hinkley point c connection project

Somerset County Council, North Somerset Council, Sedgemoor District Council, West Somerset Council

Hinkley Point C Connection Project

Stage 4 Consultation - Technical Review

Issue | 29 October 2013

This document is without prejudice to on-going consideration and remains subject to review of further information that may be requested or received in relation to the eventual DCO application.

With support from: Arup and JMP

Also incorporating transport comments on behalf of Bristol City Council and South Gloucestershire Council


Hinkley Point C Connection ProjectStage 4 Consultation - Technical Review

| Issue | 29 October 2013

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Contents

Page

Abbreviations 0

Executive Summary 1

1 Joint Councils s42 Response 9

1.1 Introduction 9

1.2 Draft Development Consent Order (DCO) 9

2 PEIR and associated consultation material 10

2.1 Context 10

2.2 Content 10

2.3 PEI definition 11

2.4 Consultation 14

2.5 Programme 15

2.6 Alternatives 16

2.7 Policy Context 17

2.8 Methodology 17

2.9 Baseline 17

2.10 Impact Assessment 17

2.11 Mitigation 19

3 Design Commentary 21

3.1 The T pylon Option 21

3.2 Proposed Route Options 22

3.3 Temporary Construction Infrastructure 24

4 Preliminary Environmental Information Report and Topic Based Plans 26

4.1 Landscape and Visual Effects 26

4.2 Biodiversity and Nature Conservation 39

4.3 Ground Environment 45

4.4 Hydrology and Water Resources 48

4.5 Historic Environment 52

4.6 Traffic and Transport 57

4.7 Air Quality and Emissions 90

4.8 Noise and Vibration 93

4.9 Socio-Economics and Land Use 97




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Appendices

Appendix A

SCC review of access details

Appendix B

Road structures identified in North Somerset on the proposed construction traffic routes




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Abbreviations

Abbreviations used commonly in this report are:

ATC – Automatic Traffic Counter NPPF - National Planning Policy Framework

AADT – Annual Average Daily Traffic NPS – National Policy Statement

AONB – Area of Outstanding Natural Beauty NSC – North Somerset Council

CIEEM – Chartered Institute of Ecology and Environmental Management

OLE – Overhead Line Equipment

CEMP – Construction (Environmental) Management Plan

PCBs – Polychlorinated Biphenyls

CSE – Cable Sealing End (compound) PEI(R) – Preliminary Environmental Information (Report)

DCO – Development Consent Order PINS – The Planning Inspectorate, the National Infrastructure Directorate of PINS is referred to as the Examining Authority in this report

DMV – Deserted Medieval Village PFRA – Preliminary Flood Risk Assessment

DPD – Development Plan Document PRoW – Public Rights of Way

EA – Environment Agency RoWIP – Rights of Way Improvement Plan

EDFE – EDF Energy SAC – Special Area of Conservation

EIA – Environmental Impact Assessment SCC – Somerset County Council

EMS – European Marine Site SHER – Somerset Historic Environment Record

ES – Environmental Statement SoCC – Statement of Community Consultation

FRA – Flood Risk Assessment SDC – Sedgemoor District Council

GLVIA3 – Guidelines for Landscape and Visual Impact Assessment Version 3

SFRA – Strategic Flood Risk Assessment

HDV – Heavy Duty Vehicle SLA – Service Level Agreement

HPB/HPC – Hinkley Point B station/Hinkley Point C SM – Scheduled Monument

HRA – Habitats Regulations Assessment SNCI – Site of Nature Conservation Interest

IDB – Internal Drainage Board SPA – Special Protection Area

IfA – Institute for Archaeologists SPD – Supplementary Planning Document

kV – Kilovolt or 1,000 volts. SSD – Stopping Sight Distance

LCA – Landscape Character Assessment TA – Transport Assessment

LIR – Local Impact Report TBC – To Be Confirmed

LPA – Local Planning Authority WSC – West Somerset Council

LWS – Local Wildlife Site ZTV – Zone of Theoretical Visibility

National Grid – the Applicant




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Executive Summary

Somerset County Council (SCC), North Somerset Council (NSC), Sedgemoor District Council (SDC) and West Somerset Council (WSC), hereafter referred to as “the Joint Councils”, have commissioned a technical review of the draft proposals and Preliminary Environmental Information Report (PEIR) prepared by National Grid in respect of the Hinkley Point C (HPC) Connection Project. This technical review has been prepared by Arup, JMP (traffic and transport) and SCC (historic environment) on behalf of the Joint Councils. The technical review relates primarily to the administrative areas of the Joint Councils. The Joint Councils have also worked closely with both Bristol City Council (BCC) and South Gloucestershire Council (SGC) in reviewing the consultation material. Traffic and transport comments in this report are made on behalf of BCC and SGC as well as the Joint Councils.

