PTE/12/59 Development Management Committee 5 September 2012

Pre-application Consultation by Channel Energy Limi ted on the Proposed Environmental Statement in Respect of the Atlantic Array Offshore Wind Farm Section 42 and 48, Planning Act 2008 Response from Devon County Council Report of the Head of Planning, Transportation and Environment Recommendation: It is recommended that the Committ ee endorses the technical response from this Authority in respect of the nece ssary amendments and additions to the final Environmental Statement that will acco mpany the application for development consent that will be submitted to the P lanning Inspectorate. 1. Summary 1.1 The purpose of this Report is to enable Members to endorse the technical response

to Channel Energy Limited (CEL) following its consultation on the proposed content of the Environmental Statement that will be submitted to the Planning Inspectorate.

1.2 This Report does not comment on the merits or otherwise of the proposed Atlantic

Array Offshore Wind Farm. 2. Introduction 2.1 CEL1 is proposing to develop a wind farm of up to 1,500 megawatts (MW) of

generating capacity within the outer Bristol Channel, known as the Atlantic Array Offshore Wind Farm (referred to hereinafter as the ‘Atlantic Array’).

2.2 The Atlantic Array would be located approximately 22 km from the south Wales

coast, 14 km from the north Devon coast and 13 km from Lundy Island, at its closest points.

2.3 The Atlantic Array is defined as a Nationally Significant Infrastructure Project (NSIP)

under the Planning Act 2008. As such there is a requirement to submit an application for development consent for the wind farm to the Planning Inspectorate.

2.4 The Atlantic Array project has been subject to ongoing site selection choices and

refinement since 2005 following extensive consultation with all relevant stakeholders.

1 CEL is a wholly owned subsidiary of Bristol Channel Zone Ltd (BCZL), itself a wholly owned subsidiary of RWE npower renewables (RWE NRL). RWE NRL is one of the UK’s leading renewable energy developers and operators. The Company currently operates 19 hydroelectric schemes and 26 wind farms in the UK including two offshore wind farms, North Hoyle and Rhyl Flats, located 7 km and 8 km off the coast of north Wales respectively. It is also in the process of constructing two larger offshore wind farms: Gwynt y Môr, 13 km off the north Wales coast, and Greater Gabbard (in which it holds a 50% share), which is located 25 km off the coast of Suffolk.

Please note that the following recommendation is subject to consideration and determination by the Committee before taking effect.

The development rights for the zone were awarded to the Company by the Crown Estate in January 2010.

3. The Project 3.1 The Company is still assessing the final layout of the proposed wind farm in order to

maximise the energy yield from the site, and to seek to minimise the environmental effects. Ultimately the number of turbines installed and the precise layout would depend on the individual capacity of the chosen wind turbines. The following table sets out the indicative turbine dimensions and numbers.

Indicative turbine size (MW)

Max number

Indicative hub height (m above LAT)

Max rotor diameter (m)

Max blade tip height (m above LAT)

3.6 278 105 125 165 5 278 110 140 180 6 250 115 165 200 8 188 125 180 220

Note: LAT = Lowest Astronomical Tide.

3.2 The project would be limited to 1,500MW of installed capacity. Therefore, the

number of turbines installed would be determined by their rated capacity, i.e. the amount of electrical power a turbine would produce. The number of turbines which would be installed at the Atlantic Array would not exceed 278. The largest turbines that may be installed would have a maximum blade tip height of 220m, and an indicative hub height of 125m above sea level.

3.3 In addition to the turbines, the Atlantic Array would include up to five meteorological

monitoring stations that are essential to provide meteorological and oceanographic data from the site.

3.4 The Atlantic Array would include between two and four offshore substations. The

location of these would be determined once the turbine layout has been decided. The power from the turbines would be delivered to the substation by sub sea cables. Transformers housed in the substations would step up the voltage for delivery to the shore via the export cables. Up to eight higher voltage cables would then export electricity from the offshore substations towards the shore, where they would be joined to the onshore cables. The offshore cables would be buried where possible, and protected where it is not feasible to do so, to prevent movement of the cables, to limit potential environmental impacts and to prevent any navigational risk to other marine users.

Onshore

3.5 The Atlantic Array would require development onshore, comprising electrical

infrastructure to allow the electricity generated by the offshore wind turbines to be transferred into the National Grid transmission system. The onshore development would include the cable landfall site at Cornborough Range and the onward cable route from the landfall location to the existing 400kV substation, located at Alverdiscott. The onshore cable route would be approximately 14.3km in length from the landfall to the substation. A new substation would be required adjacent to the existing substation at Alverdiscott to transform the voltage coming in from the wind farm to the voltage being distributed via National Grid.

3.6 From the landfall site, up to eight cable circuits would be buried underground along

the proposed cable corridor to the new substation at Alverdiscott. The landfall and cable laying activities would be temporary and land within these construction areas would be reinstated after construction, with hedgerows replanted. The proposed substation at Alverdiscott would be an operational structure, designed to remain for the life of the Atlantic Array project.

Onshore Cable Route

3.7 The cables would be buried underground within trenches. One cable circuit would be

accommodated within each trench. Therefore, up to eight trenches would be required. The cables would be buried underground at a typical depth of approximately 1.2m. The onshore cables would be buried within a construction corridor of up to 54m wide. The construction corridor would allow for up to eight cable trenches, a temporary construction access road, storage for topsoil and subsoil on both outer edges of the corridor and appropriate separation distances.

3.8 Once the installation work is completed, the haul road would be removed and the

ground reinstated using the stored topsoil and subsoil. The temporary works site areas would be removed and the land reinstated to its former condition. Once installed, the cables would occupy a corridor approximately 34m wide. It is the intention that the hedges would be replanted using locally sourced native species, and would be based on restoring the hedge to match the remaining hedgerow at each location.

3.9 A technique known as Horizontal Directional Drilling (HDD) would be used to pass

the cable underground beneath the cliffs at Cornborough Range; the A39; and, the River Torridge and its floodplain, the A386 and the Tarka Trail.

3.10 The landfall site is located to the south of Westward Ho! at Cornborough Range,

located at a low point in the cliffs to the north of an existing wastewater outfall pipe associated with the South West Water waste water treatment works. At this location, an HDD operation undertaken from the proposed landfall site would drill beneath the cliffs, exiting in the sea bed. The proposed landfall site is

3.11 The cable route would cross the A39 between Ford and Abbotsham Cross, east of

the roundabout at Abbotsham Cross. It is proposed to utilise HDD for this crossing as the A39 represents one of the main routes through the project area for both local and longer distance traffic.

