Galloper Offshore Wind Farm

Representations received regarding Galloper Offshore Wind Farm

The list below includes all those who registered to put their case on Galloper Offshore Wind Farm and their relevant representations.

SourceRepresentation - click on an item to see more details
Non-Statutory Organisations
Royal Yachting Association
"I wish to submit a written representation later to outline the RYA concerns with the proposal to apply for a declaration of a 50m safety zone during the operational phase of the windfarm for all vessels irrespective of thier size and the activity for which they are being used. A blanket exclusion is not supported by the navigational risk assessment which supports the environmental statement. Please paste the following hyperlink into your browser to view the appendix for this representation:- http://infrastructure.independent.gov.uk/wp-content/uploads/2012/02/120221_EN010003-_Galloper-Safety-Zone-Letter.pdf"
Public & Businesses
Stuart Maggs
"We are concerned regarding the flow of traffic to and from the proposed onshore works for Galloper Wind Farm at Sizewell. The junction between King George's Avenue and Lover's Lane in Leiston is extremely busy at peak times, and due to the natural flow of the roads the traffic moving along Lover's Lane is invariably moving extremely swiftly. This leads to a significant risk to road-users trying to pull into and out of the junction which is especially high when considering the breaking distances required for laden heavy goods vehicles. It also poses a real risk to the numerous pedestrians who regularly use the narrow footpath by Lovers Lane, who are then required to cross the road along which numerous additional trucks and cars will be thundering. In light of this we would strongly advocate the imposition of monitored and enforced speed limits around the junction to minimise the additional risk posed by the significant increase in heavy traffic throughout the duration of the build. Comments regarding traffic management and control throughout the documentation about securing best practice have failed to take into account any margin for the actuality of human nature, and the amount by which this invariably falls short of best practice. Once this margin is introduced it becomes clear that the impact on traffic and amenity at this road junction becomes significant rather than marginal. In addition we are concerned about the level of noise that will arise as a result of laden construction vehicles on the one hand, and unladen vehicles leaving the site on the other. Both of these pose their own risks and the deleterious effect that will have on the reasonable enjoyment of our property will again be significant. Unless and until a more realistic impact assessment on the area, allowing for human error and the vagaries of life, is performed and relevant and proportionate measures introduced to mitigate the effect of the huge amount of traffic required to complete this project, we must strongly object to it. In line with the terms on the submission form this is merely an outline of our concerns, and we are happy to provide specific information as required."
Public & Businesses
Paul Norman
"I am writing as you requested to lodge my concerns over this development both from a personal point of view ref my business – Trya Charters, and also the potential ecological effects on the marine environment. I run a Sport fishing charter operation from Titchmarsh Marina, Walton on the Naze – Trya Charters. From around the second week of April through to to the end of September I specialise in wreck and Bass fishing, and my area of operation for this activity has always been the area bound by the N Inner Gabbard buoy , east to around 5miles past the Outer gabbard and the South to a line around 2 miles South of the South Galloper Buoy, from here East to 2miles inside the S Galloper buoy. Daily activity is dictated by tide and water clarity and species sought on the day. I have visited the Galloper Wind Farm Website and have grave concerns for my business should the proposal be given planning permission as it will effectively wipe out my ability to trade for the duration of the construction period and potentially lead to my established client base finding alternative areas to fish for the future leaving me high and dry! From mid May through to mid September the principal species sought is Bass. A typical day will consist of ‘jigging’ for bait fish on the Outer Gabbard bank, before drifting the rips to the South in the main( 2-3 miles south of the Outer Gabbard Buoy), but also to the North of the bank – this activity will be effectively ‘killed off’ by the construction of the Galloper Wind Farm. The construction of the Greater Gabbard Farm has already greatly restricted activity closer to home and the signs are that tidal flows have been adversely affected by the installation of the monopiles as the degree of rips that show around the N Inner Gabbard and the S Galloper are considerably less than prior to the construction activity. It has also been noticeable that the wrecks in the local of this site have not yielded anything like the level of fish that inhabited them prior to the commencement of works 2 years ago."
Local Authorities
Leiston-cum-Sizewell Town Council
"The Town Council would wish to be involved in all stages of the examination to ensure our views are presented and noted - our particular interest will be the onshore elements of the project, how they impact on the community and what compensatory packages will be put in place to mitigate the disruption. The community was harshly treated by the concurrent Greater Gabbard project and would wish to ensure that the lessons learnt from that are now absorbed by this new, larger, project."
Other Statutory Consultees
Highways Agency
"The Highways Agency, on behalf of the Secretary of State for Transport, is responsible for operating, maintaining and improving the strategic road network (SRN) in England. We have a duty to safeguard the operation of the SRN as set out in the Department for Transport Circular 02/2007 "Planning and the Strategic Road Network. The Highways Agency's interest is the potential impact of the proposed development on the SRN. Galloper Wind Farm Limited consulted the Agency on the proposal in June 2011. The onshore facility element of the development at Sizewell is some distance from the SRN; the nearest point of contact with the SRN for any traffic associated with the development would be the A14 at Ipswich. The Agency concluded that the impact on the SRN was unlikely to be significant and accordingly had no comment. That remains the Agency's position."
Public & Businesses
Dr T.C.Rogers
"I am a resident of Dovercourt, a community highly adjacent to Harwich International Port which was used as the primary shore base in support of the construction of the Outer Gabbard Windfarm. In general terms I support the construction of infrastructure enabling the harvesting of renewable energy. I wish to be registered as an interested party for the examination of the Galloper Windfarm Proposal and submit the following comments. I have no doubt that the Harwich area benefitted financially, in the short term at least, from the influx of work and workers to the area during the recent construction phase of the Outer Gabbard Windfarm. But there was a local community price to pay. Specifically a large number of vehicles, related to the windfarm work, that were parked for extended periods of time in Harwich Town and to a lesser extent elsewhere. This additional parking had, in my view, a serious detrimental effect on the local community’s ability to go about its normal business and on tourist visitors – essential to the Harwich area’s long term economic future. At the time of writing it is unclear where the construction base for the Galloper Windfarm will be located; possibly Harwich, maybe elsewhere on the East Coast. It is also unclear if the Galloper Windfarm construction methodology will be similar to that used for the construction of the Outer Gabbard Windfarm. As a result the likely level of disruption to the local community of the selected construction base cannot be determined. Whichever construction base is selected warrants, I believe, some protection against the potential harm that could accrue from an increase in vehicle parking during the construction phase of the project. Should the Infrastructure Planning Commission see fit to grant approval to the Galloper Windfarm proposal I would ask that the approval contain conditions to prevent, or at least seriously curtail, the type of disruption that occurred in Harwich."
Local Authorities
Norfolk County Council
"Norfolk County Council welcomes the opportunity to comment on the above proposal. However, given the location of both the offshore proposals and the onshore ancillary works, the Council does not wish to raise any strategic concerns to the overall development."
