west. The potential for cumulative effects on the setting of
heritage assets will only occur where effects of the substation and converter station
overlap with the effects of the overhead line. Infrastructure more remote from the
converter station and substation could have separate effects on the setting of
cultural heritage features (see paragraphs 17.37 – 17.40 above); however, such
effects would be assessed by NGET as part of the connection proposal and would
not result in cumulative effects with the UK onshore elements of the Nemo Link.
17.68
As the NETS connection project is in the early stages of development by NGET, it is
not possible to assess specific potential effects in detail. There is however potential
for an overhead line to affect the setting of designated heritage assets. The
assessment has determined that the construction of the converter station and
substation will not result in any harm to the historic environment through historic
landscape impacts or development within the setting of a heritage asset. Therefore,
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the Proposed Development will not contribute to any cumulative effects on the
historic environment in combination with a NETS connection.
17.69
An underground connection and foundations of an overhead line tower have the
potential to affect buried archaeology. The design of the underground connection
would reduce direct impacts as far as reasonably possible, but physical impacts on
geographically distinct non-designated heritage assets are possible. While it is
acknowledged that a documentary record is not as valuable as retaining the asset,
these effects can be mitigated. The overall cumulative effect is therefore no greater
than each individual effect, assuming that suitable mitigation measures are
implemented.
Landscape and Views
17.70
If the NGET connection were to be delivered by underground cable, provided
significant tree and hedgerow clearance could be avoided by careful routing, there
would be no cumulative effects on landscape and views following reinstatement of
the land above the cable swathe. The potential for cumulative effects by an
underground connection is not considered further in this assessment
17.71
If the connection were to be provided by an overhead line, there would be
cumulative landscape and visual effects in combination with the proposed converter
station and substation. The western extent of the connection option i.e. whether the
connection extends to Canterbury North, Cleve Hill or Kemsley does not affect
cumulative landscape and visual effects. Cumulative effects will only occur where
effects of the proposed substation and converter station overlap with the effects of
the overhead line (relevant for all overhead line connection options), which is
discussed below.
17.72
The extent of the area within which landscape and visual cumulative effects, as a
result of the converter station and substation development and a 400kV overhead
line connection, would be experienced extends across the approximate Zone of
Visual Influence (ZVI) identified in Figure 10.2. The anticipated residual visual
effects of the converter station and substation beyond approximately 3km are
neutral and the anticipated residual landscape effects on the landscape at this
distance would also be neutral. Accordingly cumulative effects on landscape and
views are only of direct relevance within approximately 3km of the proposed
converter station and substation site.
17.73
The magnitude of effect that would be experienced by the landscape within
approximately 3km would be reduced by the presence of three existing 132kV
overhead lines. Two of the 132kV overhead lines run parallel and close to one
another in a westerly direction from the former Richborough Power Station site
along the valley floor. The third 132kV overhead line runs south west from the
former power station site, avoiding the higher ground at Richborough Roman Fort
before continuing south. The landscape also contains a single wind turbine and two
masts (the masts are approximately 90m high) which are west of the converter
station and substation site. Overall the cumulative landscape effects of a 400kV
overhead line connection and the proposed converter station and substation
development would be no greater than moderate adverse.
17.74
Cumulative visual effects would be experienced by a few sensitive visual receptors
in closer proximity, particularly users of the Saxon Shore Way and river users
immediately south of the converter station and substation site which would have
unobscured views of both developments. In addition, it is anticipated that visitors to
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Richborough Roman Fort and nearby residents, residents on Ebbsfleet Lane, and
the PROW network between Minster and Cliffs End would also experience
cumulative visual effects. In some of these locations, views are already restricted to
an extent by existing built form and vegetation.
17.75
The magnitude of effect that will be experienced by visual receptors within this area
would be reduced by the presence of three existing 132kV overhead lines, referred
to above. Although, a 400kV tower could be approximately 20m taller than the
existing 132kV towers, depending on the alignment of a potential new overhead line
connection, existing 132kV towers could form a larger component in some views.
Existing views also include the single wind turbine and two masts west of the
proposed converter station and substation site. Overall the significance of
cumulative visual effects would be no greater than moderate adverse.
Traffic and Transport
17.76
Construction works for the UK onshore elements of the Nemo Link and the
connection (overhead or underground) will involve the transportation of plant and
machinery and personnel. Cumulative effects on the road network are only likely to
arise in the surrounding area of the converter station and substation where travel
routes are shared for the two developments.
17.77
Traffic movements associated with the construction of the converter station and
substation are expected to be far greater than those associated with the connection
(overhead or underground). The traffic and transport assessment for the converter
station and substation concludes that the construction phase will result in a
maximum increase in road traffic of 0.9% and a maximum increase in HGV traffic of
17%. Potential effects for both the NETS connection and the UK onshore elements
of the Nemo Link will be temporary and localised and will be subject to appropriate
mitigation(via a Transport Management Plan) to ensure that effects are not
significant. Overall the significance of residual cumulative effects on traffic and
transport would be unlikely to be greater than those reported for the converter
station and substation.
17.78
Once operational, the NETS connection and the UK onshore elements of the Nemo
Link will not result in any adverse individual or cumulative traffic and transport
effects as vehicles will only be required infrequently for repair and maintenance. In
addition, the substation will be unmanned and only six workers will operate the
converter station per day.
Noise and Vibration
17.79
The underground NETS connection options would not give rise to noise and
vibration during the operational phase. Overhead lines are generally quiet but can
make a slight crackling noise in damp weather conditions; however, this noise
quickly dissipates within tens of metres from the source. The National Policy
Statement for Electricity Networks notes that noise from overhead lines is unlikely to
result in an application being refused as a variety of mitigation measures are
possible, such as the positioning of lines and the design and maintenance of
conductors. No significant individual or cumulative noise effects are anticipated
during the operation phase.
17.80
Construction activities associated with both undergrounding and the erection of an
overhead line have the potential to generate noise and vibration. These effects
would be temporary and localised and can be appropriately mitigated via the
364
implementation of industry standard measures and by using well established best
practice techniques discussed at Chapter 12 – Noise. It is anticipated that in the
vicinity of the former power station site (where cumulative effects are most likely to
occur), such mitigation measures will ensure that cumulative effects can be
appropriately managed to ensure noise and vibration effects are not significant.
Air Quality
17.81
Construction activities associated with both the UK onshore elements of the Nemo
Link and either an overhead or underground NETS connection have the potential to
generate dust and emissions from plant and traffic movements that could adversely
affect air quality. These effects would be temporary and once away from the former
power station site, construction traffic would rapidly disperse across the local road
network. Significant air quality effects can be avoided through the implementation
of industry standard mitigation measures as detailed in Chapter 13.
17.82
Underground or overhead line NETS connection options would have no effects on
air quality during the operational phase. The operation of the Nemo Link will not
result in adverse effects on air quality. No cumulative effects on air quality are
therefore predicted.
Coastal Tourism, Recreation and Socio-Economics
17.83
With the implementation of mitigation measures (see Chapter 14), there will be no
significant adverse effects of the UK onshore elements of the Nemo Link on
tourism, recreation and socio-economics. None of the NETS connection options
would affect any major areas of economic activity or tourist assets of national
importance; there is little scope for any cumulative effects from the NETS
connection in combination with the Nemo Link development. During the detailed
design stage for the connection, any effects on recreation areas during construction
(e.g. closure and diversion of footpaths) will be appropriately managed to ensure
disturbance and inconvenience is kept to a minimum. Effects will be localised and
temporary and will not result in significant adverse cumulative effects.
Electric and Magnetic Fields
17.84
Electric and magnetic fields from overhead or underground connections and the UK
onshore components of the Nemo Link will combine with the fields already present
in the area from other sources, which vary with time depending on electricity usage.