3.12 The cable route would cross the River Torridge to the south of Bideford and to the

south of the Torridge Estuary SSSI. At the crossing location, the A386 runs to the west of the river and the Tarka Trail is located to the east. It is proposed to utilise HDD for this crossing in order to minimise effects on the river, A386 and the Tarka Trail. The drill length would be approximately 600m long and would start and finish beyond the river floodplain.

Substation

3.13 A new onshore substation is proposed adjacent to the existing National Grid 400kV

substation at Alverdiscott, which lies approximately 5km to the south east of Bideford. This substation would be designed to transform the voltage delivered from the wind farm into that suitable for distribution via the national grid transmission system.

3.14 The existing 400kV substation is located within a grass field used as grazing land, with a variety of overhead lines crossing the land and connecting to the substation. The proposed substation would occupy a maximum built area of approximately 9.5ha and a maximum total area of 13.4ha (including earthworks and access roads) located to the west of the existing substation on either side of the existing access road. The land use is currently a combination of arable and pasture.

3.15 Buildings, up to 14m in height, would be provided within the substation to

accommodate equipment. Access to the substation would require relocation of the existing substation access road. The substation is anticipated to be un-manned during operation and is only likely to require lighting during visits.

3.16 A landscape strategy has been developed for the substation site in order to screen

the development as far as practicable, together with providing ecological habitat. In addition, a number of existing overhead lines currently visible to the west of the existing substation would be buried underground as part of the project.

Construction Programme

3.17 The offshore components and onshore substation for Atlantic Array may be installed

in a single phase (1,500MW) or in up to three phases of smaller developments (approximately 500MW each). If the application for the development is successful, it is anticipated that construction would commence in 2016, although some works may commence earlier.

Offshore

3.18 Offshore construction is currently expected to commence in early 2017, though this

may occur as early as 2016. A single build for the offshore wind farm (1,500MW) is anticipated to take up to 6 years to complete. If built in phases the total offshore construction period, from the start of installation of phase 1 to the end of the installation of phase 3, may be up to 11 years, and the gap between phases may be up to six years. The total time over which offshore construction would actually take place would remain the same, i.e. estimated at up to 6 years.

Onshore

3.19 In the event that the Atlantic Array substation is built in a single phase, the duration is

anticipated to be approximately three years. If the works are undertaken using a phased approach, each phase may take up to two years. It is possible that the construction phases for the substation may not be continuous (if the construction phases offshore are not continuous). The total duration (with gaps between phases) may be up to 11 years.

3.20 Construction works for the cable route (including HDD works) would be undertaken in

a single phase. It is anticipated that this would take approximately 2.5 years. 4. Comments 4.1 The detailed comments from this Authority are contained in the Appendices to this

Report. This Section summarises, where appropriate, the main issues raised.

Highways

4.2 Officers of this Authority have been working with RWE and RPS (RWE’s transport consultants) to ensure that should this application go ahead, the impacts on the highway and highway users are kept to a minimum. Both RWE and RPS have been keen to take advice from DCC highway officers and it is hoped that the advice given on the necessary additional information the Highway Authority would like to be submitted in order for those reading the information to be able to make a fair assessment of the impacts of the Atlantic Array on the Devon highway network. The information presented in the transport section has been examined, and a number of questions and comments have been made. Further clarification is sought on a variety of issues, and some additional work is requested (the full content of which is set out in Appendix I).

4.3 The transport section of the Draft ES considers the construction of the onshore

infrastructure only. This includes the 54m wide cable route and the construction required to upgrade the national grid substation at Alverdiscott. The construction and/or transportation of the turbines themselves are not assessed and neither is an operation and maintenance (O & M) depot considered. Whilst the reason for this is that RWE are not in control of where the depot will be, in order to assess the overall impact on highway as a result of the Atlantic Array, some consideration should be made of the possibility that additional traffic will be on the highway network in Devon. This is particularly important if the substation is built in three phases as opposed to one, due to the overlap in the operation of the O&M base traffic and the substation construction traffic.

4.4 Whilst the Applicant has been advised that a full transport assessment is not required

for the entire area, and that individual junction assessments do not need to be undertaken for all junctions, it is nevertheless necessary to consider local conditions when assessing the traffic impacts and the junctions that will see a significant increase in general traffic or HGVs should be assessed.

4.5 Although the assessment of vulnerable groups is welcomed, no results have been

included in the document. The existing level of traffic and HGVs passing each sensitive receptor should be shown in a table with the proposed traffic levels during construction of the onshore facilities.

4.6 Additional or alternative assessment should be carried out in a similar form to that

within the DfT’s Transport Analysis Guidelines in order to adequately appraise the social and distributional impacts resulting from the construction elements of the Atlantic Array proposal.

4.7 The largest impact of the onshore construction work is that of the HGVs travelling on

the roads during the construction of the cable route. The number of HGV daily trips for the construction of the cable route is estimated to be 214, with a further 27 trips for the substation. This total of 241 HGV trips (482 movements) will be travelling along the highway network on a daily basis around the Bideford area.

4.8 It is essential that a construction management plan is submitted and adhered to that

ensures all works are carried out safely and to the standard required by the Highway Authority.

4.9 Permanent signs and an adequate signing strategy will be required at each location

that the cable route crosses the public highway. Certain road closures should be co-ordinated so that only one road is closed at a time in order to maintain adequate diversionary routes. Additional information is requested regarding the working of the

closures and how the roads that are crossed by the cable route will operate, both at normal times, and whilst the road is closed.

4.10 A condition survey of the highway network in the surrounding area should be

conducted prior to construction work and again after completion of the work. Payment of a proportion of the cost of returning the roads to the standard that would be required by this Authority after the works have been completed.

4.11 As the majority of HGV movements are associated with the cable route the impact of

HGVs on inappropriate roads can be minimised by HGVs using the haul road to access all compounds and the substation when possible. This may result in further distances being travelled by some vehicles, but will ensure the safety of highway users on the smaller and more sensitive roads.

4.12 In order to minimise the additional level of traffic passing through the villages of St.

Johns Chapel, Newton Tracey and Alverdiscott, all vehicles should be instructed and directed to use the A39, B3233, Manteo Way and Gammaton Road to access the substation, rather than using the B3232 via Newton Tracey. The A39 route offers a higher standard of road and will be safer for all highway users, although it is further to travel.

4.13 As Bideford Quay is a working quay, with the transfer of a range of cargoes from

road transport to water transport, there are often a large number of HGVs accessing this area for deliveries. Travel restrictions on HGVs accessing the cable route when the loading of these cargoes is taking place will need to be considered as part of the construction management plan

Landscape

4.14 A desk study review of the landscape sections of the Draft ES has been undertaken

using EIA review criteria set by the Institute of Environmental Management and Assessment (IEMA). This review notes key areas of concern that it is recommended that the final ES should address. No comments are being made on the Historic Seascape Character and Terrestrial Heritage Assets parts of the ES.