Non-Statutory Organisations
Robert Charels Butters on behalf of FELIXSTOWE FERRY FULL-TIME FISHERMANS ASSOCIATION
"I am representing the 6 full time commercial fishing vessels which work out of Felixstowe Ferry. Our concers are disruption to our fishing grounds and activities during the building of the windfarm, and once it is built. Particular concern is the loss of fishing grounds on the site of the wind farm, and along the cable route to the shore. Past experiances have shown the cable routes have become un fishable when we have been assured that all areas will be returned to their origional state."
Other Statutory Consultees
Broads Authority
"The windfarm itself is proposed to be sited well outside the Broads Executive Area and as such there should be no visual impacts on this nationally designated landscape. It is the case, however, that the infrastructure requirements for the inland links have not yet been determined and this inland infrastructure, which is essential to support the delivery of power from the proposed wind farm, does have potential to have significant impacts on the Broads."
Public & Businesses
Dave Waldron
"I am a commercial fisherman and have been fishing this particular area for the past 25 years. Where the windfarm will be situated is where I have been fishing and earned a large part of my living. The Inner Gabbard windfarm has already disrupted my fishing activities over the past 2 years and continues to do so. Since this windfarm has been built the fishing has deteriorated. The disturbance of the area has damaged these fishing grounds in my opinion. The Galloper Windfarm will have the same effect if not more so, because it is increasing the area of disruption. I am very concerned because it has affected my income over the past 2 years and this development can only decrease it by more. As a fisherman I am restricted to quotas and days at sea so to maintain these fishinggrounds is very important to me. Although I am all for looking to ways of generating 'green' power, the cost of construction and the amount of power generated does not in my opinion outweigh the disruption of the marine environment."
Public & Businesses
Roy Sadd
"I am just interested on what impact this will have on felixstowe shore line"
Other Statutory Consultees
London Array Ltd
"A letter was sent to the Galloper wind farm commenting on the pre-application documentation. The following recommendation was asked to be included: A 4km Buffer that has been proposed for the displacement effects at Galloper will result in the site being captured in the Appropriate Assessment that will be forth coming for the London Array Phase 2, Kentish Flats Extension and Gunfleet Sands 3. It is suggested that any impact, more than 2km from a protected site is excluded from an incombination assessment. It is recommended therefore, a reduction in the buffer to 1km will result in Galloper being excluded from this assessment. After reading through the Ornithology section of the Environmental Statement, this could not be found to be implemented, and a 4km buffer is still in place. We therefore re-submit our original comment."
Public & Businesses
Terry Woodrow
"My concerns are that the proposed extention of the Galloper wind farm will adversley affect my business as a charter boat skipper as a lot of our fishing is conducted within the extended area"
Non-Statutory Organisations
VisNed (Dutch Demersal Fisheries Organisation)
"The windfarm is being planned in an area which is a rich harvesting ground for our fleets. Our fleets target the high priced flatfish species such as sole, plaice, turbot, brill and lemon sole. Not only will areas be inaccesible for trawls touching the bottom, there is also insufficient knowledge about the influence of cable passages on travel patterns of fish. Fish are sensitive to the slightest distrubance, be it temperature, noise, vibrations, magnetic fields generated by cables etc. Until now we are unaware of posssibilities or impossibilites to fish within the park and which mitigating measueres will be taken to prevent negative inpact of disturbances of the habitat of the fish. We would like to communicate on these issues directly with the developer."
Other Statutory Consultees
Health Protection Agency
"At the scoping phase for the project HPA requested that the applicant conduct the assessment of compliance with the referenced Wind Farm Position Statement. The submission is specifically related to its remit in non-ionising radiation and chemicals, and is based on the information contained within the application documents. In respect of the human health impact of electric and magnetic fields (EMFs) HPA has reviewed Chapter 28 of the Environmental Statement (ES), which assesses the potential human health impacts associated with EMFs produced by the onshore electricity transmission and distribution assets of the proposed Galloper Wind Farm (GWF). HPA is satisfied that the applicant has demonstrated compliance with the ICNIRP guidelines and therefore no additional comments are necessary from the standpoint of the health impact of EMFs produced by the proposed wind farm."
Non-Statutory Organisations
Orford and District Inshore Fishermen's Association
"The Orford and District Inshore Fishermen's Association represents the interests of its members in any activity that may impact, whether positively or negatively, their traditional and licensed rights to fish in the waters around the coast of the United Kingdom."
Local Authorities
Maldon District Council
"I write to advise you that officers have undertaken a consultation process with Councillors regarding the proposal and Maldon District Council’s consultation response is as follows: Having reviewed the Environmental Statement this covers all the relevant material planning considerations which need to be analysed as part of the application process for development requiring an Environmental Impact Assessment, in accordance with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009. With regard to the impact upon this District: • The distance from the wind farm to the Council’s nearest point is approximately 100km to the north east of Bradwell on Sea. When looking towards this direction the Gunfleet Sands wind farm would partially screen the Galloper wind farm, and given the distances involved it is considered that the Galloper wind farm is unlikely to be readily visible from this District. However, there are concerns that the wind farm would fall within the Suffolk Heritage Coastal Designation and therefore impact upon this coastal designation • There are concerns over the cumulative noise impact of this wind farm and the Gun Fleet Sands wind farm There are no other comments to make with regard to the other material considerations which statutory and non-statutory consultees will advise on. I hope this information is of assistance and confirms this Council’s position."
Non-Statutory Organisations
The Royal Society for the Protection of Birds
"The existing Greater Gabbard offshore windfarm and the proposed Galloper extension lie in proximity to a number of Special Protection Areas (SPA) and Ramsar sites, as designated under Article 4 (1) and 4 (2) of the EU Directive on the Conservation of Wild Birds (2009/147/EC), and listed under the Ramsar Convention on wetlands of international importance (1971), respectively. Our main concerns relate to the risk posed to SPA and Ramsar species both from this project alone and in combination with other projects. For example, one of our primary concerns relates to the significant collision risk posed to lesser black-backed gulls of the Alde-Ore Estuary SPA both alone and in-combination with other projects. However, whilst we welcome provision of relevant environmental information by Galloper Wind Farm Limited (GWFL) we have a number of concerns about the adequacy of this information and/or its analysis and assessment. For example, in addition to our concern relating to lesser black-backed gulls referred to above, we also have concerns relating to the adequacy of the analysis and assessment of potential cumulative disturbance and collision impacts on red-throated divers of the Outer Thames Estuary SPA, and of cumulative collision risk to gannets of the Flamborough Head and Bempton Cliffs SPA. The RSPB has been involved in pre-application discussions organised by GWFL and provided initial written comments on draft ornithological information. From our initial review of the submission documents, we are unable to confirm that our concerns have been addressed. However, we will continue discussions with GWFL with a view to resolving these concerns, where possible, and to ensure that robust evidence is submitted to the IPC. We may wish to submit and/or present further evidence if appropriate and appear at any hearings the IPC may wish to convene on the matters of concern to us, should this be necessary. We reserve the right to add to and/or amend our position in light of any new information submitted by GWFL."