The way in which the fields combine with each other is complex, however, in this
situation, where all the fields are well below guideline levels, it is not necessary to
consider the details of this, as the combined field will also be below guideline levels.
Conclusion
17.85
For the majority of the environmental topic areas, potential adverse effects will be
temporary and localised. Adverse construction effects can also be avoided or
reduced through the implementation of best practice industry standard mitigation
and prevention measures.
17.86
Potential temporary and permanent effects on ecology (including loss of habitat and
collision risk), archaeology and cultural heritage (including Scheduled Monuments,
Conservation Areas and Listed Buildings) and landscape and views (including the
Kent Downs AONB and a number of National Character Areas) could arise from
any of the connection options.
365
17.87
Careful route alignment by NGET would likely ensure that the potential for
significant adverse effects on designated areas could be avoided or minimised as
far as possible (subject to detailed routeing at a later date).
17.88
The construction and operation of the NETS connection, which is required for the
operation of the Nemo Link, has the potential to result in cumulative environmental
effects when considered together with the construction and operation of the UK
onshore elements of the Nemo Link.
17.89
Potential cumulative effects during the construction period are largely localised and
of a temporary nature. Appropriate mitigation measures can be implemented by
NGET to ensure that no significant cumulative effects occur. For construction
effects with the potential to be longer lasting and/or permanent (e.g. ground
conditions and hydrology), the implementation of best practice industry standard
mitigation and preventative measures will also ensure that significant cumulative
effects can be avoided.
17.90
Potential cumulative effects during the operation period are largely minimal and
localised and are not anticipated to be significant. There is potential for cumulative
ecological effects on Thanet Coast and Sandwich Bay, Stodmarsh and The Swale
Natura 2000 sites (disturbance to breeding and wintering birds using these sites
and moving between them). Such effects could potentially be mitigated through the
development of the detailed design of the connection and identification of mitigation
measures. Environmental assessment work will also be undertaken for the
connection option to determine the significance of likely effects and appropriate
mitigation. The cumulative operation effects on landscape and views (if an
overhead line is proposed) are anticipated to be no greater than moderate adverse
due to the presence of existing infrastructure in the surrounding area including three
132kV overhead lines, a wind turbine and two masts.
17.91
At a time when the nature and extent of the NETS connection is finalised, consent
under the relevant legislation will be applied for by NGET separately (as detailed
above at paragraphs 17.5-17.7) to this planning application for the UK onshore
elements of the Nemo Link. All potential relevant environmental effects and
appropriate mitigation of the connection will be assessed and identified separately
by NGET to provide sufficient information to the relevant authority to enable
consents (if required) to be granted under the relevant legislation.
366
367
368
18.0
SUMMARY AND CONCLUSIONS
Introduction
18.1
This concluding chapter presents a summary of the proposed development. It also
provides a summary of the main conclusions arising from the environmental
assessment of the Proposed Development.
18.2
The Nemo Link is a proposed high voltage direct current (HVDC) electrical
interconnector which will allow the transfer of electrical power via subsea cables
between the UK and Belgium. The UK onshore elements, for which planning
permission under the Town and Country Planning Act 1990 is being sought,
comprise a converter station, substation and cables installed below the ground
between the converter station and the mean low water mark.
18.3
Alternative converter station sites, underground cable routes, landfalls and subsea
cable routes were considered as part of the development of the Nemo Link. This
established that a converter station site at Richborough and an underground cables
route to a landfall at Pegwell Bay was the preferred option as this best meets the
project objective relating to technically feasibility, economic viability, deliverability
and the least disturbance to the environment and people. Alternative options are
included at Appendix 3.1 of the Environmental Statement
18.4
Following selection of the preferred option, further detailed environmental and
technical studies as well as consultation have been used to refine the preferred
option and further reduce the potential environmental effects of the Nemo Link
project including the substation which the convertor station is required to connect to.
This included considering emerging results from environmental assessments with
initial technical designs and results of consultation with stakeholders, land owners
and local communities.
Proposed Development
18.5
The components forming the Nemo Link Interconnector in the UK requiring planning
permission under the Town and Country Planning Act 1990 will comprise:






Two HVDC subsea cables between the landfall and the low water mark;
Two HVDC onshore underground cables from the converter station to the
landfall on the coast at Pegwell Bay where they will be joined to the subsea
HVDC cables;
Fibre optic cables installed with the onshore and subsea HVDC cables for the
purposes of operational telemetry and communications;
An HVDC converter station on part of the site of the former Richborough Power
Station;
A 400kV electricity substation on part of the site of the former Richborough
Power Station; and
Three 400 kilovolts (kV) high voltage alternating current (HVAC) underground
electricity land cables to connect the above substation to the high voltage direct
current (HVDC) converter station and up to two telecommunications cables for
telemetry, control and protection purposes only.
369
HVDC Subsea Cables
18.6
The cables will be one of two subsea cable types: Cross Linked Polyethylene
(XLPE) or Mass Impregnated (MI). The cables will be rated between 350kV and
500kV. The size of the subsea cables will depend on the final design and rating but
will be approximately 15cm diameter. The cables will be bundled together in the
same trench and jointed to the HVDC onshore underground cables in the transition
joint pit (TJP), an excavated pit (15m long x 5m wide x 2.5m deep) with a reinforced
concrete plinth laid in its base.
HVDC Onshore Cables
18.7
The onshore underground cables will be of the same type as the HVDC subsea
cables (XLPE or MI) which will minimise the complexity of the joint at the TJP. The
diameter of each of the onshore underground cables will be approximately 15cm.
The distance from the TJP to the converter station is approximately 2.3km. The
fibre optic cables will be installed with the onshore underground cables and will be
approximately 50cm in diameter.
18.8
The onshore underground cables will be installed onshore in three distinct ways
along the length of the route as follows:



Standard trenching;
Surface laid with capping; and
Horizontal directional drilling (HDD).
Converter Station
18.9
The converter station will occupy a footprint of approximately 5 hectares (ha) and it
is proposed that the main building will be constructed around the steel frame of the
former Richborough Power Station’s turbine hall. The converter station will be
designed for a 40 year lifespan and will be approximately 30.3m tall at its highest
point.
18.10
Other components of the converter station include a service building, a storage
building, converter transformers, a mechanically switched capacitor (MSC)
approximately 11.75m high, a shunt reactor, a distribution network operator (DNO)
substation (providing 11kV auxiliary power), a diesel generator and outdoor high
voltage electrical equipment which consists of busbars, circuit breakers, switches,
insulators and other connecting equipment. The tallest elements of the converter
station (other than the main building) will be the service building and the overhead
gantries which are approximately 15m high.
Substation
18.11
A new 400kV Gas Insulated Switchgear (GIS) substation is required to connect the
interconnector to the national grid electricity transmission system. The 400kV
substation forms part of this planning application, however, the connection between
the substation and the national grid is still in early development and does not form
part of this planning application.
18.12
The substation will be built in a separately fenced compound immediately west of
the proposed converter station and will be connected to the converter station by
underground high voltage alternating current (HVAC) cables.
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18.13
The proposed substation will occupy a footprint of approximately 2.65ha, and will
contain indoor and outdoor electrical equipment. It includes a GIS Hall containing
the switchgear, outdoor Gas Insulated Busbars (GIB), overhead line gantries, two
Supergrid Transformers (SGTs), a Mechanically Switched Capacitor (MSC) and a
Static Var Compensator (SVC) compound. The MSC and SVC are specific types of
equipment used to regulate and stabilise transmission voltages.
18.14
The GIS Hall will be approximately 52.2m long, 21.5m wide and 15m high and clad
similar to the external appearance of the converter station. The maximum height of
the outdoor electrical equipment will be approximately 12.7m.