4.15 Also, as the review is desk-based, it therefore does not include a field assessment to

consider the visual impact assessment based on the photomontages from selected representative viewpoints. It is understood that Natural England, the National Trust, and the North Devon AONB Partnership will be commenting on these aspects as far as offshore effects are concerned.

4.16 The Draft ES predicts that the offshore array would result in significant adverse

landscape and visual impacts on Lundy Island and parts of the North Devon AONB . The Atlantic Array proposal therefore highlights a key tension between these two aims, calling for a balanced decision based on a clear understanding of the benefits and the environmental harm likely to result from the proposal.

4.17 It is therefore vital that the effects of the proposals on Devon’s landscapes are

properly assessed and conveyed to the decision maker. Therefore the aim of the review of the landscape section is:

• To ensure that the relevant Chapters (both onshore and offshore) of the ES

follow best practice guidelines, and can be relied upon by decision-makers when assessing the effects of the proposals on the distinctive character, qualities and features of Devon’s landscapes.

• To ensure that the ES is presented in an objective and unbiased way, and

conveys these significant adverse in a way that is useful, helpful and easy to understand. Given the extremely large volume of material contained within the draft ES it is vital that decision-makers are clear about the significance of environmental harm to be weighed against the benefits of the proposals. This demands that the quality of the landscape and visual impact assessment for both onshore and offshore effects are extremely high, including the non-technical summary.

• To ensure the ES contains details of adequate and appropriate

mitigation/compensation for significant adverse effects, should the decision-maker feel that the benefits outweigh the harm.

4.18 The detailed review of the landscape sections of the Draft ES are contained in

Appendix II to this Report.

Ecology 4.19 Although this Authority is not responding in detail on the ecological issues as these

are being dealt with by Natural England, Devon Wildlife Trust and the Northern Devon Biosphere Partnership, it does, however, wish to emphasise the need to ensure that there is effective mitigation, compensation, and enhancement for impacts on hedges. Further detail on this impact of the proposal is incorporated into landscape response at Appendix II. It is also agreed (as suggested by the Biosphere Partnership) that Defra’s off-setting metric is used to calculate the requirements for compensatory habitat.

Archaeology

4.20 The cable route will impact on a number of features of archaeological interest.

However if the method of survey and recording is carried out in accordance with the methodology outlined in the consultation draft, then this Authority is of the opinion that those impacts will be addressed satisfactorily.

Recreation, Tourism and Socio Economic Effects

4.21 The Recreation and Tourism section of the Draft ES highlights the importance of

tourism to Northern Devon (North Devon and Torridge combined), in particular water sports based tourism. It recognises that the natural beauty and the coastal/rural atmosphere of the area are some of the many reasons for its popularity.

4.22 During this and previous consultations, respondents have raised concerns about the

potential for tourism to be affected by the presence of the proposed offshore wind farm, both through visual and other impacts. The Draft ES rightly recognises that tourism impacts of a visual nature are influenced by personal attitudes to offshore development.

4.23 The results of a number of surveys of visitors and businesses have been included in

the Draft ES relating to the impact of wind farm development upon tourism activities and the image of an area in the UK and Europe. These results indicate that the effects are largely neutral, or positive. They also indicate that there is little evidence to prove a link between changes in character of a landscape and actual visitor behaviour.

4.24 These statements within the Draft ES, however, do not note when the surveys were undertaken; the location of the surveys, for example whether those undertaken elsewhere were comparable to northern Devon; whether surveys undertaken elsewhere referred to specific developments of a certain size and location, or were generic; or whether studies took into account any novelty factor associated with offshore wind farm projects, which at the time of survey could potentially have been uncommon and increased the popularity of offshore windfarms. It would be helpful if further clarification of this is provided within the text.

4.25 Significant concerns have been raised locally regarding the potential impacts of the

proposed Atlantic Array on the tourism industry. The size of the industry in North Devon and Torridge must not be underestimated. Should any negative impacts be felt locally they are likely to have a profound economic effect. In 2008 in Northern Devon, South West Tourism estimated:

• 1,030,400 trips by staying visitors • 4,591,300 staying visitor nights • £228,145,000 spend by staying visitors • 3,064,000 day visits • £135,141,000 spend by day visitors • £12,652,000 other tourism related spend • 10,633 jobs related to tourism spending • 17% of employment in North Devon, and 10% of employment in Torridge is

supported by tourism 4.26 Within the Draft ES reference is made to a number of key documents, but these are

not included within the technical annexes. These should be included within the ES to ensure the full range of evidence is available, as opposed to summarised extracts and statements relating to these documents, to enable an objective appraisal of the likely full impacts. Full methodologies should be included. These documents are:

• BVG Atlantic Array Socio-Economic study (2012) • ICM Atlantic Array Tourism survey (2011) • Regeneris Socio-Economic impact assessment of the Gwynt-y-Mor offshore wind

farm (2005) 4.27 North Devon Plus has expressed concerns regarding baseline tourism data used to

assess the impact of the proposed Atlantic Array. Different data sets have been used to assess tourism impacts in Northern Devon and South Wales, making it difficult to draw exact comparisons, or objective conclusions.

4.28 The European NEA2 project undertaken in 2009 concluded that the watersports

sector plays a significant role in the economy of northern Devon, employing over 2,000 staff and generating an estimated £80m turnover. Potential impacts on Northern Devon surfing resources have been ruled out from further assessment. Ireland forms a wave shadow preventing the direction of swell which would pass through the Array before meeting the identified surfing locations in Northern Devon. While this is evident, the Draft ES does not adequately justify this screening and the issue should be clarified. In addition the draft ES should consider the impact on waves at surfing locations along the north coast of Devon and Exmoor, e.g. Lynmouth and Porlock. These waves are within the swell shadow of the proposal and should be assessed with the same methodology as surfing resources along the South Wales coast.

4.29 The Draft ES acknowledges that some of the pile driving periods of offshore construction are likely to be audible form the coasts of North Devon and Lundy, in particularly during calm weather. During the offshore construction period the potential impact of noise and vibrations associated with this activity on the wider tourism industry has not been adequately assessed. The Draft ES should provide further assessment and monitoring programmes to identify the extent to which offshore piling may detract from people’s enjoyment of the region’s beaches.