Other Statutory Consultees
English Heritage
"English Heritage is the Government’s advisor on all aspects of the historic environment in England. English Heritage is an Executive Non-departmental Public Body sponsored by the Department for Culture, Media and Sport (DCMS) and we report to Parliament through the Secretary of State for Culture, Media and Sport. The National Heritage Act (2002) enabled English Heritage to assume responsibility for maritime archaeology in the English area of the UK Territorial Sea. However, for development projects that occur in any adjacent area of UK Continental Shelf any advice that we offer is done so without prejudice to our responsibilities. We have reviewed ‘Galloper Wind Farm Project – Environmental Statement’, prepared by RWE npower renewables and SSE Renewables (dated October 2011) and we offer the following comments: Chapter 19 Archaeology and Cultural Heritage (dated October 2011, Document Reference 5.2.19): Onshore historic environment Following successful pre-application consultations with English Heritage and the County Archaeological Service we are satisfied that an adequate desktop assessment has been completed and that part of the development site has been subject to field evaluation with the results incorporated into the application. We are satisfied that the scheme is unlikely to have a significant detrimental impact on the setting of nationally designated heritage assets. Whilst there is a need for further archaeological evaluation we feel that this can be undertaken in advance of construction if consent is granted for the scheme as it is unlikely, based on the work to date, that nationally important heritage assets will be affected and there should be adequate flexibility to avoid or protect remains in the unevaluated areas including the temporary construction areas as opposed to the substation site. We advise that in accordance with national policy guidelines (Policy HE12.3 of PPS5) planning conditions to record and advance the understanding of the significance of the heritage asset before they damaged or destroyed should be conditional of any consents for the scheme. Offshore historic environment The preparation of the Archaeological Written Scheme of Investigation (WSI), in agreement with English Heritage (and any relevant local authority), is very important and we direct your attention to Model Clauses for Archaeological Written Schemes of Investigation: offshore renewables projects published by The Crown Estate in December 2010. Please note that a WSI provides an agreed statement on methodologies for subsequent data analysis and interpretation and we recommend that the WSI is prepared by a body affiliated to a professional association, such as the Institute for Archaeology. It is particularly important that any desk-based review of available records is corroborated by data obtained from any geotechnical and geophysical surveying campaign commissioned for this project. For example, archaeological interpretation of geophysical survey data to inform the installation programme so that if any floating barge or jack-up barges are employed using an anchor spread they do not impact any sites or other anomalies of archaeological potential. We noted that reference was made to Archaeological Exclusion Zones (AEZs) as a mitigation measure and, subject to the final design for this project, we expect further discussion regarding selection of AEZs, as described in Technical Appendix Report 19.B (Marine Archaeological Study), and associated monitoring requirements to support their effective identification, assessment and avoidance, as per the terms of the draft deemed Marine Licence. We only accept that any residual impacts might be of ‘negligible significance’ if the developer ensures that copies of any agreed archaeological assessment reports are deposited with the National Monuments Record; this requirement is completed by submitting an English Heritage OASIS (Online AccesS to the Index of archaeological investigationS’) form with a digital copy of the report. Notification of the completion of the OASIS form is to be sent, by the developer, to the relevant local authority for any aspect of this project that occurs within the boundaries of a terrestrial local planning authority. Similarly, the statement made in 19.10.14 regarding cumulative benefits of offshore development can only be realised if that information, once accepted, is placed in the public realm, as per the terms of the draft deemed Marine Licence. We noted that particular attention was directed at ‘known archaeological sites and geophysical anomalies of potential anthropogenic origin’, but this does not adequately address cumulative development pressures on palaeo-environment features and elements that may contain archaeological material, as detailed in sections 19.4.38 to 19.4.48 (see also figure 19.7) and in Appendix 19.B. However, such matters should be addressed through the production and delivery of an agreed WSI and the application of an Archaeological Reporting Protocol so that appropriate action is taken if the project encounters any unidentified archaeological sites or other material of archaeological interest. Technical Appendix 4, Report 19.B – Galloper Wind Farm Project Environmental Statement Technical Report: Archaeology and Cultural Heritage – Marine Archaeology Study. Prepared by Wessex Archaeology (Ref: 66803.05, dated September 2011). We noted the detail provided in Table 10 (‘worst case project design for archaeology) and section 5 (potential impacts during construction phase) which should be addressed by the WSI to be prepared for this project. We are prepared to accept the statement made in 5.5.4 regarding the placement of 100m buffers around identified sites of potential archaeological interest, although we require clarification about how the buffer will be drawn in reference to the different design scenarios, and how the final scheme layout will take account of these buffers (see 5.5.5 and Figures 15 and 16). We also concur with the statements made in 9.1.18 in reference to the ‘complete recovery of cores to aid interpretation of the palaeochannels identified during assessment…’ and we must also draw your attention to a statement made in 9.1.19 in regard to ‘a scheme specific WSI’ to be produced and delivered in agreement with English Heritage, as per the terms of the draft deemed Marine Licence. Draft Development Consent Order (including deemed Marine Licence), dated November 2011 (Document Reference: 3.1) – We support the terms of the draft deemed Marine Licence as set out in Schedule 6, Part 2 (Conditions) which are necessary to deliver the required mitigation measures as identified by the Environmental Statement prepared for this proposed project."
Non-Statutory Organisations
Manston Airport
"We are grateful to have been consulted by the developer prior to this application being submitted and note that our response to them was that Manston Airport would be unlikely to object to this proposal. It was our initial finding that this wind farm would be fully visible to our primary radar and paint an area of clutter on our display screens, however, this would be unlikely to have operational significance given it's location and distance from Manston. This was given as a preliminary non-binding view only and we would only confirm our position following consultation on the final site design. We do though wish to be registered as an interested party so that we may be kept apprised of developments in the event that our position has to be reviewed."