HVAC Cables
18.15
Three 400kV HVAC cables and two telecommunications cables will connect the
converter station to the 400kV substation. The HVAC cables will be cross-linked
polyethylene (XLPE) type and will be approximately 150mm in diameter. The total
length of the HVAC cables route is approximately 200m.
Environmental Impact Assessment
18.16
The Proposed Development to which this planning application relates is not
considered to fall under Schedule 1 or Schedule 2 of the Town and Country
Planning (Environmental Impact Assessment) Regulations 2011 and therefore EIA
is not required. However, taking into account the environmental obligations
imposed on the holder of an interconnector licence by Schedule 9 and Section 9 of
the Electricity Act 1989, and the relationship of the Proposed Development (subject
to this planning application) to the wider Project (part of which is subject to formal
EIA under Belgian law), National Grid Nemo Link Ltd has decided to prepare and
submit a voluntary Environmental Statement to accompany this application for
planning permission.
Summary of Potential Environmental Effects
18.17
The site selection and response to the technical constraints have resulted in a
development proposal in which the environmental effects have been reduced or
eliminated in the majority of disciplines to such an extent that there are few
significant residual effects. A summary of the likely effects is described below and
any effects that are not considered to be significant have been described within the
preceding chapters and are not included here.
18.18
Land Use – Predicted effects from the installation and construction of the Proposed
Development are localised, temporary and of minor significance. These include
effects on including effects on Stonelees Nature Reserve, BayPoint sports complex,
Pegwell Bay County Park, associated open space and recreation routes and part
closure of the foreshore and traffic disturbance associated with an increase in
construction traffic movement. The onshore underground cables have been routed
so that they will not prevent any future development proposals within Pegwell Bay
Country Park; however, there will be restrictions on planting above the cables route.
The proposed converter station and substation would make a positive contribution
as it would result in the re-use of derelict land contributing to national and local
policy sustainability objectives.
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18.19
Ground Conditions – Any potential effects will be eliminated through the
implementation of appropriate best practice and industry standard mitigation both
during construction and operation.
18.20
Hydrology and Flood Risk - Any potential effects will be reduced to minor
significance through the implementation of appropriate best practice and industry
standard mitigation both during construction and operation. A sustainable drainage
system will be implemented on site to ensure surface water run-off is adequately
controlled and will not result in a pollution risk to nearby watercourses and
groundwater.
18.21
Ecology – the construction and operation of the converter station and substation will
not have a significant impact on nature conservation due to the lack of ecologically
sensitive features within the site. The cable has been routed to minimise effects on
important species and habitats and cable installation works will be timed to avoid or
minimise impacts on breeding birds, nesting birds and natterjack toads. Different
sections of the cable will be installed at different times depending on the timing
constraints within each section. Overall a minor adverse to minor benefical impact
is predicted during construction. No impacts have been identified during operation.
18.22
Archaeology and Cultural Heritage – No significant impacts on above ground or
shallow archaeological deposits are predicted; however, a watching brief is
proposed during cables installation to identify the presence of unknown
archaeological deposits. Following the implementation of a programme of
mitigation, the archaeological and cultural heritage resource within, and close to,
the development site will remain unaffected and the overall impact of the scheme is
neutral.
18.23
Landscape and Views – The construction and operation of the converter station and
substation will result in moderate adverse visual effects on recreational users of the
Saxon Shore Way and the River Stour but the residual impact will be reduced to
moderate/minor by mitigation, including landscaping, and is not considered to be
significant. Mitigation measures would reduce the significance of effect of the
proposed converter station and substation on landscape character to minor adverse
to neutral. New planting around the site and at the site entrance would improve the
landscape quality of the site and would assist in integrating the proposed
development into the sites context. The significance of effect on landscape of the
underground cable route, and above ground section capped with chalk, would
remain neutral on completion with mitigation and after establishment.
18.24
Traffic and Transport – Minor adverse effects will be limited to the construction
phase and will be localised and temporary. The percentage increase with regard to
total traffic on each of the routes assessed is under 1%; the highest percentage
increase in HGV traffic was calculated to be 17% along A256 Dover Road. In all
other instances the percentage increase in HGV traffic was under 10%. There will
be no significant residual effects following the implementation of mitigation
measures including the preparation and implementation of a Transport
Management Plan.
18.25
Noise and Vibration – Mitigation will be incorporate into the design of the converter
station and substation to ensure that the noise target (assessed noise levels no
higher than the background noise levels) is achieved. Construction noise will be
minor to neutral significance with the exception of horizontal directional drilling
which will be of moderate significance; this activity is temporary and would be
expected to occur over 6 days and 3 nights.
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18.26
Air Quality – Following the implementation of mitigation measures, which consist of
well-established industry-standard techniques, effects on air quality resulting from
construction traffic and dust generating activities will be localised, temporary and of
negligible significance.
18.27
Coastal Tourism, Recreation and Socio-Economics - With the implementation of
mitigation measures, there will be no significant adverse effects on tourism,
recreation and socio-economics. The proposed development will bring benefits to
the area during construction through some direct employment and through use of
local businesses.
18.28
Electric and Magnetic Fields - The assessment has demonstrated that no
mitigation will be required because the EMFs are within UK Government guidance
levels and there will not be any significant effects arising from the NEMO link.
18.29
Cumulative Impacts – No significant cumulative adverse effects resulting from any
aspect of the UK onshore elements with any other aspect of the Nemo Link are
anticipated to arise during the construction or operation phases. There are no
predicted long-term cumulative effects resulting from the Proposed Development
and other development proposals in the study area. Any potential effects are likely
to be localised and temporary during construction and can be mitigated by the use
of well-established techniques. No significant cumulative adverse effects resulting
from any aspect of the Proposed Development with the grid connection that will be
required to connect the Nemo substation to the national electricity transmission
system (whether by overhead line or underground cable) are anticipated to arise
during the construction or operation phases.
Mitigation
18.30
Mitigation measures have been proposed to avoid, offset or reduce impacts where
these are predicted. A schedule of the proposed mitigation measures is included
below.
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Table 18.1: Schedule of Mitigation Measures
Mitigation Schedule
Land Use



The working width associated with cables installation will be kept to a minimum to reduce disturbance to adjacent land;
Temporary working areas and access roads will be fully reinstated following construction;
The laydown area will be reinstated to its current standard and it will be made available for future use by the developers of
Richborough Energy Park;
 Access to the Viking Trail and Thanet Coastal Path will be retained where possible during the construction period. Where there is
a Health and Safety requirement to prevent or reduce access, appropriately signed diversions will be agreed and put in place;
 Any public access restrictions will be minimised as much as possible and limited only to periods of major construction activity
such as earthworks;
 Temporary signage advising visitors of construction activities will be erected. This will include signs within the car park of Pegwell
Bay Country Park to ensure that visitors are aware of construction activities being undertaken;
 Contractors will prepare a Construction Environmental Management Plan (CEMP) prior to the commencement of construction.
This will include measures to ensure good construction practices are adopted on site;
 Measures to ensure construction activities do not result in any disturbance to land users surrounding the former power station site
will be developed in consultation with the site owners and operators. This will include ongoing communication and liaison,
measures to address site access and movement and working hours;
 A Transport Management Plan (TMP) will be prepared and implemented prior to the commencement of construction activities;
 Working hours during periods where recreational activity is greatest (i.e. evenings and weekends) will be limited as much as
possible; and
 Measures to control dust and noise will be adopted during the construction period.
Ground Conditions and Contamination
Prior to construction works commencing, targeted investigation works will be undertaken in agreement with an Environmental Health
Officer to assess the nature and extent of potential groundwater contamination associated with the historic pollution incidents at the
northern and southern ends of the cable route. Where pollutant linkages are identified, a robust remediation method statement will be
compiled to detail the necessary mitigation measures.