4.30 While it is recognised that RWE is yet to award contracts for Operations and

Maintenance of the proposed scheme, the Draft ES does not provide sufficient evidence regarding the socio-economic benefits which may arise as a result of the proposal. RWE should continue to work with the local authorities and educational facilities to ensure opportunities are maximised in terms of employment, skills, training, education and development of the supply chain for both onshore and offshore construction. The Draft ES should be developed to provide specific measures to be adopted to ensure that RWE delivers added economic value to northern Devon including:

• Harbour facilities assessments to clarify the exact level of investment expected at

each harbour • Continued liaison with local educational facilities to develop an appropriate skills

sector • Specific commitments to utilise local contactors where possible, particularly in

relation to onshore construction • Specific commitment to ensure that local businesses are drawn into the supply

chain as soon as possible and at as high a tier as possible 4.31 The Draft ES relies on a series of key documents regarding the local economy some

of which are outdated and have been superseded. The assessment of the four development scenarios is dependent on an appropriate baseline and should be assessed against a control scenario describing business-as-usual. RWE should expand the Draft ES to draw on experience with its other offshore wind farm developments in the UK relating to job and supply chain development. Further evidence is required to enable an understanding of how wind farm related jobs might impact on employment in other local economies such as fisheries and tourism.

Commercial Fisheries

4.32 The Severn and Devon Inshore Fisheries and Conservation Authority (IFCA) has

identified gaps within the Draft ES. RWE should continue with ongoing, transparent negotiations until all outstanding issues are resolved. The Draft ES does not appear to adequately assess the potential for turbine foundations to alter local tidal flows and sediment patterns and the subsequent impact this may have on fishing grounds within the proposal’s boundary and in adjacent waters. This may impact on the predicted increase in shellfish and larval dispersal in the wider area.

4.33 The Draft ES acknowledges that trawling will be displaced from within the proposed

Array, but that potting will be able to continue once construction is complete. IFCA suggests that insufficient separation between turbines, unpredictable tidal flows and the length of lines required at water depths experienced in the area will pose a serious risk of entanglement and subsequently displace any potting activity. RWE should continue discussions with IFCA and the North Devon Fisheries Association regarding the full range of potential impacts and amend the Draft ES where necessary.

4.34 The Draft ES does not adequately assess the secondary impacts associated with the

potentially permanent loss of certain elements of the fishing industry. Permanent, or semi-permanent seabed infrastructure could potentially lead to reductions in local port activity and the loss of associated shore based jobs such as processing and supply. The Draft ES should further consider the impact on local ports such as Appledore Fish Docks and any potential detriment to community vitality and jobs supported by the industry.

4.35 The Draft ES does not adequately address the inter-related, cumulative effects of

offshore infrastructure on the fishing industry with other developments in the Bristol Channel and River Severn. Further assessment is required to establish the combined effects of future development such as tidal generation projects within the Severn Estuary and the establishment of Marine Conservation Zones. The combined impact on fishing grounds, fleet activity, port and harbour employment and the local economy should be assessed.

4.36 RWE should continue to liaise with the local sector to establish an appropriate level

of compensation and account for losses to the industry through all phases of development and beyond the lifetime of the proposal. Where compensation is considered inappropriate by the local sector, RWE should look to support the growth of alternative methods of fishing and continue a programme of ongoing monitoring within the Array.

5. Options/Alternatives 5.1 This Authority has the option as to whether or not to respond to the consultation on

the Draft ES. It is considered necessary to make detailed comments at this preliminary stage in order to assist the Applicant in preparing a more comprehensive final ES that should then enable the Planning Inspectorate to reach a properly considered decision.

6. Reason for Recommendation 6.1 It is recommended that the Committee endorses the technical response from this

Authority in respect of the necessary amendments and additions to the final Environmental Statement that will accompany the application for development consent that will be submitted to the Planning Inspectorate.

6.2 In addition, it is recommended that Officers continue to work with RWE and its

consultants in order to assist in the preparation of the final ES.

Dave Black Head of Planning, Transportation and Environment

Electoral Divisions: All – in particular Bideford South & Hartland; Fremington Rural; Braunton Rural; Combe Martin Rura l; Northam;

Ilfracombe; and Bideford East

Local Government Act 1972: List of Background Papers Contact for enquiries: Stewart Redding Room No. AB2 Lucombe House, County Hall, Exeter, EX2 4QD Tel No: (01392) 383368 Background Paper Date File Reference 1. Pre-application Consultation

documents on Atlantic Array June 2012 _

sr220812dma shc/cr/atlantic array wind farm 05 280812

Appendix I To PTE/12/59

DCC Response as Highway Authority Officers have been working with RWE and RPS (RWE’s transport consultants) to ensure that should this application go ahead, the impact on the highway and highway users is minimised. This Appendix sets out details of what additional information the Highway Authority would like to be submitted in order for those reading the information to be able to make a fair assessment of the impacts of the Atlantic Array on the Devon highway network. The information presented in the transport section has been looked at and a number of questions and comments have been made. Further clarification is sought on a variety of items and some additional work is requested. The transport section of the ES considers the construction of the onshore infrastructure only. This includes the 54m wide cable route and the construction required to upgrade the nation grid substation at Alverdiscott. The construction and/or transportation of the turbines themselves are not assessed and neither is an operation and maintenance (O&M) depot considered. Whilst the reason for this is that RWE are not in control of where the depot will be, in order to assess the overall impact on highway as a result of the Atlantic Array, some consideration should be made of the possibility that additional traffic will be on the highway network in Devon. This is particularly important if the substation is built in three phases as opposed to one, due to the overlap in the operation of the O&M base traffic and the substation construction traffic. The delivery of the 210 tonne transformers has been thoroughly investigated and DCC officers have been working with RWE to ensure that the route from Appledore Shipyard to the substation via the Torridge Bridge and Manteo Way is of a standard to accommodate such large loads and that they are transported safely with as little impact as possible on highway users and local residents. A legal agreement is sought such that any damage to the highway due to the transporting of abnormal loads is repaired at the cost of RWE. The use of Appledore shipyard and transport of the transformers by water is encouraged. Further goods arriving via this route would be welcomed in order to reduce the impact on other junctions in the County. There is some concern about the criteria being used to assess the impact and changes in traffic flow as shown in table 12.5 (Onshore Vol.2). The criteria used for assessing the traffic impact is based on 1993 guidelines (from Institute for Environmental Assessment, Guidelines for the Environmental Assessment of Road Traffic) and should only be used to assess the environmental effects of the changes in traffic. This guidance indicates that up to a 30% increase in traffic, or HGVs, would be negligible, and between 30 and 60% would be a low impact. Whilst these criteria may be correct in terms of how increases in traffic are perceived, these levels are not acceptable to use to assess some of the categories proposed (para 12.29) such as driver delay. By way of an example, a 30% increase in traffic on Bideford Quay would be severe for congestion; however a 30 to 60% increase is likely to have a low impact on noise levels. On some minor local roads a 90% increase in traffic would result in an acceptable increase in delay to drivers due to the current traffic level and delay being small. A different methodology should be used to assess the impact of traffic, which takes into account he number of additional vehicles as a result of the development as well as the proportion increase and whether or not the road/junction is suitable for such increases.