Non-Statutory Organisations
Ministry of Defence
"I am writing to advise you that the Ministry of Defence has no objection to the above proposal at this time on the basis that there will be an unspecified number of turbines with a height to blade tip of 195m. The turbines will be located within the boundaries of an area defined by the following coordinates 1 TM 73383 40655 2 TM 74263 41250 3 TM 75152 41823 4 TM 76032 42417 5 TM 76032 42417 6 TM 84745 35720 7 TM 84447 34724 8 TM 84173 33731 9 TM 83228 33299 10 TM 82307 32894 11 TM 81374 32476 12 TM 79841 31231 13 TM 78862 30645 14 TM 77890 30089 15 TM 75048 31901 16 TM 76056 29769 17 TM 75272 32878 18 TM 75534 33858 19 TM 75058 37959 20 TM 73154 39515 21 TM 74695 39514 22 TM 83337 39390 23 TM 84369 37267 24 TM 76968 30183 25 TM 81160 40606 26 TM 80219 40187 27 TM 79564 40749 28 TM 78258 41891 29 TM 78909 41320 30 TM 83992 38819 31 TM 82681 39961 32 TM 75671 31311 33 TM 77044 20940 34 TM 77881 21667 35 TM 76702 17416 36 TM 76721 16445 37 TM 76684 15471 38 TM 76511 18950 39 TM 76099 20545 40 TM 79348 22428 41 TM 85534 17044 42 TM 80279 22861 43 TM 81270 23272 44 TM 82176 23792 45 TM 85471 20821 46 TM 83267 23884 47 TM 85410 23350 48 TM 84079 24500 49 TM 85060 24893 50 TM 82453 16035 51 TM 80308 14239 52 TM 79369 13818 53 TM 78442 13409 54 TM 77503 12998 55 TM 75454 12847 56 TM 74530 12422 57 TM 74877 10876 58 TM 73947 10438 59 TM 73304 11003 60 TM 69495 16978 61 TM 68577 16553 62 TM 69861 15433 63 TM 68282 15573 64 TM 70812 13361 65 TM 67993 14593 66 TM 68611 14037 67 TM 69259 13484 68 TM 69890 12900 69 TM 70550 12347 70 TM 71178 11732 71 TM 85629 18380 If the application is altered in any way we must be consulted again as even the slightest change could unacceptably affect us. It should be noted that this response is based on current levels of wind farm development in the area. Defence Infrastructure Organisation Safeguarding wishes to be consulted and notified of the progression of the planning application to verify that it will not adversely affect defence interest."
Non-Statutory Organisations
East Anglia Offshore Wind
"East Anglia Offshore Wind (EAOW) are developing wind farms in the wider vicinity of the Galloper project and as such there are likely to be cumulative and in combination assessment synergies. EAOW therefore wish to register as an interested party in order to ensure that we understand the common issues relating to our projects and how they may be dealt with during the determination process. In particular EAOW may have useful representations to make in relation cumulative and in combination assessment aspects to facilitate the Galloper Habitats Regulation Assessment. For example, It is unclear within the report(s) if the Galloper project is aware of where East Anglia ONE is located and, as a result, whether our project is factored unnecessarily heavily into to the in-combination assessment with regards the Alde Ore SPA and lesser black-backed gulls. Much of this confusion is from the interpretation of stakeholder gull tagging data that refers to overlap with the East Anglia Zone and this has been, either inconstantly or erroneously, ascribed to East Anglia ONE in some instances. For example the East Anglia ZONE falls within the 40km core foraging range for lesser black-backed gull but East Anglia ONE is not and therefore our first project could be more heavily weighted in the assessment."
Other Statutory Consultees
Jonathan Bower on behalf of EDF Energy Plc
"To view the representation from EDF Energy, please copy and paste this link into your browser; http://infrastructure.independent.gov.uk/wp-content/uploads/2012/02/MX-5000N_20120229_120549.pdf"
Local Authorities
Suffolk County Council
"This submission is made by Suffolk County Council on behalf of itself and Suffolk coastal District Council In principle the local authorities are supportive of the further development of offshore wind energy. They has worked with the applicants for this project to seek to overcome any issues with regard to the landside matters in the pre-application phase. However there are a number of matters which remain unresolved or require further consideration by the Examining Authority (EA). These include: 1. Whether the location for the substation at Sizewell is appropriate, given its location on a greenfield site in an Area of Outstanding Natural Beauty. Alternative sites, either outside the AONB or on brownfield locations had been considered and rejected by the applicants. The EA will need to be clear that no more appropriate location is available; 2. The substation proposal is in a sensitive green area between Sizewell Power Stations and the town of Leiston. The local authorities are still working with the applicants to ensure that the best possible initial and long term landscaping is in place to mitigate the impact; 3. The landscaping will take some time to mature before it can fulfil its function of mitigating the visual impact of the substation development. In the meantime, an AONB Amenity and Accessibility Fund is intended to compensate for the damage caused. The local authorities are not yet convinced that this is adequate to meet the need; 4. The construction phase of the development is likely to have adverse impacts on the highway network and the amenities of local residents. The local authorities need to consider the Requirements to be included in the DCO and the Onshore Outline Construction Code of Practice to ensure that these issues are adequately addressed; 5. The EA will need to be clear that the consequences of having substantial numbers of construction workers on this site adjacent to two nuclear power stations have been fully considered by the Office of Nuclear Regulation and the County Emergency Planning Team. We consider that it is likely some or all of matters 2-4 will have been resolved before the examination is carried out. However we will keep you informed of any such outcomes."