Within Pegwell Bay Country Park, investigation works will be undertaken to assess the nature and depth of capping materials overlying
the landfill area. Should investigation works identify a need for the construction phase to penetrate the landfill materials (i.e. in the vicinity
of the proposed joint pit) then a robust remediation method statement will be compiled to detail the necessary mitigation measures.
374
Mitigation Schedule
Fuels, lubricants, and chemicals required during construction and operation will be stored in secure bunded areas at appropriate
distances from watercourses with refuelling restricted to these areas. Spill kits will be available on site in case of emergency.
Standard design criteria will ensure components containing oil and lubricants are contained within bunded areas.
Pollution prevention measures will be adopted including measures to intercept and treat run-off prior to leaving site and the use of cut-off
ditches and filtration systems.
A CEMP will be prepared which will set out methods which contractors will be required to undertake as a minimum.
The CEMP will include quality control procedures to be employed for the import and export of materials to and from site. Methods for
controlling surface water run-off and dust and measures to remove contaminated materials off site to licensed treatment or disposal sites
will also be detailed.
Should apparently contaminated material be found during excavation works, where this has previously not been identified, work will
cease until the material has been characterised and appropriate measures to dispose of contaminated materials have been identified.
Contaminated materials will be characterised both chemically and physically in line with BS EN 14899:2005 –‘Characterization of Waste Sampling of Waste Materials - Framework for the Preparation and Application of a Sampling Plan’. Registered waste carriers will only be
used to convey any contaminated waste materials off site to suitably permitted facilities. All relevant documentation will be completed and
kept in line with regulations.
The laying of cables over the surface of the ground within Pegwell Bay Country Park will prevent potential contamination pathways being
opened and prevent migration of landfill gas and leachate should these be present within the landfilled area.
Measures will be undertaken to reduce the amount of water entering excavations so as to minimise dewatering activities. Should dewatering be required, the Environment Agency will be consulted and appropriate abstraction and discharge licences will be obtained if
necessary. Prior to disposal to surface water bodies, water will be treated to ensure it meets appropriate water quality standards.
Soils excavated through areas of open trenching will be monitored to ensure they are free from contamination and suitable for re-use.
Upon completion of the HDD works, surplus-drilling fluids will be pumped out of the launch and receptor pits by vacuum tanker and
removed from site to a suitable registered waste disposal facility by a registered waste carrier.
Where elevated concentrations of sulphates have been identified through the area of the proposed converter station and substation,
appropriate classes of concrete, resistant to sulphate attack will be used to mitigate this.
375
Mitigation Schedule
Hydrology and Flood Risk
General
Measures to prevent pollution of the water environment (including measures to control and manage silt-laden run-off, control mud
deposits and prevent spillages/leaks) will be set out within a Construction Environmental Management Plan (CEMP). Good practice
guidance will be based on EA Pollution Prevention Guidance. The following measures will be included in the CEMP:
 Where feasible, suitable construction techniques will be adopted to ensure that no migration pathways are created to
jeopardise groundwater quality;
 Appropriate storage and handling measures for all hydrocarbon fuels and lubricating oils, including the use of bunded
storage areas or the use of double-skinned storage tanks;
 The use of drip trays for static plant and designated refuelling areas for mobile plant;
 The implementation of appropriate spillage contingency measures to mitigate the effect of such spillages on the surface
water; and
 Appropriate personnel awareness training of the potential environmental implications of all construction work on site.
 The prevention of silt-laden run-off and mud entering the surrounding surface water drains and watercourses by:
o Timely site phasing and engineering, thus minimising un-surfaced and un-vegetated areas of the site;
o The provision of measures to intercept and treat run-off prior to it leaving site, including the use of peripheral cutoff ditches, settlement facilities, filtration and/or use of flocculants to effect the removal of water borne
particulates; and
o The provision of wheel-cleaning equipment for site plant to prevent the tracking of mud onto the public highway
and therefore into the off-site surface water drainage systems.
A Storage and Spillage Emergency Response Plan will be in place, which will include:
 The storage and use of fuel and oils on site in accordance with the Control of Pollution (Oil Storage) (England) Regulations
2001;
 Fuel and other potentially polluting chemicals stored well away from watercourses in a secure impermeable and bunded
storage area (minimum capacity 110% of the storage capacity of the tank);
 Refuelling of plant in a designated area at the site compound only;
 Maintenance of vehicles in a designated area at the site compound only;
 Fixed plant will be self bunded and/or part of a controlled containment system in accordance with EA Pollution Prevention
Guidance;
 Mobile plant will be in good working order, kept clean and fitted with drip trays where appropriate;
 Spillage kits and absorbent material will be carried by mobile plant;
 The site will be secured to prevent vandalism that could lead to a pollution incident;
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Mitigation Schedule



Designated concrete wash out areas will be constructed in accordance with good practice guidance and will be clearly
identified and used;
An Emergency Response Plan will be prepared and construction workers trained to respond to spillages; and
Construction waste or debris will be prevented from entering any waterbody.
Surface Water
HDD is proposed for the cables between the BayPoint sports complex sports fields and the former power station. This will avoid surface
disturbance of the recently constructed roundabout on the A256, avoid disturbance to Minster Stream and also avoid disturbance to a
compartment of Hacklinge Marshes Site of Special Scientific Interest (SSSI). Cables installation by HDD will not require modifications
(temporary or permanent) to the stream or interruptions in its flow.
All utility services associated with the development, including re-use of existing surface water outfalls from the former power station site,
will be designed to ensure their long-term fitness for the purpose, and will be appropriately tested prior to commission to demonstrate
their integrity and maintained throughout their use.
Appropriate sustainable drainage methods will be implemented as part of the detailed drainage strategy for the converter station and
substation site to ensure surface water run-off is effectively managed and discharge rates are no greater than pre-development levels.
Appropriate methods will be adopted during construction to contain and control runoff from the temporary laydown facility and provide
pollution control.
Water Quality
In accordance with the draft Sustainable Drainage Standards, the storage and handling of materials on site would require at least three
levels of treatment prior to discharge to a sensitive watercourse (River Stour identified by the EA as sensitive). These levels could be
provided by;
d)
e)
f)
The infiltration trench;
Settlement/containment lagoon; and
Petrol interception prior to the outfall.
A further source of potentially contaminated waters will be the oily water associated with the petrol interceptors and sumps within the
main sites. Each will be a contained structure and will require off-site removal to a suitably licensed disposal facility (or ultimately to a
suitable off-site foul sewer, subject to Southern Water approval).
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Mitigation Schedule
Flood Risk
Appropriate mitigation measures will be put in place during construction works in accordance with legislative requirements and good site
practice guidance to prevent flooding during construction from the risks identified.
Measures will be put in place during construction to ensure that the runoff from site is not increased. Temporary drainage systems may
be required to ensure that this is met. The temporary drainage systems and systems of work will also take account of the potential for
overland flow from outside of the site to cause flooding on site.
Measures will be implemented during construction to prevent debris and other material entering temporary or permanent drainage
systems or watercourses. This can be achieved through provision of temporary drainage, construction stage SuDS, and appropriate site
management.
During the construction phase, if groundwater levels are high, appropriate techniques will be utilised to mitigate the risk, such as
dewatering and ground freezing. If groundwater dewatering is required, it is likely pumps will be used to abstract the water from the
excavations, and it is likely that the pumped water will be discharged into the River Stour. Consent will be sought from the EA for any
temporary discharge to the watercourse.
The CEMP will describe the main construction compound locations and storage areas. Flood risk is to be part of the consideration in
determining the locations of these elements of the works.
A Flood Plan will detail appropriate actions in the event of a flood and will include suitable evacuation procedures, safe egress route and
a plan showing the location of assembly points.
The substation building and MSC and SVC compound will be raised above the 1 in 1000 year (plus climate change) level and the
converter station building and compound and the remaining substation compound will be raised above the 1 in 200 year (plus climate
change) level. The impact on the extent of flooding outside the site area due to land raising will be negligible for most flood events.