As agreed with DCC planning officers, a full transport assessment is not required for the entire area and individual junction assessments do not need to be undertaken for all junctions. However, local conditions should be thought about when assessing the traffic impacts and the junctions that will see a significant increase in general traffic or HGVs should be assessed. Whilst the assessment of vulnerable groups is welcomed, no results have been included in the document. The existing level of traffic and HGVs passing each sensitive receptor should be shown in a table with the proposed traffic levels during construction of the onshore facilities. Figure 12.6 should be updated with additional sensitive receptors as it fails to include many, such as Littleham Village Hall and any place of worship. Additional or alternative assessment should be carried out in a similar form to that within the Department for Transport’s Transport Analysis Guidelines (WebTAG) unit 3.17, in order to adequately appraise the social and distributional impacts resulting from the construction elements of the Atlantic Array proposal. Although this documentation is in relation to appraising transport infrastructure, the assessment methodology in terms of severance and safety is one that can be applied the onshore construction. The largest impact of the onshore construction work is that of the HGVs travelling on the roads during the construction of the cable route. Table 12.15 gives the number of HGV daily movements for the cable route to be 214, and a further 27 for the substation. These 241 HGV movements will be travelling the highway network on a daily basis around the Bideford area. It must be noted that these are HGV movements on the road network, of which each HGV makes at least two (one to arrive, and one to depart). Depending on the number and frequency of HGVs that use small local roads for access, the impact on these small local roads can be low, if an adequate construction management plan is drawn up and abided by. Clarification is sought on a number of items relating to the interaction of the haul road and public highway. The majority of these comments will form the basis of a construction management plan that ensures all works are carried out safely and to the standard required by the Highway Authority. Permanent signs and an adequate signing strategy will be required at each location that the cable route crosses the public highway. Information on road closures has been provided in the documentation, and further details of how this would work shall be agreed with DCC highway officers prior to the start of construction on the cable route. Road closures numbers 12, 13 and 14 in figure 12.2 (Onshore vol.2) should be co-ordinated so that only one road is closed at a time in order to maintain adequate diversionary routes. Additional information is requested regarding the working of the closures and how the roads that are crossed by the cable route will operate: (a) at normal times, and (b) whilst the road is closed. Information is also sought regarding the length of time road closures will be in place, and details of the interaction between the highway network and the haul road should be explained and agreed with DCC highway officers. Use of the haul road for private vehicles near to Gammaton Road should also be investigated as a possible diversionary route. Further investigation should also be made into using the section(s) of haul road between Manteo Way and the substation as public highway after the construction, particularly if the substation construction is in more than one phase. This would result in the Atlantic Array project providing benefits to the local population by providing local highway users a standard of road higher than that of Gammaton Road. The entire 54m (or 34m without earthworks) width of the cable route that crosses any highway would need to be replaced in one section, rather than filling in the eight trenches

separately. This should also come with a guarantee of at least 3 years from the completion date of the project (i.e. once the abnormal use has ceased and the roads returned to normal traffic loading). A condition survey of the highway network in the surrounding around should be conducted prior to construction work and again after completion of the work. Payment of a proportion of the cost of returning the roads to the standard that they were in prior to the construction should be made to DCC after the works have been completed. There are drainage easements in place around the area of the cable route, particularly around Gammaton Reservoir, that prevent surface water and ice building up on the highway. Checks should be made to find where these are and work should be done to ensure that during and post construction of the cable route these easements still operate adequately. The impact to traffic from the Horizontal Directional Drilling (HDD) under the A39 and A386/River Torridge will be negligible as traffic will still be able to use these roads. No work has been presented to show that the unstable cliff faces along the A386 and River Torridge will not be affected. There are often minor rock falls onto the A386 that close this road and the land beneath the A386 is prone to landslips despite the stabilisation work that has been carried out over the past two decades, including rock pinning and netting. Emergency plans should be made that can be implemented in the event of either a major or minor rock fall onto the A386 or land slip beneath the road, whether this is a result of the HDD work or not. Torridge District Council’s Emergency Planning Officer will be able to advise on this. It is accepted that there will be some impact on Roundswell roundabout and RPS are awaiting traffic information from DCC officers in order to accurately assess the impact at this junction. DCC officers will work with RPS to ensure that a robust assessment is made of the impact on traffic conditions in the Barnstaple area. The Study area in figure 12.1 covers a large area. The main impacts will be on the Bideford and Alverdiscott area, with some impact around Barnstaple. Assessment of traffic flows on the A361 east of the Landkey junction is not required, other than for Junction 27 of the M5 motorway. Recent housing developments in Tiverton have been given a holding direction by the Highways Agency due to their impact on Junction 27. Although the vehicle impact on this junction from these housing developments is small, the junction is over capacity in peak periods. The impact of the Atlantic Array onshore facilities (as well as any traffic impact resulting from the transport of the turbines or parts, if by road) should be discussed with Highways Agency. In the instance of housing development in Tiverton, the Highways Agency sought contributions towards improving Junction 27. As the majority of HGV movements are associated with the cable route the impact of HGVs on inappropriate roads can be minimised by HGVs using the haul road to access all compounds and the substation when possible. This may result in further distances being travelled by some vehicles, but will ensure the safety of highway users on the smaller and more sensitive roads. For example, if for some reason an HGV needed to travel from the HDD compound next to the A386 to the substation, it should travel along the haul road to the A39, along the A39, B3233, Manteo Way, Gammaton Road, leave Gammaton Road at the Woodville Farm compound and along the haul road to the substation. New temporary junctions on the A39 and A386 for site west of the Torridge, and Gammaton Road for sites east of the Torridge, should be designed and submitted to the Highway Authority for approval. This is to ensure the safety of all road users and ensure that adequate junctions are created for the number of vehicles predicted to use these junctions. Due to the length of the project, any infrastructure required at the junctions should be permanent in nature, for example; mobile traffic signals would not be acceptable,

permanently sited signals would be required to be installed, should a signalised junction be required. In order to minimise the additional level of traffic passing through the villages of St. Johns Chapel, Newton Tracey and Alverdiscott, all vehicles should be instructed and directed to use the A39, B3233, Manteo Way and Gammaton Road to access the substation, rather than using the B3232 via Newton Tracey. The A39 route offers a higher standard of road and will be safer for all highway users, although it is further to travel. As Bideford Quay is a working quay, with the transfer of clay from road transport to water transport, there are often a large number of HGVs accessing this area for deliveries. Travel restrictions should be put in place on HGVs accessing the cable route when the loading of clay is taking place. This shall form part of the construction management plan and is to reduce the number of HGVs on the road for safety reasons, and to keep traffic delay to a minimum in Bideford at these times. Further restrictions on the movement of HGVs should be implemented to avoid conflict with school start and finish times (term time only) and during the busy summer season. DCC officers are currently investigating traffic patterns in Barnstaple, and an improvement scheme for Roundswell roundabout is being designed. The impact of the onshore construction at this junction is likely to be significant in terms of HGVs and private cars used by workers getting to and from the various sites in Torridge. Although it is proposed that there will be no vehicles travelling through this junction at peak times, a full assessment at this junction is requested, and financial contributions towards any DCC improvement scheme are sought. To minimise the volume of traffic travelling to and from the substation site public transport should be provided to augment the existing, poor, public transport options in Torridge. Buses between Alverdiscott and Bideford/Barnstaple should be provided wholly or partly by RWE following discussions with bus operators in the area. This would have the added benefit of providing public transport to areas that currently have none, and increasing the currently very infrequent rural services in this area.