Other Statutory Consultees
Marine Managment Organisation
"GALLOPER OFFSHORE WINDFARM PROJECT BY RWE NPOWER RENEWABLES LTD AND SSE RENEWABLES DEVELOPMENTS IPC APPLICATION AND ASSOCIATED DOCUMENTS The MMO is an interested party for the examination of DCO applications for nationally significant infrastructure projects in the marine area. The MMO has received notice of such an application for Galloper Offshore WindFarm (IPC ref: EN010003). Please find below the MMO’s initial comments on this application. Please note these are only initial comments and the MMO reserves the right to make further comment on this application throughout the examination process. The MMO is interested in this project because it involves installing up to 140 wind turbines, associated developments and cabling within the marine area. The MMO has made an initial assessment of the draft DCO and has the following comments on Schedule 6 for your consideration: 1.The MMO requests that the following condition is added to the DCO: The undertaker must submit a Decommissioning Plan at least 3 months prior to any planned decommissioning works. This plan must be approved in writing by the MMO prior to the commencement of any decommissioning works. 2.The MMO requests that a condition is added to the DCO to state that when disposal of dredge material at sea is planned a separate marine licence must be obtained prior to the commencement of any dredge or disposal works. 3.The MMO requests that a condition is added to part 2 section 15 (2) on page 52 detailing the requirement for the undertaker to conduct pre construction surveys for fish within the windfarm and agreed reference zones to establish a baseline. 4.The MMO requests that a condition is added to part 2 section 17 (2) on page 53 detailing the requirement for the undertaker to conduct post construction surveys of the fish population within the windfarm and agreed reference zones. This is to allow for the assessment of impacts to fish populations. 5.The MMO requests that a condition is added to part 2 section 9 page 49 to state that soft start procedures will be used during any piling event. The soft start duration should be a period of not less than 20 minutes. Should piling cease for a period greater than 10 minutes then the soft start procedure must be repeated. 6.The MMO requests that a condition is added stipulating the minimum burial depth for the inter array and export cables. The MMO would suggest a minimum of 1.5 meters, however, we would also recommend that discussion on the actual depth should take place between MMO, the applicant and relevant navigation authorities. 7.The MMO requests that a condition is added to part 2 section 9 (d) page 50 to state that the environmental management and monitoring plan will include the methodology used to minimise the re-suspension of material during construction or dredging operations. 8.The MMO requests that a condition is added to part 2 section 13 on page 51 to state that all agents, contractors and vessel operators will abide by the conditions of the DCO. 9.The MMO requests that a condition is added to part 2 section 13 on page 51 to state that all vessels operators will abide by the marine pollution contingency plan submitted by the undertaker under part 2 section 9 (d) on page 50. 10.The MMO requests that part 2 section 7 (1) on page 48 is amended to also state that any oil, fuel or chemical spill within the marine environment is reported to the MMO, Marine Pollution Response Team. 11.The MMO requests a condition be added to part 2 section 9 on page 49 stating that the undertaker will submit a document stipulating the best environmental practice referred to in part 2 section 7 (2) page 48. 12.The MMO requests that part 2 section 7 (6) page 49 is amended to state that the audit sheet must be submitted to the MMO for approval and no construction works shall commence until this has been agreed. 13.The MMO requests that part 2 section 15 (3) page 52 is amended to state that the baseline report must be submitted to the MMO 4 months prior to construction and that construction must not commence until the MMO has given written approval of the report. The MMO considers that that sufficient detail has not been provided within the application and Environmental Statement (ES) to assess the impacts from disposal of dredge material. The MMO has advised above a condition requiring the undertaker to obtain a separate marine license for these works. If these works are to be included within the DCO further information will need to be provided and additional conditions added to the DCO. The MMO has made an initial assessment of the ES and the report to inform the Habitats Regulations Assessment. In the opinion of the MMO the ES identified and assessed potential impacts. The ES document is comprehensive, and the Environmental Impact Assessment (EIA) included all the relevant receptors, pathways and potential impacts arising from the construction, operation and decommissioning of Galloper offshore Windfarm, alone and in combination to other developments, with the exception of the disposal of dredge material as noted in our comments above. Yours sincerely Alan Gibson Marine Environment Team Marine Management Organisation"
Other Statutory Consultees
Environment Agency
"After reviewing the Environmental Statement and the supporting Flood Risk Assessment (FRA) we have no objections from a flood risk point of view. First of all we are pleased to see the landfall of the cabling will be south of our flood defences. Therefore no Flood Defence Consent will be required from the Environment agency for this activity. As the site falls within Flood Zone 1 of the Environment Agency flood maps, the site will not be at risk to fluvial or tidal flooding. Surface water disposal from the proposed development has been looked at within the drainage assessment of the FRA. From the calculations provided we are currently content with the methodology and arrangements. We are pleased to see within the draft DCO Part 3 paragraph 24 (1) and (2) the disposal of surface water aspect of this development will be looked at. There are no other matters that we wish to comment on."
Non-Statutory Organisations
National Federation of Fishermen's Organisations
"Insufficient attention is currently paid to elaborating how the developer is to address the residual impacts to the fishing sector. Reference is made to following the best practice guidelines on fisheries liaison and planning, but no details on what this would entail or commitments from the developer are given. We consider these matters to be crucial to securing coexistence with the fishing industry and are a reasonable request given the impacts to fishing operations attributable to this development. In addition, the developer refers to reports that detail generic options for fisheries mitigation but again no detail is offered. We consider that these matters should be addressed as far as possible before licence consent. This should include the preparation of fisheries liaison plan (as per current fisheries liaison best practice guidance) and a fisheries coexistence plan which details approaches to addressing residual impacts and any operational issues to reduce the likelihood of conflict e.g. commitments to procedures for gear retrieval within safety zones. This should be undertaken through engagement with fisheries stakeholders. Appropriate monitoring regime will need to be put in place with adequate baselines to assess EMF and fishery effects. We do not consider that aggregation effects will necessarily occur or be beneficial as implied. Such considerations are likely to be site specific and such generalities cannot be made. Assumptions that fisheries will continue to decline over the duration of the project are poorly informed with regard to the underlying trends in fisheries were many stocks in the North Sea are transitioning to recovery. Such changes will likely support higher levels of fishing activity over the 25 year period of the project."
Other Statutory Consultees
National Grid
"National Grid has been working closely with SSE and RWE NPower Renewables Ltd to make arrangements for connecting the proposed Galloper Wind Farm to the national high-voltage electricity transmission system. Under these arrangements, SSE and RWE NPower Renewables Ltd will be responsible for a limited range of works in respect of the grid connection that needs to be undertaken within the onshore application site boundary and these works are therefore included in the DCO application. Further details of these arrangements are set out in the ‘Grid Connection Statement’ submitted by SSE and RWE NPower Renewables Ltd as part of its DCO application. National Grid will continue to work with SSE and RWE NPower Renewables Ltd in respect of the impacts which the proposal will have on National Grid’s existing infrastructure. National Grid infrastructure within the application order limits National Grid high voltage electricity overhead transmission lines lie within the proposed application site/order limits. These lines form an essential part of the electricity transmission network in England and Wales. Details of the overhead lines are as follows: • 4ZX 400kV route BRAMFORD – SIZEWELL • 4ZW 400kV route BRAMFORD - SIZEWELL I enclose a copy of a plan showing the route of our overhead lines within the application site/order limits. *To view this plan, please copy this link into your brower; http://infrastructure.independent.gov.uk/wp-content/uploads/2012/02/GALL-0004-Stirling-for-National-Grid-Apendix-1.pdf We wish to reiterate the following points which should be taken into account by the IPC in considering the application: • Statutory electrical safety clearances must be maintained at all times. The construction cannot be closer than 5.3m to the nearest (lowest) conductor. National Grid will seek to ensure that our tower access is maintained during and after construction. These distances are set out in EN 43-8 Technical Specification for “overhead line clearances Issue 3 (2004) outlined at the following webpage: http://www.nationalgrid.com/uk/LandandDevelopment/DDC/devnearohl_final/appendixIII/ap pIII-part2 • Further guidance on development near electricity transmission overhead lines is available here: http://www.nationalgrid.com/NR/rdonlyres/1E990EE5-D068-4DD6-8C9A 4D0B06A1BA79/31436/Developmentnearoverehadlines1.pdf Specific representations regarding landscaping/planting Our previous representations also referred to the planting/landscaping proposed in the area crossed by the overhead electricity line. Schedule 1 Part 3 Sections 21 and 22 of the Development Consent Order refer to the provision, implementation and maintenance of landscaping. Schedule 1 Part 3 Section 21 states that a written landscaping scheme and associated working programme (which accords with the landscape strategy submitted with the application) shall, after consultation with the relevant planning authority and Suffolk County Council, be submitted to the Commission for approval. It also states that the landscaping scheme shall be implemented as approved. In terms of structural landscaping and planting near to our high voltage overhead line, National Grid requests to be consulted where it is proposed to alter the ground level in vicinity of our overhead line. Planting can take place subject to adequate maintenance access to the overhead line being provided. However, it is important that appropriate species are selected for locations below and adjacent to the transmission route to ensure that safety clearances are maintained and that the species that have been planted do not grow to heights that would infringe the safety clearances. Footpaths can be successfully accommodated beneath high voltage overhead lines and where possible, design efforts should seek to orientate alignments away from pylons. National Grid therefore requests that appropriate conditions are included in the Development Consent Order to ensure the above issues are addressed adequately and, before approving the landscape scheme and associated working programme, the IPC will need to be satisfied that these conditions are capable of being met fully. It may also wish to discuss with the relevant local planning authorities how inspection, enforcement and any amendments will be dealt with. It is possible some of these tasks could be reserved to the IPC, or allocated to the relevant local planning authorities, or allocated to the local planning authorities in consultation with the IPC. Further Advice If we can be of any assistance to you in providing informal comments please do not hesitate to contact us at the address below: National Grid Land & Development Stakeholder and Policy Manager Land & Development Team National Grid House Warwick Technology Park Gallows Hill Warwick CV34 6DA In addition the following publications are available from our website at www.nationalgrid.com/uk/landanddevelopment: • National Grid’s commitments when undertaking works in the UK – Our stakeholder, community and amenity policy • A sense of place – Design guidelines for development near high voltage overhead lines • Development near overhead lines. I hope the above information is useful. If you require any further information please do not hesitate to contact me."