Ecology
Method Statements will be produced prior to any works within designated areas detailing how impacts on the habitats and species within
the area will be reduced or avoided. These will be produced in consultation with NE and KWT.
Pegwell Bay Designated Areas
The route of the subsea and onshore underground cables and location of the TJP and other joint pits have been chosen to avoid
ecologically sensitive receptors wherever possible. The subsea cable and landfall are within areas of saltmarsh south of the area
previously disturbed by the installation of the Thanet Offshore Wind Farm cable. This will avoid disturbance to the more extensive areas
378
Mitigation Schedule
of saltmarsh habitats south of Pegwell Bay Country Park the cable corridor.
Prior to commencement of works within the saltmarsh habitats, an inspection of the habitats will be undertaken by an ecologist to
determine the presence of on-going nesting activity. If active nests are identified, the commencement of works in the vicinity of the nest
site will be delayed until the nest is no longer in use. A Method Statement will be agreed with NE prior to commencement of works.
Works within the intertidal areas will be timed to avoid the periods most sensitive to wintering birds and nesting birds using the habitats.
Works within the intertidal areas will therefore be undertaken between June and August.
Site compounds will be located outside of the Pegwell Bay designated areas. No equipment, materials, chemicals or fuel will be stored
within or adjacent to designated areas. Compounds within the Richborough Site and Pegwell Bay Country Park will be used for the
storage of equipment, materials and chemicals. All refuelling of plant will be undertaken within the site compounds, within the
Richborough Site and Pegwell Bay Country Park.
All suitable plant and equipment working in the designated sites will be bio oil based. A site checklist will be used for traffic management
and plant to ensure they are all in good working order.
Drip trays or plant nappies will be used under all mobile or small plant such as generators etc.
Delivery vehicles will deliver to the site compounds to reduce disturbance and risk of spillages and leaks within the designated areas or
wider areas.
All plant and equipment working in the vicinity of the shore line shall be clean on delivery. If not all tracks, wheels etc. shall be thoroughly
cleaned before entering the working area. Generation of silt shall be minimised by excavators/dumpers etc. by limiting movements by
machinery. Plant will be regularly washed down in a bunded area and issuing water will be collected and disposed of off-site.
Dedicated skips shall be provided for disposal of materials off-site (segregated where possible).
A contingency plan for spillages etc. will be produced prior to start on site. Spill kits will be available in the site compound and all working
plant.
Prior to the start of installation works the saltmarsh areas that are to remain untouched by the works shall be visibly segregated from the
works area using temporary fencing. An ecologist shall advise as to locations of these habitats and placement of protective fencing.
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Mitigation Schedule
Machinery required to access the intertidal areas will be restricted to set routes to limit the area impacted.
Vegetation that will be directly affected by cable installation works will be removed by cutting turves. The turves will be stored locally and
will be replaced following completion of cable installation and backfilling of the trench. Different saltmarsh and grassland communities
will be stored separately and replaced based on the NVC habitat types in each part of the saltmarsh. Removal, storage and replacement
arrangements and removal will be determined through production of a Method Statement in consultation with Natural England.
Reinstatement of habitats will be undertaken in sections as the cable installation is completed and immediately following backfilling.
Excavated material on the mudflat habitats will be replaced as quickly as possible to avoid leaving exposed trenches at times of high tide.
There will be no loss of mudflat habitats as part of the works but the disturbance of the mudflats through excavation of sediments will be
unavoidable.
Following installation of the cable and TJP the working area within the saltmarsh will be fenced to allow saltmarsh vegetation to reestablish without further disturbance.
Monitoring surveys of the affected saltmarsh will be undertaken for five years following construction and the results will be submitted to
NE and KWT.
Monitoring surveys of intertidal invertebrates will be undertaken annually for a period of 5 years following the cable installation works to
determine the recolonisation rates of the disturbed areas of mudflat habitats.
Pegwell Bay Country Park
In the northern section of Pegwell Bay Country Park, the cable will be laid on top of the existing ground level to avoid disturbing the
underlying landfill. Chalk will be used to cover the cables and will be graded into the surrounding ground levels. The graded chalk will
then be used to create a swathe of chalk grassland through the north of the park, connecting to the area of existing chalk capped area in
the southern section of the Country Park. This will increase habitat and provide habitat for more diverse range of native species.
Stonelees Nature Reserve Habitats
As far as is practical, the working width associated with cables installation will be kept to a minimum and be kept close to the existing
cycle path. Impacts will be reduced to habitats within the previous working area of the cycle path, affecting as little of the previously
undisturbed habitats as possible.
Site compounds will not be located within Stonelees Nature Reserve. No equipment, materials, chemicals or fuel will be stored within or
380
Mitigation Schedule
adjacent to designated areas. Compounds within the Richborough Site and Pegwell Bay Country Park will be used for the storage of
equipment, materials and chemicals. All refuelling of plant will be undertaken within the site compounds, within the Richborough Site and
Pegwell Bay Country Park
All suitable plant and equipment working in the designated sites will be bio oil based. A site checklist will be used for traffic management
and plant to ensure they are all in good working order.
Drip trays or plant nappies will be used under all mobile or small plant such as generators etc.
All plant and equipment working in the vicinity of the shore line shall be clean on delivery. If not all tracks, wheels etc. shall be thoroughly
cleaned before entering the working area. Generation of silt shall be minimised by excavators/dumpers etc. by limiting movements by
machinery.
A contingency plan for spillages etc. shall be produced prior to start on site. Spill kits will be available in the site compound and all
working plant such as dumpers/excavators.
To inform the production of a Method Statement for works within Stonelees Nature Reserve, an NVC survey will be undertaken of areas
to be affected by the proposals. Information obtained as part of the survey will be used to produce a Method Statement in consultation
with Natural England detailing mitigation and working methods to be used during installation of the cable.
Prior to commencement of works within Stonelees Nature Reserve, temporary fencing will be installed around the site working areas to
ensure encroachment into surrounding habitats is avoided.
Grassland habitats to be affected by trenching and cable installation works will be removed in turves and replaced following
reinstatement of subsoil areas. Removal, storage and replacement arrangements and removal will be determined through production of
a Method Statement in consultation with Natural England.
Reinstatement of habitats will be undertaken in sections as the cable installation is completed and immediately following backfilling.
Wintering Birds
Cable installation works within the designated areas saltmarsh and modified grassland of Pegwell Bay will commence outside the months
that peak numbers of birds using the intertidal and saltmarsh habitats are present (October to February for lapwing, golden plover,
turnstone and grey plover and May for turnstone, sanderling and grey plover). Cable installation works within the intertidal and saltmarsh
areas will not be undertaken during this period. This will also apply to any cable installation works within 50m of the seaward edge of the
381
Mitigation Schedule
Country Park to prevent disturbance from the use of machinery on the edge of the park.
In the event of delays resulting in the cable installation works within the intertidal area extending into the sensitive period for wintering
birds, further mitigation will be supplied. Where possible, wooden hoarding will be used to visually screen the works from birds using the
bay. For the duration of the extended working period an additional warden will be supplied to help deter members of the public entering
the intertidal area during works.
Cable installation within this area will be undertaken following a Method Statement produced in consultation with KWT and NE.
Breeding Birds including Redshank
Installation of the onshore cable, TJP and subsea cable within the saltmarsh habitats north of the Country Park will be phased to avoid
the peak nesting period for species, such as redshank, that use the saltmarsh habitats for nesting purposes (Mid April to July). During
this period no works will be undertaken within 100m of the pool within the saltmarsh habitats to avoid disturbance to nesting redshank.