Appendix II To PTE/12/59

DCC Response on Landscape Project Draft ES Ref June 2012 Review method:

Desk study using IEMA’s ES review criteria

Sections specifically reviewed

Offshore ES: Chapter 12: Seascape, Landscape and V isual Resources, and associated sections including NTS an d Vol 3 Annex 12.1 Onshore ES: Chapter 6: Landscape and visual

INTRODUCTION A rapid desk study review of the above sections has been undertaken by DCC’s landscape officer using EIA review criteria (COM3-6) set by the Institute of Environmental Management and Assessment (IEMA). Limitations Due to time limitations, the review is not comprehensive, but notes key areas of concern that it is recommended that the final ES addresses. Also, due to limitations in the specialist knowledge of this reviewer, no comments are being made on the Historic Seascape Character and Terrestrial Heritage Assets parts of Chapter 12. The review is desk-based, therefore does not include a field assessment to consider the visual impact assessment based on the photomontages from selected representative viewpoints. It is understood that both Natural England, the National Trust and the North Devon AONB Partnership will be commenting on these aspects as far as offshore effects are concerned, therefore these aspects have not been further reviewed by DCC’s landscape officer in any comprehensive or systematic way. Importance to address concerns Devon County Council supports renewable energy generation in its strategic plan. It also supports the protection of the environment. The draft ES predicts that the offshore array would result in significant adverse landscape and visual impacts on Lundy Island and parts of the North Devon AONB . The Atlantic Array proposal therefore highlights a key tension between these two aims, calling for a balanced decision based on a clear understanding of the benefits and the environmental harm likely to result from the proposal. It is therefore vital that the effects of the proposals on Devon’s landscapes are properly assessed and conveyed to the decision maker. Therefore the aim of this review is: • To ensure that Chapter 6 (onshore) and Chapter 12 (offshore) of the ES follow best

practice guidelines and can be relied upon by decision-makers when assessing the effects of the proposals on the distinctive character, qualities and features of Devon’s landscapes.

• To ensure that the ES is presented in an objective and unbiased way, and conveys these significant adverse in a way that is useful, helpful and easy to understand. Given the extremely large volume of material contained within the draft ES it is vital that decision –makers are clear about the significance of environmental harm to be weighed against the

benefits of the proposals. This demands that the quality of the landscape and visual impact assessment for both onshore and offshore effects are extremely high, including the non technical summary.

• To ensure the ES contains details of adequate and appropriate mitigation/compensation

for significant adverse effects, should the decision-maker feel that the benefits outweigh the harm.

REVIEW Criteria Comment EIA CONTEXT AND INFLUENCE Alternatives See comments under mitigation Consultation Annex 3.2 Appendix 2 (List of consultees to scoping request) should

include Devon County Council (instead of Dorset CC?) Chapter 6, Table 6.13 April 2012: Devon County Council:

Request certain bullet points to be amended/added as follows, to reflect DCC record of meeting: • Welcomed sensitive cable route design, which seeks to avoid or minimise loss of significant woodland, trees and other landscape features that contribute to landscape character; • Request for 2 single frame photomontages at 50mm viewing distance to enable scale of substation to be properly understood; • Request to consider further minimisation of visual impact through colour treatment of substation buildings and reinstatement of any hedgerows removed in last 100 years (ref historic OS maps). • Request to refer to Devon Character Areas as part of Devon’s landscape character assessment evidence base

EIA CONTENT Baseline: general

The landscape baseline, including a consideration of the policy context in relation to Policy C01 of the DSP, should also refer to Devon’s landscape character assessment evidence base2.

Baseline: Offshore ES

Chapter 12 & Volume 3, Annex 12.1, Section 2 (Plann ing policy context relating to S&LVIA). This should include a consideration of the local planning policy context for assessment of offshore effects on the landscape and visual resource. Currently, Chapter 12 refers to Annex 12.1 which contains two paragraphs relating to National Policy Statement for renewable Energy Infrastructure (EN-3) (para 2.63 - 2.64). This could be interpreted to mean that local planning policies are not material considerations. However, we are certain that those relating to landscape quality and local distinctiveness of all landscapes in Devon are of importance and relevance to decision-makers in consideration of offshore effects, given the close relationship (particularly visual perceptions) between the sea and the coast. The sensitivity of Devon’s landscapes and the effects of the development upon these should be material considerations taken into account in mitigation. Therefore, Chapter 12 should fully explain the relationship between the coast and the sea in policy terms i.e. potential for offshore development to affect

2 Note that ‘Landscape Character Zones’ referred to in Devon Structure Plan policy CO1 were superseded by ‘Devon Character Areas’ in March 2012, as published on our website at: http://www.devon.gov.uk/index/environmentplanning/natural_environment/landscape.htm

matters covered by local policies. The National Planning Policy Framework gives great weight to “conserving landscape and scenic beauty in National Parks, ..…and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty” (115.). Policy C03 of the Devon Structure Plan protects AONBs but in addition to the NPPF also requires particular care to be taken to ensure that any development proposed adjacent to such areas does not damage their natural beauty. In addition, the distinctive character and valued qualities of all Devon landscapes are protected by Policy C01 of the adopted Devon Structure Plan, and Devon’s landscape character assessment evidence base now provides a robust evidence base for: (a) defining what the distinctive character and valued qualities of Devon’s landscapes are; and (b) providing strategy and guidelines on how landscapes should be protected, managed and guided towards change. This policy reflects the need for the quality and character of Devon landscapes to be sustained and enhanced for future generations since these fundamentally underpin the attractiveness of the county and the wellbeing of people who live and visit Devon. The spirit and purpose of this is also reflected in existing and emerging local plan policies. These and other relevant policies should be mentioned in the context of offshore as well as onshore effects. Scope to cross-refer to other sections of the ES where policy context is covered may be appropriate (see later points).