Other Statutory Consultees
Maritime and Coastguard Agency
"On the 16th January the Maritime & Coastguard Agency (MCA) received a notice of acceptance of application given under Section 56(2) of the planning Act 2008. The letter indicated that the IPC have accepted the application documents from Gabbard Wind Farm Limited (GWFL) and that the project was now moving into the pre-application phase. During the preparation of the application documents MCA has been closely involved with the developers application progress, primarily through development and review of the Navigation Risk Assessment (NRA), from the initial scoping report, through to the Preliminary Environment report and DCO, under which a full review of the NRA in accordance with MCA recommendations contained within MGN 371 was undertaken . MCA is concerned that advice provided against the preliminary environmental report and draft DCO has in many areas been ignored At this stage a brief review has been undertaken of both the DCO and specifically Chapter 16 of the ES covering Shipping and Navigation, the following key issues are raised as notes of concern: 1 The DCO has not taken into account specific references regarding emergency response required by the MCA. 2. Effects of radar interference potentially obscuring small targets is a significant concern for the regulators, with considerable research undertaken, the developer appears to under estimate the risk associated close proximity navigation and radar interference. 3. A comprehensive traffic survey was completed in accordance MCA recommendations, however it is considered that the interpretation and use of the data within chapter 16 under states the significant traffic activity, highlighted at paragraph 16.7.25 indicating 105 vessels per day within the general area, for example operator responses within Sunk TSS limited to just 4 shipping companies not considered representative of the overall shipping activity. MCA would expect reference far broader consultation for such a busy shipping area, eg Sunk VTS user group and International Chamber of Shipping (ICS) 4. Emergency response procures, have not been updated by developer, with inaccurate historical references to MCA emergency tugs still in place. Emergency Response Procedures need to include not only SAR cover but also developer resources and actions. 5. Cumulative and in Combination impacts are a major concern to MCA in particular the relationship with the adjacent East Anglia licensed area just 1.9 miles to the North East. Development of the Northern boundary has significant cumulative and in combination effects , furthermore effects on cross boundary developments appear to have been discounted , and the referenced figure 16.19 significantly understates the risk. 6. It is assumed within the ES that a 50m operational Safety Zones will be implemented; this is not the case any Safety Zone application made to DECC is subject to an additional NRA and is dealt with on a case by case basis. In summary, the strategic location of this development requires a compelling argument to support its development. The interpretation of NRA data suggests chapter 16 of the ES needs to be further reviewed, the proximity with other wind farms has not been properly explored , and significantly the Southern North Sea Offshore Wind Forum (SNOSWF) does not include representation from GWFL. As a Statutory Stakeholder, it is understood that the MCA will be approached by the IPC during the application process; however it was felt that the opportunity would be taken at this early stage to raise some key areas of discussion and concerns over the submitted Environmental Statement (ES), in order to assist the IPC in its application review."
Public & Businesses
Mr William Pinney
"I represent two local commercial fishing boats from Orford, both under 10 metre vessels that fish this area. The proposed sites for this windfarm will take away very important fishing grounds from us. Grounds that we have fished for the last 40 or so years. It will displace large beam trawlers from Belgium & Holland, which may then concentrate their efforts in other areas, thus making it very difficult to work fixed gear such as pots, long lines & nets, without them being towed away by the trawlers. We have effectively been stopped from fishing the Inner Gabbard bank, the Galloper Bank and the area between the Inner Gabbard and Outer Gabbard for the last 2 ½ years. The contractors, ‘Fluor’ have virtually bullied us off the site by imposing what we believe to be an illegal exclusion zone around the whole site. We believe we should be allowed to work within 50 metres of a turbine and 500m of any active installation, not stopped fishing there. The project has gone on far longer than was originally planned and many cables have been left unburied across the banks for long periods. We have suffered the loss of many lobster & crab pots by the heavy traffic going to and from the site. The financial loss in terms of time, gear and lost earnings is very high and is not covered by the minimal compensation that we have received. The last 2 tears have been virtually ruined for us in that area and at the Outer Gabbard because of the noise disturbance. The pilings on the monopiles do badly upset the fish population. This has been recognised by the ‘East Anglia One’ project to the north and they are going to support their pylons by a different method. I would hope that would happen on the proposed site if they go ahead. I am concerned that they will employ the same methods of toal excusion to the new site as they have done so far. I hope that they will not cross the Outer GabbardBank with cables that lie exposed. If turbines are placed too close to the inside of the Outer Gabbard Bank it will be impossible to fish there again. The cumulative effect of yet more windfarms is yet another nail in the coffin of the local fishing industry, and will lead to more jobs being lost and a long tradition of East Anglian fishing being further jeopodised. I am very much opposed to this project going ahead. I feel that this company have shown far less regard for the local fishing industry than other windfarm operators and have used their muscle to ride roughshod over us."