Prior to the commencement of works within the saltmarsh habitats, a walkover survey will be undertaken to determine the presence of
any active nests and if necessary works will be postponed until nests are no longer active. Methods used during this survey and works
within the saltmarsh will be detailed in a Method Statement.
Removal of vegetation for cables installation within Pegwell Bay Country Park and Stonelees Nature Reserve will be undertaken outside
of the bird nesting season (March-August inclusive) or will be preceded by an inspection by an ecologist for active nests immediately
prior to vegetation removal.
Removal of vegetation within the converter station and substation site will be undertaken outside of the bird nesting season (MarchAugust inclusive) or will be preceded by an inspection by an ecologist for active nests immediately prior to vegetation removal.
Replacement planting within the converter station and substation site will replace nesting habitat removed prior to the start of the
development.
Protected Flora
Pre-commencement surveys of the cable route will be undertaken to identify any protected species of flora within the working area. In
the event that any protected plants are discovered, these plants will either be fenced out of the working area or transplanted to
undisturbed locations as appropriate to their requirements. Where practical, measures will be implemented to encourage recolonisation
of the working areas by these species (e.g. seed selection). These methods will be detailed within Method Statements covering the
working methods of cable installation.
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Mitigation Schedule
Natterjack Toads
A licence will be obtained from Natural England to allow the cable installation works that may affect suitable natterjack toad habitats
within 500m of the reintroduction site within Stonelees Nature Reserve. As part of the licence application, a Method Statement will be
produced in consultation with KWT and NE. The details of the licence will be determined during the licence application process, but are
likely to include a combination of the timing of works to avoid disturbance to potential hibernation features during the winter months (NovFeb), habitat management and controls to reduce disturbance effects and translocation. Arisings from the trench excavation works can
be used to create suitable amphibian refugia, following agreements with KWT and NE.
Reptiles
A repeat survey of suitable reptile habitats will be undertaken prior to the cable installation works. This information will be used to
produce a reptile Method Statement detailing the methods that will be used to install cables within these areas and the locations of these
methods. The Method Statement will be produced in consultation with Kent Wildlife Trust.
Vegetation within areas affected by works between Pegwell Bay Country Park and the TJP and within Pegwell Bay Country Park and
Stonelees Nature Reserve will be managed prior to works to degrade habitat suitable for use by reptiles. Potential refugia will also be
removed from the working area and placed within suitable undisturbed habitats. Vegetation removal will be implemented outside of the
bird nesting period (March to August inclusive) or will be subject to inspections by an ecologist prior to removal. Habitat management
and cable installation will be undertaken between April and September when reptiles are most active due to higher temperatures.
Following completion of cable installation the ground will be reinstated either through seeding the chalk bunds in the north of the Country
Park or by replacing original topsoil where excavations have taken place.
Arisings from the excavation works can be used to create reptile refugia in suitable undisturbed areas of the Country Park.
Bats
The converter station and substation external lighting scheme would typically only be used for emergencies and during maintenance
activities required outside hours of daylight. This will ensure that potential bat foraging and commuting habitats are not detrimentally
affected.
Watercourses, Ditches and Water Vole
The working area for cables installation within Stonelees Nature Reserve will be maintained as a minimum of 5m from the ditch that runs
parallel to the proposed onshore cable route. This will avoid disturbing any water voles that may be present within the ditch.
River Stour, European Eel, Atlantic Salmon and River Lamprey
383
Mitigation Schedule
The converter station and substation external lighting scheme would typically only be used for emergencies and during maintenance
activities required outside hours of daylight. This will ensure that fish migration along the River Stour is not detrimentally affected.
Archaeology and Cultural Heritage
Mitigation with regard to cables installation via open trenching is proposed for predicted impacts to the post-medieval coastguard station
(RSK HM1) in the form of a watching brief during construction works. A watching brief will also be maintained during the cable
installation to ensure that any previously unrecorded archaeological remains are identified and recorded during groundworks.
A watching brief with regard to Pleistocene and Palaeolithic remains will be undertaken during any deep excavations (i.e. excavations
beyond the modern overburden) related to the scheme. Both phases of the watching brief would be undertaken in line with a Written
Scheme of Investigation agreed with KCC in advance of the fieldwork, and followed by a programme of analysis and reporting also to be
agreed with and delivered with KCC.
Landscape and Views
The mitigation of likely construction effects on landscape and views would be largely achieved through the implementation of a
Construction Environmental Management Plan which would include the following measures:
 Protection of trees to be retained to BS 5837 (2005), for the duration of the construction works;
 Screening on-site activity where practical whilst at the same time not being a highly negative visual distraction in itself;
 Management of site traffic to and from site, minimising excessive traffic movement on the surrounding road network; and
 Management of working times to minimise visual effects of construction in evenings and at weekends when residential and
sports and leisure receptors may be most likely to be present.
The mitigation of likely long-term effects on landscape and views would be largely achieved through the following measures:
 The use of colour graded cladding to the converter station building, ranging from a muted green at the building’s base to
off-white at the roofline. This will minimise landscape and visual effects and particularly the effect on views where the
building sits on the horizon. Due to its lower height the substation building will be clad in a single colour (muted green);
and
 Tree and shrub planting proposed on the western boundary of the converter station and substation site to partly filter and
screen some views of the converter station from the west and northwest (in particular from the Saxon Shore Way and from
River Stour) and to filter and screen views of the substation proposals from the south (in particular from the Saxon Shore
Way).
The wider proposals for Richborough Energy Park include the implementation of new planting as part of a separate but closely related
planning application for a new perimeter site road. Planting proposals will include replacement tree planting along the eastern and north
eastern site boundaries (partly mitigating trees loss to accommodate the new road), new native trees, shrubs and fruit trees near the site
384
Mitigation Schedule
entrance, existing trees and shrubs on the northern site boundary being retained and enhanced with new native tree planting, and new
native trees and shrubs along part of the sites western boundary adjacent the River Stour in front of new fencing.
Traffic and Transport
During construction, wheel washing facilities will be provided both at the main site entrance and also the vehicular entrance to the
construction compound located at the Country Park. This will ensure mud/debris is not deposited on the surrounding carriageway. All
HGVs will be covered and sheeted as appropriate.
Mitigation measures will also include the introduction of delivery management strategies to ensure that HGVs travel outside of peak
periods where possible, avoid sensitive residential areas and stick to agreed routing plans.
Appropriate road signage will be provided as required; suitable signage will be placed within the Country Park to inform local users.
Details of the proposed mitigation strategy would be developed in detail during the preparation of a Transport Management Plan.
Abnormal load movements mitigation measures include:
 Police escorts and delivery programmes timed to cause minimal disruption;
 Vehicles will be marked as abnormal or long vehicles and where necessary temporary warning signs will be placed at required
locations along the roads being used by site traffic; and
 It is also proposed to undertake a full condition survey before and after the delivery of any abnormal load. The condition of the
carriageway will be reinstated to the same or better condition following the use of the route.
Noise and Vibration
Best practice construction noise methods will be used to minimise noise associated with cables installation and construction of the
substation and converter station, to include:






Site vehicles will not be over revved, or left with engines idling in close proximity to residential neighbours;
All plant and machinery to be properly maintained and silenced in accordance with manufacturer’s instructions;
Development of a Construction Management Plan detailing the mitigation to be implemented throughout each stage of
construction;
Regular communication with residents living close to the cables route and converter station and substation site. The
communication will include details of expected work schedules and activities taking place, and contact details in case of query or
complaint;
Screening of HDD noise emission points using layout of temporary structures (such as site offices) and hoarding; and
Where cabling works pass within 20m of properties pre and post construction building surveying will be undertaken. Vibration
385
Mitigation Schedule
monitoring will be undertaken at the start of the construction works to more accurately quantify the risk of vibration generated by
each stage of the works giving rise to a significant impact at varying distances. This data will be used, if necessary, to modify the
distance from the route at which building surveys are triggered.