Baseline: Onshore ES

Chapter 6, para.6.74- & Offshore Chapter 12: Local landscape character assessment. In addition to National Character Areas and Landscape Character Types, the landscape character baseline should also refer to Devon Character Areas. These summarise the distinctive characteristics and special qualities of geographically specific areas in Devon. They sit within the National Character Areas, giving a finer grain of detail. Landscape Character Types identified at district level sit within the Devon Character Areas. Devon Character Areas have been defined in compliance with the European Landscape Convention. It is vital that the landscape baseline highlights the distinctive characteristics and special qualities of Devon landscapes affected. This enables identification of the characteristics and qualities that are at risk of harm as a result of the proposals, and this should be considered as part of the assessment of significance. Importantly, the expressions of significance (e.g. major/moderate adverse effects on…) should be precise about what special/valued qualities/characteristics would be significantly affected.

Chapter 6, para.6.7 (Planning policy context relat ing to landscape and visual impacts). This lists the relevant planning policies but should also sum up at the end with a consideration of what these are trying to achieve. In addition, it is suggested that the wording relating to Devon Structure Plan policy CO1 (3rd bullet) is amended to read: “Policy CO1 relates to landscape character and local distinctiveness and seeks to sustain and enhance the distinctive qualities and features of Devon’s landscape, ensuring that proposals are informed by and sympathetic to its character and quality. It refers to Devon’s landscape character assessment evidence base, which now comprises locally derived generic landscape character types (published by each district within Devon) which sit within a framework of geographically specific Devon Character Areas derived at county level (published by Devon County Council”.

Annex 6.1 (lists of local planning policy context related to landscape and visual impacts). This should be referred to in the offshore effects ES Chapter 12 as well as the onshore effects ES Chapter 6. It should also include the policies in full, as there is a danger of missing content, as has happened for Devon Structure Plan policy CO1.

Assessment: Offshore ES

Chapter 12 . (See also related comment on landscape baseline). This currently has insufficient evaluation of the sensitivity of the landscapes potentially affected by the offshore proposals. It fails to convey in the main chapter and in the non technical summary exactly what valued and distinctive qualities of the landscapes affected in Devon are at risk of harm from the development, as evidenced in Devon’s landscape character assessments. Best practice guidance states: “The determination of the sensitivity of the landscape resource is based upon an evaluation of each key element or characteristic of the landscape likely to be affected. The evaluation will reflect such factors as its quality, value, contribution to landscape character, and the degree to which the particular element or characteristic can be replaced or substituted”. The special qualities of landscapes relate to the ‘cultural services’ used by DEFRA to describe and evaluate the importance of ‘ecosystem services’. The North Devon AONB and Lundy Island supporting our spiritual health and wellbeing, particularly by providing places where anyone can appreciate the special qualities of wildness, remoteness from modern life and contact with raw nature, sense of escapism and tranquillity. Lundy Island in particular offers a special sense of escapism and retreat from modern life which has been valued for centuries. It is defined as Heritage Coast, whose undeveloped character should be maintained (NPPF 114). Given the significant concerns about this aspect of the proposals, the significance of the effects upon people should be clearly and succinctly described in more depth in Chapter 12 without reference to supporting annexes or tables.

Vol 1 Chapter 23 Inter-relationships. Chapter 12 predicts that the Array would result in significant adverse effects on the landscape character and visual resource of Lundy Island and the N Devon AONB. However, it does not currently attempt to assess the consequential effect on people, given that visual impact is not an absolute. The ES should identify and assess the significance of the inter-related/secondary effects on people’s health/wellbeing, and on Devon’s economy - given that the natural beauty and special qualities of Devon’s northern coast and Lundy Island attracts people to live here as well as underpinning tourism.

Assessment: onshore ES

Chapter 6: landscape impacts of construction - par a. 6.161 and elsewhere. This should refer to Devon Character Areas as well as the Landscape Character Types listed as affected. Currently the text refers to character areas when referring to landscape character types, which adds to the confusion about the LCA classification system. There is a distinction between character areas and character types made in the 2002 best practice guidance on landscape character assessment by the

then Countryside Agency. Consideration of sensitivity of the landscape character types is made (e.g. para. 6.173). However, this should relate to the distinctive characteristics and special qualities in each character area or type is to help indicate the likely sensitivity of the character area or type to the nature of the development proposal. Therefore if the construction affects a ‘secluded valley’ landscape character type that is valued for its tranquillity and rural character, the presence of construction compounds and activities for two years may be significant. The assessment should be reviewed and amended to reflect this.

Chapter 6: landscape impacts of construction: par a. 6.174. The assessment states that the cable route would have a low magnitude of impact on the ‘Estuaries local character area’ (see also point above). However, it is understood that the route will pass underground the estuary, so shouldn’t this be ‘no impact’?

Photomontages: All photomontages should include information on a recommended viewing distance and size of sheet in order to use equate to normal vision at the viewpoint. This is vital in order to allow accurate assessment of magnitude of the sub station. Currently this information is lacking for some photomontage figures. This would accord to LI best practice Advice Note 01/11 on the use of photography and photomontage in LVIA.

Mitigation: Offshore ES

Need to consider further mitigation It is appreciated that the EIA process has resulted in the current proposed array being less extensive than previously, as described under ‘Measures being adopted as part of the project’. Nevertheless, even after the adoption of these measures, the effects of the array are still assessed as significant and adverse for the landscape and visual resource of parts of the North Devon AONB and Lundy Island. There is deep concern over these currently predicted residual effects, which are considered unacceptable given their long duration (during 11 years construction and subsequent 25 year design life). The purpose of EIA is to protect the environment and ensure that the iterative design and assessment process results in a proposal with the least damaging environmental effects. Therefore it is strongly suggested that the EIA process should continue to identify mitigation measures that would further reduce the visual impacts of the array so that they would not result in significant effects on North Devon AONB and Lundy Island. For example, further visual impact mitigation could include consideration of the following:

• Scope to minimise the scale of the turbines • Scope to further minimise the extent of the array • Scope to move the Array further away from Lundy and the N

Devon coast • Scope to select turbine colours that blend them into the seascape

backdrop more • Scope to achieve the objectives of the project in alternative ways,

or in combination with other renewable energy generating options.

If there is no scope for consideration of further mitigation measures, the ES (both in Chapter 12 and in the non technical summary) should clearly state that the mitigation measures being adopted as part of the project are ineffective at minimising the magnitude of visual impacts. It should also clearly state the reasons why the further mitigation measures identified above are not being considered.