Parish Councils
Aldringham-cum-Thorpe Parish Council
"The Galloper Environmental Statement does not appear to evaluate the aerodynamic impact of the turbine array (rather than the structures) on wave climate and hence possible impacts on the shoreline. We have asked Galloper to demonstrate that the effect of wind perturbation and pressure over the fetch length for wave height and period is negligible (or otherwise) when assessed for the cumulative impact on shoreline sediment transport. At the time of IPC registration no response has been received. If these effects are below statistical significance within natural variations we consider that it is for the developer to demonstate by analysis. Or if not that the developer should be required to ringfence reasonable resources to mitigate impacts which result from the development."
Other Statutory Consultees
JNCC
"This letter forms the initial representation of both the Joint Nature Conservation Committee (JNCC) and Natural England on the application documents submitted to and accepted by the IPC for the Galloper Offshore Wind Farm. In our view, there are a number of issues relating to environmental interests that are yet to be fully addressed by Galloper Wind Farm Ltd (GWFL). We emphasise that we have not yet had opportunity, through the pre-application process, to agree GWFL’s approach to HRA Screening and at the last point of review, we recommended that significant amendments were required. Through pre-application consultation JNCC and Natural England have raised significant concerns that need to be addressed through Appropriate Assessment (AA). Our key concern relates to the validity of the assessment of the impact of collision risk on the Lesser Black-Backed Gull population of the Alde-Ore Estuary Special Protection Area (SPA). We draw to the attention of the IPC that we are yet to review a full draft form of the submitted application, and note that on last sight, we were of the opinion that significant alterations were required. As such, we feel that an important step in the evaluation process will be our submission of a written representation containing full, detailed comments on topics relevant to JNCC and Natural England’s interests. Recognising the brevity of this representation, and the complexity of the apparent issues, we are unable to present a comprehensive response at this point. Therefore, in lieu of full detailed comments, we have included an outline of our approach to analysis of the application documents, as this should assist the IPC in reaching judgement on the sufficiency of the application. Further detail in relation to our concerns will be provided at the appropriate juncture. Our review of the application documents will focus on the Environmental Impact Assessment (EIA), Habitats Regulations Assessment (HRA), European Protected Species (EPS) and Wildlife and Countryside Act 1981 (as amended) licensing processes. In assessing the submitted Environmental Statement, the following key steps for each topic/receptor will be assessed in order to ascertain whether the conclusions drawn within the Environmental Statement are robustly supported by appropriate evidence. Where significant uncertainty remains, this should be explicit in the use of confidence estimates and appropriate and transparent use of expert judgement. We highlight that this is not a comprehensive list of the questions that will be answered when assessing the application document and should be considered in the context of relevant EIA and HRA guidance. 1. Data collection method • Have the data been collected in such a way so as to enable appropriate and robust statistical analysis? • Are the data presented appropriate to support the conclusions? E.g. Cumulative Impact Assessment – has this been defined at the correct temporal and spatial scale (to define which other projects and which receptors to be considered)? 2. Data analysis and presentation of results • Is the analysis thorough enough to support the conclusions (e.g. presented with indication of confidence in the data)? • Are any assumptions /expert judgements made fully expressed? • Are the conclusions supported by evidence as far as possible? 3. Identification of relevant features and quantifying potential impact • Has the realistic worst case scenario for development been presented? • How sensitive is the feature identified on a local, regional and, in the case of highly mobile species such as birds and marine mammals, at a population level? • Are there likely to be effects to a special interest features of a site designated or notified for nature conservation purposes (e.g. SAC/SPA/SSSI)? • Have all potential direct and indirect effects been assessed against the conservation objectives of all relevant designated sites? 4. Identification of appropriate and feasible mitigation measures • Is it possible to mitigate sufficiently against the impacts presented? • Where the need for mitigation has been highlighted during pre-application consultation, have these requirements been addressed in the application documents? It is important to note that some elements of work that may take place prior to consent being granted have the potential to cause an offence without appropriate mitigation measures. Overall, it is important to consider the validity of the application in support of the conclusions, i.e. what level of confidence can be attributed to the statements made regarding environmental impacts to enable the decision maker to make a valid decision on the risk posed to features of environmental importance. We highlight that this representation is not a comprehensive list of our concerns and that further detail will be provided, as we progress through the analysis of the information submitted and through the IPC’s examination process. We refer you to our comments relating to the associated Scoping consultation and Section 42 (PEI), carried out in August 2010 and July 2011 respectively."
Non-Statutory Organisations
Suffolk Wildlife Trust
"We have the following comments regarding this application: Terrestrial Habitat Loss It is disappointing that the design of the substation elements of this proposal involve the loss of woodland and grassland in addition to that already lost to the Greater Gabbard wind farm scheme. The semi-natural grassland known as Broom Covert was assessed in the Preliminary Environmental Report (Chapter 24, paragraph 24.4.17, June 2011) as being of ‘National’ importance as it was of sufficient quality to qualify as both Suffolk and UK Biodiversity Action Plan (BAP) habitat. This area has been downgraded to being of ‘Local’ importance in the Environmental Statement (Chapter 23, paragraph 23.4.17, October 2011). This area is part of the Sandlings heathland and we are concerned that no justification has been provided to support this change in importance. Such a change has resulted in the assessed impacts of the proposed scheme being lessened. Additionally, the further loss of woodland from the substation area has the potential to adversely affect the existing heronry, a feature which is little recorded in this part of Suffolk. Again no justification for the loss of this feature is provided within the Environmental Statement. Compensation through habitat creation is proposed as part of the application. However, the amounts of new habitat proposed vary throughout Chapter 23 of the Environmental Statement. For example in paragraph 23.6.31 states that 4.3Ha of new woodland and 1Ha of scrub/grassland will be created, whereas paragraph 23.6.34 states that 1.6Ha of ‘core’ woodland and 1.3Ha of ‘woodland edge/grassland’ will be created. It also appears that areas proposed for mitigation/compensation for this project are currently being used as existing mitigation/compensation areas for the Greater Gabbard wind farm project (e.g. the reptile translocation area). We object to this approach as it is likely to lead to insufficient mitigation/compensation provision. Reptile Mitigation The area proposed as reptile receptor habitat has been planted to provide screening for the existing Greater Gabbard substation. We also question whether this location is likely to provide suitable long-term reptile habitat given its existing proposed use. Bat Mitigation Whilst we support the provision of additional bat roosting habitat it should be noted that similar proposals were included as part of the Greater Gabbard mitigation package. To the best of our knowledge these are yet to be implemented. Migratory Birds From the Environmental Statement it appears that the ornithological survey work (Chapter 11) consisted of daytime boat and aerial surveys. However, no assessment appears to have been made of the likely impact of the proposal on birds which are crossing the project area at night. We consider that night surveying and/or the use of remote survey techniques (e.g. radar) could have been employed in an attempt to rectify this deficiency. A large number of migratory birds are known to fly at night and this proposal has the potential to have an adverse impact on any passing through the project area. Terrestrial Monitoring Although terrestrial mitigation/compensation measures have been proposed there is no reference to monitoring. We recommend that ecological monitoring is carried out post-construction, particularly as the project involves the translocation of reptiles."