Mitigation will be incorporated into the design of the converter station and substation to ensure that the noise target (assessed noise
levels no higher than the background noise levels) is achieved.
Prior to commencement of works on the converter station and substation, modelling will be undertaken on the final design and layout of
the plant to verify that the above condition is met. Sound power levels can be reduced through design, selection of equipment and by
employing mitigation measures, which could include:
Substation
 TCRs housed within noise shields or full noise enclosures;
 Noise shields to harmonic filters;
 Enclosures around the SCT and SGTs; and
 Low noise fans, silencers on cooling fans or barriers around cooling fans.
Converter Station
 Enclosures around the Shunt Reactor and converter station transformers; and
 Low noise fans, silencers on cooling fans or barriers around cooling fans.
Air Quality
The following mitigation measures will be implemented where appropriate (depending on the construction phase being undertaken at that
time):
 All vehicles will be required to adhere to site speed limits which will be designed to minimise on site dust generation;
 Limitation of vehicle movements during cables installation to the working width wherever possible;
 All plant equipment will be correctly adjusted and maintained to minimise emissions;
 Materials recycling will reduce the extent of off-site disposal and the use of fresh materials, thus reducing the need to load,
unload and transport potentially dust gathering materials;
 Minimisation of dust generation from the loading of trucks. The potential for dust generation associated with the transfer of
materials on to vehicles can be controlled by the wetting of very fine or dry materials and the minimisation of drop heights;
 Covering lorries carrying potentially dust generating materials;
 Where necessary, materials stored on site will be wetted, covered or profiled to minimise dust generation by the wind. Storage
areas will be sited away from potentially sensitive receptors where practicable;
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Mitigation Schedule
 Stationary equipment with the potential for dust generation (such as soil sieving equipment) will be sited away from sensitive
receptors. Where dust generating operations are near to sensitive receptors, enclosures will be provided if appropriate;
 Access roads and crossing points of highways along the route will be swept periodically to remove dust from hard surfaces;
 Unsurfaced working areas will be watered when necessary (such as during prolonged periods of dry weather) to maintain
moisture content and hence reduce dust generation;
 Vehicle wheel washes will be used at the site exits;
 Visual site inspections will be undertaken to ensure that the build-up of materials with the potential to generate dust on site is
prevented;
 Prompt reinstatement of topsoil and vegetation upon completion of construction to minimise risk of windblown dust;
 Limited predetermined areas for construction workers parking, from which workers will be transported to the active construction
section; and
 All plant will be switched off when not in use for long periods.
Coastal Tourism, Recreation and Socio-Economics
During installation of the onshore underground cables, access to the Viking Trail and Thanet Coastal Path will be retained where
possible. Where there is a Health and Safety requirement to prevent or reduce access, appropriately signed diversions will be put in
place. Any restriction on access will be minimised and limited only to periods of major construction activity such as earthworks.
Temporary signage advising visitors of construction activities will be erected. This will include signs within the car park of Pegwell Bay
Country Park to ensure that visitors are aware of construction activities being undertaken.
To minimise construction disturbance, working hours during periods where recreational activity is greatest (i.e. evenings and weekends),
will be limited as much as possible.
All land take associated with cables installation will be reinstated following completion of cable laying activities so will not adversely affect
future recreational land use.
The creation of chalk grassland habitat within Pegwell Bay Country Park will enhance botanical biodiversity and increase the wildlife
amenity for visitors.
Arboricultural Implications
Tree surgery works to T48, T60, G3, G6, G13, G24 and G38 will be discussed and agreed with each Council’s Arboricultural Officer.
To reinforce the required tree protection measures and avoid the requirement for ongoing arboricultural supervision a pre-start meeting
will be arranged between the site contractor, a qualified Arboricultural Consultant and each Council’s Arboricultural Officer.
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Mitigation Schedule
During the meeting the alignment of protective fencing will be confirmed and trees for removal and retention within woodland plantation
groups will be marked. Special construction methods around T50 and T51 and around the chalk capping area will also be discussed
prior to the production of an Arboricultural Method Statement.
An Arboricultural Method Statement will be produced to cover site access and movements, tree removals, works within Root Protection
Areas and other tree protection measures.
In the northern part of the Country Park, the cables will be covered with a chalk capping layer and seeded with approved seed mix (local
seed will be used where available). The chalk capping will cover a length of approximately 477m (area of approximately 0.46ha) and will
improve the vegetation and biodiversity interest of Pegwell Bay Country Park. This is consistent with the approach to management that
has been undertaken favouring the establishment of chalk grassland (rather than extensive tree planting.
Offsite planting is proposed on land at the south west boundary of the proposed converter station and substation site. This will occupy an
area of approximately 0.12ha and will comprise a native woodland mix including Crataegus monogyna, Prunus spinosa and Corylus
avellana. This area will also incorporate approximately 77nr. Lombardy Poplar (TBC and subject to agreement with the local planning
authorities) to provide screen planting similar to existing planting at the northern boundary of the proposed converter station and
substation site. The planting schedule will be established during the construction phase and subject to a long term management plan.
388
Conclusions
18.31
The construction of the Nemo Link is in accordance with European Union and UK
policy to increase transmission capacity between countries and to ensure robust
electricity supplies. A UK-Belgium interconnector will provide enhanced
opportunities for the UK to trade with wider European power markets.
18.32
The construction and operation of the proposed development will not give rise to
any significant long term effects. Any impacts identified as part of the assessment
are considered to be localised and temporary and appropriate mitigation measures
will be implemented to avoid, offset or reduce impacts.
18.33
The table below provides a summary of the residual environmental effects of the
proposed UK onshore elements of the Nemo Link to which this application relates.
Table 18.2: Summary of EIA Results
SUMMARY OF EIA RESULTS
Topic Area
Residual Effects*
Construction
Land Use
Minor Adverse
Ground Conditions and
No Effect
Contamination
Hydrology and Flood Risk Minor Adverse
Ecology
Minor Adverse-Minor
Beneficial
Archaeology and Cultural
Low/Negligible
Heritage
Landscape
Moderate Adverse
Views
Moderate/Minor Adverse
Traffic and Transport
Noise
Air Quality
Coastal Tourism,
Recreation and SocioEconomics
Electric and Magnetic
Fields
Minor Adverse
Moderate
Negligible
Minor Adverse-Minor
Beneficial
No Effect
Operation
No Effect
No Effect
Minor Adverse
Negligible
No Effect
Minor Adverse
Moderate/Minor
Adverse
Negligible
Minor
No Effect
No Effect
No Effect
* Summarises residual effects on the basis of the ‘worst’ or most significant effect identified.
389
390
GLOSSARY AND ABBREVIATIONS
Alternating Current (AC)
An electric current that reverses its direction at regularly
recurring intervals.
Ancient Woodland
Ancient woodland is designated as being land which has been
continuously wooded since AD1600 in England and Wales or
AD 1750 in Scotland.
Area of Outstanding
Natural Beauty (AONB)
Areas of special landscape character and value, of national
importance. Such areas are considered to represent
landscapes of high sensitivity. Their care has been entrusted
to local authorities, organisations, community groups and the
individuals who live and work within them or who value them.
Baseline
A standard by which things are measured or compared.
Biodiversity Action Plan
(BAP)
A set of future actions that will lead to the conservation
enhancement of biodiversity.
Cable Ducts
Pipe through which cables are drawn.
Cable Drums
Reel on which a cable is kept and for transportation.
Climate Change
A term used to refer to all forms of climate inconsistency but
especially change from one prevailing climatic condition to
another. The term is usually used synonymously with the term
global warming.
Combined Heat and
Power (CHP)
A plant designed to produce both heat and electricity from a
single heat source.