Mitigation: Onshore ES

Chapter 6, para. 6.206: Further mitigation. Restoration of landscape features is proposed on a like for like basis (as also mentioned in Chapter 7, para. 7.251). However, the cable route falls within the Northern Devon Biosphere Reserve, which is a DEFRA biodiversity offset pilot area as well as a Nature Improvement Area. Therefore a like for like basis would not accord with current strategies and Government pilot projects. DEFRA metrics should be followed for the replacement of wildlife habitats such as hedgerows and trees, and a mitigation strategy agreed through the biodiversity offset pilot administrators. Habitat compensation targets should take account of potential to strengthen Devon’s locally distinctive landscape character (see Devon Character Area profiles and Landscape Character Type profiles in Devon’s LCA evidence base for guidance). Therefore further mitigation should be included beyond the proposed ‘like for like’ basis.

EIA PRESENTATION Quality: general

The ES currently does not clearly state in the LVIA chapter conclusions and the non technical summary whether the significant effects predicted to occur on the landscape and visual resource would be positive or negative (adverse or beneficial). It is insufficient to say that the proposals would give rise to significant effects without explaining what the significant effects would be. It would be a reasonable requirement for the ES to do this, given the significance criteria used in the methodology (see Chapter 12, Table 12.9), the need to comply with best practice guidance3, and the policy context, which seeks to conserve and enhance the character and special qualities of the North Devon AONB and the undeveloped character of the Heritage Coast. An objective assessment should fully acknowledge where significant effects would be adverse. This would allow decision-makers to fully weigh up the adverse effects against the benefits of the scheme.

Quality: Offshore ES

Chapter 12. The risks posed from the development to the special qualities and characteristics of the N Devon AONB and to Lundy Island should be summarised in Chapter 12 rather than referring to annexes, given this is a key issue.

Table 12.13 explains the basis for using 278 turbines at 180m high for the photomontages. This has been judged to be a ‘worst case scenario’ visual impact compared to a smaller number of taller turbines. However, the ES does not explain the basis of this very well, and the preference for visual permeability rather than minimal height of turbines is not clear. Why would taller turbines have less visual impact than smaller ones? Would they not appear to be closer and therefore of greater magnitude? The apparent density of the larger number of turbines may be attributed to use of wireframes in black ink rather than what would actually be seen (i.e. white turbines against sky/sea).

3 LI/IEMA (2002) Guidelines for Landscape and Visual Impact assessment (2nd edition): see Appendix 6

Chapter 12 Para. 12.14 refers to Volume 3, Annex 12.1 for details of the baseline environment. However, this is insufficient to annex such information given that significant effects are predicted, the ES currently fails to convey exactly what valued qualities and characteristics of the landscape are at risk of harm from the development. As a minimum, both the NTS and Chapter 12 should refer directly to the distinctive characteristics and special qualities of the areas affected, as recorded in Devon’s landscape character assessment evidence base. It should indicate the key qualities that are particularly sensitive to the proposed development e.g. wildness referred to in Annex 12.1.

Quality: onshore ES

Generally : The assessment fails to convey that a swathe of Devon countryside over 50m wide will be laid bare for up to two years, including parts of the North Devon coastal scenery that is valued at a National level (as recognised through its designation as AONB). It fails to state that the movement and activity associated with construction is likely to have a significant effect on areas valued for their tranquillity and natural beauty for up to 2 years.

Chapter 6, para 6.281 - Summary and conclusion . The quality of the text would benefit from improvement to better convey the significant effects. For example, in para. 6.282 it states: “Effects on the local character areas would be minor or moderate adverse at worst for the duration of the works, reducing to negligible (for most character areas) or minor adverse (for the most sensitive areas) following completion of the works.” It is difficult to comprehend what this means, and attempts should be made to write in a way that makes sense to people. For example it would be better to say “During the two year construction period, the special qualities of tranquillity valued by people within a secluded valley of the Torridge Valley would be adversely and moderately affected, which is considered a significant effect”. Where reference is made to ‘character areas’ the names of the landscape should draw upon the classifications used in Devon’s LCA for landscape character types and Devon character areas e.g. ‘undulating farmland of the Bideford Bay Coast’ for LCT 5B.

Chapter 6, Figure 6.6: Close residential propertie s. It would be useful for this figure to highlight all sensitive visual receptors within the substation visibility zone, not just the location of private residences. Therefore, public rights of way should be highlighted within the zone, as indicated on DCC website: http://gis.devon.gov.uk/basedata/viewer.asp?DCCService=footpath

Chapter 6.7a: Indicative landscape plan . To ensure a clear link between assessment and design processes, it would be useful for this plan to be called ‘Indicative landscape mitigation plan’, and for each proposed element to be annotated to show its purpose/objective e.g. “proposed woodland belt to screen views of sub-station from views x and y, and to enhance biodiversity…” etc. This will also help to inform detailed landscape proposals e.g. species mix, density.

Non-technical summary: Offshore effects

The ES does not provide sufficient information for someone to understand the significant effects of the offshore proposals on Devon’s landscape and visual resource (see earlier comment under ‘assessment: ‘offshore: general). The nature and significance of effects should be clearly stated, and these

should be expressed as adverse where this reflects the results of assessment. Para. 6.50 states: “In terms of landscape character, significant effects would be likely to occur within very limited areas of the Gower AONB and more extensive areas of the North Devon AONB”. This is insufficient given that this is a key issue of concern to many. The NTS should be more clearly and directly worded, for example by stating that “the proposals would have a significant adverse effect on the outstanding natural beauty of the North Devon AONB, as perceived from a number of sections of coastline, and as represented by the photomontages predicting worst case visual impacts from viewpoints x, y and z…” etc. The significance of this should also be stated in terms of secondary or inter-related effects on health and well-being (see related points above). The NTS also currently omits mention of the significant adverse effects the proposals would have on the special qualities and visual characteristics of Lundy Island. The likely consequences of these significant adverse effects upon people’s health and well-being, and upon Devon’s economy (including tourism) should also be mentioned.

Para. 6.48 does not reflect the findings of the assessment accurately, particularly the last sentence. The residual impacts are significant and adverse upon Lundy and upon parts of the N Devon AONB. Perhaps this was meant to mean the significance of effect on the combined areas of seascape units affected? If so, how relevant is this, given that landscape or seascape units should be an area that is all that can be perceived by someone at any one time?

Non-technical summary: Onshore effects

Onshore effects: The NTS does not convey the predicted effects in a way that is easily understandable (see earlier comments). The NTS also fails to convey what the onshore impacts would be and why this is significant, given that a swathe of Devon countryside over 50m wide will be laid bare for up to two years, including parts of the North Devon coastal scenery that is valued at a National level (as recognised through its designation as AONB).

Document cross-referencing

Volume 2, Chapter 6: Landscape and Visual concerns assessment of onshore elements. It would be useful if this were stated on the cover page.