Non-Statutory Organisations
Nord-Pas de Calais/Picardie Fisheries Committee
"The Nord - Pas de Calais / Picardie Regional Fisheries Committee represents the interest of the French fishermen, from Dunkirk to the Baie de Somme. The project of Galloper wind farm is located on a place used by several fishermen from Dunkirk and Boulogne-sur-Mer (netters and trawlers). As interested party, we have some concerns about the consequences of the implementation of this new wind farm: during the construction of the wind farm and during the exploitation, with a loss of fishing grounds. In the context of the Fisheries Common Policy we do have fishing rights in the UK water (6-12 nm) and we would like to underline it. This project will impact our activities so we would like to be fully informed and consulted on it."
Public & Businesses
Mr Martin Freeman
"I disagree with the following aspects set out in the application: Noise levels * surveys used are old/out of date (2009). *Noise survey NOT taken at Halfway Cottages (which are nearest houses to Galloper), but between Crown farm/halfway cottages. Application refers to noise at Halfway Cottages. *From personal experience of Greater Gabbard’s construction/continued noise the noise levels stated are underestimated. Traffic *speed limit needs to start at leiston turning down to Sizewell Power Station sites *due to the number of near misses/accidents on road (dealt with and witnessed over 90 accidents during 17 years I have lived here and I have witnessed alot of near misses at entrance to the Greater Gabbard site) *near misses and one accident involving road sweeper used during construction of Greater Gabbard. *does not take into account visitors to Sizewell (day and long stay) and Sizewell B outages traffic/worker increase *lots of rights of way and alot of events held on this road from running, sponsored walks and horse carriage/riding *Traffic data used is old/out of date (SZA decommissioning studies, Dry Fuel Store, 2009 noise survey). Where is data collated during construction of Greater Gabbard. Light pollution *lots of problems with light pollution on roads/facing houses during Greater Gabbard construction. *use of lights, type of lights and duration of lights on need tight controls Working hours *tighter controls and less working hours (shorter days and/or no weekend working at all) due to experience of Greater Gabbard working late in evenings using machinery at 10:30pm causing noise and light pollution. Temporary Storage area *how will it be used? - reservations over noise/light pollution as very close to house. Complaints/monitoring *need for continuous monitoring of noise and traffic to take necessary action to avoid unnecessary disturbance to houses *24hr contact required and 24hr resource available to resolve complaints in timely manner (as unable to contact Greater Gabbard majority of time to resolve issues)"
Public & Businesses
Miss Maria Toone
"I disagree with the following aspects set out in the application: Noise levels * surveys used are old/out of date (2009). *Noise survey NOT taken at Halfway Cottages (which are nearest houses to Galloper), but between Crown farm/halfway cottages. Application refers to noise at Halfway Cottages. *From personal experience of Greater Gabbard’s construction/continued noise the noise levels stated are underestimated. Traffic *speed limit needs to start at leiston turning down to Sizewell Power Station sites *due to the number of near misses/accidents on road (dealt with and witnessed over 90 accidents during 17 years I have lived here and I have witnessed alot of near misses at entrance to the Greater Gabbard site) *near misses and one accident involving road sweeper used during construction of Greater Gabbard. *does not take into account visitors to Sizewell (day and long stay) and Sizewell B outages traffic/worker increase *lots of rights of way and alot of events held on this road from running, sponsored walks and horse carriage/riding *Traffic data used is old/out of date (SZA decommissioning studies, Dry Fuel Store, 2009 noise survey). Where is data collated during construction of Greater Gabbard. Light pollution *lots of problems with light pollution on roads/facing houses during Greater Gabbard construction. *use of lights, type of lights and duration of lights on need tighter controls Working hours *tighter controls and less working hours (shorter days and/or no weekend working at all) due to experience of Greater Gabbard working late in evenings using machinery at 10:30pm causing noise and light pollution. Temporary Storage area *how will it be used and for how long? - reservations over noise/light pollution as very close to house. Complaints/monitoring *need for continuous monitoring of noise and traffic to take necessary action to avoid unnecessary disturbance to houses *24hr contact required and 24hr resource available to resolve complaints in timely manner (as unable to contact Greater Gabbard majority of time to resolve issues)"
Non-Statutory Organisations
Chamber of Shipping
"• Due to some unaddressed concerns over navigational safety risks, the Chamber of Shipping cannot offer approval for the current proposals for the Galloper Offshore Wind Farm. • Our primary concern relates to the lack of a buffer between the northern site boundary and the high densities of east-west traffic travelling along it. The lack of a buffer presents a clear navigational safety risk. This traffic may be further constrained by any future development in the south of the East Anglia zone and the 8.8m shallow patch of water noted in paragraph 16.4.28. While we appreciate that the developers can only consider confirmed development proposals within the East Anglia zone (i.e. East Anglia ONE) we feel that mitigation measures should be applied to ensure that a sufficient corridor is maintained for vessels operating on these routes. Using the shipping template contained within MCA MGN 371, we recommend a minimum 2nm buffer in order to reduce risk to sufficiently low levels. • We are concerned that the developers have chosen not to outline the pre-mitigation levels of risk for collision incidents during the operational phase in Table 16.9. The table refers to paragraph 16.12.2 for an explanation, but this paragraph does not appear to exist in the Environmental Statement. The effectiveness of the proposed mitigation measures cannot be accurately assessed without a clear analysis of pre-mitigation risk. We find this oversight extremely worrying due to the significance and scale of this proposed development. • We believe that the potential consequences of collision incidents in plots 16.5-16.8 (Sections 16.6 and 16.7) have been downplayed. In the event of a vessel-to-structure or vessel-to-vessel collision there is always a strong possibility of fatalities. Therefore, we consider the potential worst-case consequences to be “serious” or “major” based on the consequence bands used in the developers’ risk matrices. • We have concerns over the effectiveness of the May 2011 Hazard Review Workshop in accurately assessing risk. The Chamber attended this meeting and we feel that analysis of worst and most likely case scenarios was lacking and that the impacts on various commercial vessel types were not discussed. In our opinion, insufficient time was allowed for this workshop, attendance was poor and the purpose of the hazard identification exercise was inadequately explained. Therefore, we do not believe that the results of the workshop provide an accurate assessment of navigational risk. • We do not support the proposal for 50m safety zones to be enforced during normal operations. We do not believe that a strong enough case has been put forward for these safety zones to be established and that the zones would place unnecessary restrictions on smaller craft operating close to the wind farm. The 50m operational safety zones at the Greater Gabbard Wind Farm should not be used as a justification for the enforcement of similar safety zones at Galloper."