Conservation Areas
A local designation of area of land and buildings of special
architectural or historic interest, the character or appearance of
which local authorities consider should be preserved or
enhanced.
Construction
Environmental
Management Plan
(CEMP)
Converter Station
Document which sets out a variety of control measures for
managing the potential environmental effects of construction
works including control and management of noise, dust,
surface water runoff, waste and pollution control.
Terminal equipment for high voltage direct current
transmission line in which direct current is converted into
alternating current and vice versa.
Converter Transformers
These change AC voltage to an appropriate level for
conversion within a valve hall.
Current
A flow of electrons in an electrical conductor.
391
Development Plan
A document setting out the local planning authority’s policies
and proposals for the development and use of land and
buildings on the authority area. It includes unitary, structure
and local plans prepared under transitional arrangements and
development plan documents prepared under the Planning
and Compulsory Purchase Act 2004.
Dewatering
Removing water from a system.
Department for Energy
and Climate Change
(DECC)
DECC is a British Government department which brings
together the work of the Climate Change Group, previously
housed within the Department for Environment, Food and
Rural Affairs (Defra), with the Energy Group from the
Department for Business, Enterprise and Regulatory Reform
(BERR).
Direct Current (DC)
The unidirectional flow of electric charge.
Discharge
To release water into a natural or manmade system.
Distribution System
The portion of the transmission and facilities of an electric
system that is dedicated to delivering electric energy to the end
user.
Disturbance
A variation in normal conditions.
Dust
Dust is made up of solid particles between 1 and 75 microns in
size. The term is used to describe particles resting on the
ground or other surfaces that can become airborne before
returning to the surface.
Electromagnetic Field
(EMF)
A physical field produced by electrically charged objects.
English Heritage
The Government’s statutory adviser on the historic
environment.
Environmental Clerk of
Works
Also referred to as the Site Environmental Manager (SEM).
Person appointed to be responsible for the preparation and
implementation of the CEMP and ensuring that mitigation
measures identified are appropriately implemented.
Environment Agency
Executive non-departmental public body responsible to the
sectary of state for the environment, food and rural affairs.
Environmental Impact
Assessment (EIA)
A statutory assessment of the possible positive or negative
impact that a proposed project may have on the environment,
together consisting of the natural, social and economic
aspects.
Environmental Statement
Document containing the findings of the Environmental Impact
392
(ES)
Assessment (EIA).
Fauna
All of the animals found in a given area.
Flora
All plant life found in a given area.
Habitat
Ecological or environmental areas that is inhabited by a
particular species of animal, plant or other type of organism.
Horizontal Directional
Drilling (HDD)
The drilling of non-vertical wells for the installation of
underground cables.
High Voltage Direct
Current (HVDC)
Cable transmitting direct current bulk electrical power, typically
over long distances.
Infrastructure Planning
Commission
An independent body that examines applications for nationally
significant infrastructure projects.
Interconnector
HVDC cable linking two separate transmission systems.
Joint Nature
Conservation Committee
(JNCC)
A public body that advises the UK Government and devolved
administrations on IK wide and international nature
conservation.
Landfall
A cable landing point, where a submarine cable joins the land.
Landscape Character
Assessment
This is an approach to understanding the differences between
landscapes, and can serve as a framework for decisionmaking that respects the local distinctiveness.
Listed Building
A building of special architectural or historic interest.
Local Biodiversity Action
Plan (LBAP)
Outline the actions to be taken at a local level.
Local Development
Frameworks (LDF)
A non-statutory term used to describe a folder of documents,
which includes all the local planning authorities’ local
development documents.
Local Nature Reserves
(LNR)
Sites with wildlife or geological features that are of a special
interest locally.
Local Planning
Authorities
The local authority or Council that is empowered by law to
exercise planning functions.
Marine Cable Route
Proposed marine part of the project which includes the marine
cable route from the UK to Belgium through UK, French and
Belgian waters.
Mitigation
Measures and actions taken to minimise, reduce, remedy
and/or compensate for the adverse impacts of development.
393
Natural England
Independent public body whose purpose is to protect and
improve England’s natural environment.
Permitted Development
Rights to carry out certain limited forms of development without
the need to make an application for planning permission.
Planning Permission
Formal approval sought from a Council, often granted with
conditions, allowing a proposed development to proceed.
Power Station
Facility for the generation of power/electricity.
Public Right of Way
(PROW)
The most widely known right to cross private land is known as
a 'right of way'. If this is a right granted to everyone it is a
'public right of way'.
Ramsar
Wetland sites that are protected under the Conservation of
Wetlands (Ramsar, 1971) called the Ramsar Convention. It is
an intergovernmental treaty that embodies the commitments of
its member states to maintain the ecological character of their
Wetlands of International Importance.
Renewable Energy
Energy resources that are naturally replenishing.
Scheduled Monuments
These are monuments which range from the prehistoric
standing stones, burial mounds, through to many types of
medieval site, castles, monasteries, abandoned farmsteads
and villages to the more recent results of human activity such
as colliers that are of national importance.
Site Environmental
Manager
Also referred to as the Environmental Clerk of Works (ECoW).
Person appointed to be responsible for the preparation and
implementation of the CEMP and ensuring that mitigation
measures are appropriately implemented.
Sites of Biological
Importance
Non statutory designations used locally by a number of local
authorities in England.
Sites of Importance to
Nature Conservation
(SINC)
Sites applied to areas of most importance for nature
conservation within a local authority area in England.
Species
A group of interbreeding organisms that seldom or never
interbreed with individuals in other such groups, under natural
conditions.
Special Area of
Conservation (SAC)
Strictly protected sites designated under the EC Habitats
Directive.
Special Protection Area
(SPA)
Strictly protected sites classified in accordance with Article 4 of
the EC Birds Directive which came into force in April 1979.
394
Outline Waste
Management Plan
Document prepared by the Contractor in consultation with
XXXX which details how waste will be managed during
construction of the development.
Sites of Special Scientific The country’s very best wildlife and geological sites.
Interest (SSSI)
Subsea
Technology and methods employed for cable installation in the
marine environment.
Substation
Facility equipment that switches, changes, or regulates
electricity voltage.
Transformer
An electrical device for changing the voltage of an alternating
current.
Transmission
The movement or transfer of electric energy over an
interconnected group of lines and associated equipment
between points of supply and points at which it is transformed
for delivery to consumers or is delivered to other electric
systems. Transmission is considered to end when energy is
transformed for distribution to the consumer.
Transition Joint Pit
Transmission System
Area within which two sections of cable are joined together.
An interconnected group of electrical transmission lines and
associated equipment for moving or transferring electric
energy in bulk between points of supply and points as which it
is transformed for delivery over the distribution system lines to
consumers or is delivered to other electrical systems.
Transport Management
Plan
Document which sets out a variety of control measures for
managing the potential transport effects during the
construction period.
A mechanism for securing the preservation of single or groups
of trees of acknowledged amenity value. A tree that is subject
to an order may not normally be topped, lopped or felled
without the consent of the Local Planning Authority.
Tree Preservation Orders
(TPOs)
Trunk Road
Strategic or major road usually containing high volumes of
heavy goods vehicles.
Valve Halls
Contain power electronics equipment that converts from AC to
DC (or vice versa).
Voltage
The difference in electrical potential between any two
conductors or between a conductor and ground. It is measure
of the electric energy per electron that electrons can acquire
and/or give up as they move between the two conductors.
Water Framework
European Union directive which commits European Union
395
Directive (WFD)
member states to achieve good qualitative and quantitative
status of all water bodies (including marine waters up to one
nautical mile from shore) by 2015. It is a framework in the
sense that it prescribes steps to reach the common goal rather
than adopting the more traditional limit value approach.
World Heritage Site
(WHS)
A cultural or natural site of outstanding universal value
designated by the International Council on Monuments and
Sites (ICOMOS)
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