This report has been prepared to help inform a response to National Grid regarding the draft proposals and PEIR for the HPC Connection Project. The PEIR precedes submission of an application for Development Consent by National Grid, which we understand is scheduled for early 2014.

This report is intended to complement individual responses that may have been made or may be made by individual authorities and does not seek to prejudice those responses.

Outstanding information and further structured engagement

As would be expected for a PEIR document, additional baseline data and assessment material remains to be prepared prior to its incorporation into a formal Environmental Statement (ES) to accompany the application for Development Consent.

A number of matters remain unresolved from earlier consultations and are identified again in this response. The additional information required includes:

Photomontages from all agreed viewpoints but in particular for key views such as the crossing of the Polden Hills;

A landscape scheme (as referred to in Schedule 2, Article 4 of the draft DCO) according with the principles set out in paragraph 2.8.11 of the National Policy Statement (NPS) for Electricity Networks Infrastructure (EN-5)1 and paragraph 5.10.20 of the NPS for Energy EN-12;

An ecological management strategy (as referred to in Schedule 2, Article 10 of the draft DCO) and according with the principles set out in Section 2.7 of NPS EN-5;

Ecological survey data and impact assessment of green route proposals for the 132kV undergrounding near Portishead;

A Construction Environmental Management Plan (CEMP) (as referred to in Schedule 2 Article 11 of the draft DCO);

A Transport Assessment (TA);

1 National Policy Statement for Electricity Networks Infrastructure (EN-5). Department for Energy & Climate Change, July 2011. 2 National Policy Statement for Energy (EN-1). Department for Energy & Climate Change, July 2011.




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Access Details (as referred to in Schedule 2, Article 6 of the draft DCO);

Construction Traffic Management Plan (as referred to in Schedule 2, Article 12 of the draft DCO);

A construction method statement;

Bat and otter detailed survey data;

A robust assessment of the impacts on public rights of way (PRoW) including a route wide mitigation strategy and definition of path management proposals and the duration of RoW closures, supported by PRoW condition surveys;

A footpath implementation plan (as referred to in Part 2, Article 17 of the draft DCO)(although it is recommended that this is extended to form a PRoW implementation plan);

The proposed surface and foul water drainage system (as referred to in Schedule 2, Article 8 of the draft DCO) and in particular details of surface water management during construction and operation in areas of undergrounding;

Confirmation of river crossing options (e.g. whether bridging or directional drilling) in areas of undergrounding;

Detailed flood risk assessments (FRA) including specific detail in relation to topography, flood risk management, protection, resistance or resilience;

Historic environment data as listed in PEIR Chapter 11, Paragraph 11.9;

An assessment of the impact of temporary pylons;

Clarification of actual tree and hedgerow loss;

Substation site walkover survey data;

Air quality assessment of construction traffic movements;

Information regarding the methodology for assessment of tourism impacts;

Effects on land holdings in areas of undergrounding;

Additional business survey data; and

A Health Impact Assessment (HIA).

The extensive nature of the highlighted list, which includes key mitigation strategies that are referenced in the draft DCO, limits a full understanding of the environmental effects of the project at this stage. The mitigation strategies address the principle impacts of the proposals (e.g. in relation to landscape, ecology, transport, PRoW and construction activities). Ideally, these mitigation strategies would have been available for public comment as part of the PEIR, to enable a more complete understanding of the environmental effects of the project and the intended approach to mitigation. Given the concerns of, and direct impacts upon, local communities, National Grid should consider whether further structured engagement on these strategies could be provided.

Furthermore, National Grid should engage with the Joint Councils in the development of appropriate opportunities for mitigation as the scheme becomes more defined with more environmental data and analysis being available. This will enable the Joint Councils to achieve a greater focus on and consensus through the Statement of Common Ground.




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National Grid should provide a programme for provision of these documents to ensure that there will be sufficient time and opportunity for the Joint Councils to meaningfully influence the strategies - and related requirements and planning obligations - prior to submission of the DCO application. This is considered to be key in relation to landscape and ecology where a considerable proportion of vegetation (currently only indicated as maximum extents of potential loss) will be removed for safety clearances during construction and maintenance of overhead lines; and for undergrounding works. In relation to undergrounding there is currently only a commitment to replanting of hedgerows ‘where possible’ and tree planting elsewhere only where it has been agreed.

Local policy

Due regard should be given in the ES to the development plan policies, adopted guidance and strategies of the respective planning authorities and any policies specifically related to impact assessment and mitigation of development impacts. At present, although local policies are listed within the appendix material, the reporting lacks reference to how specific local policy, guidance and strategies have informed the assessment and clarity on this point is considered necessary.

Programme of works

The proposed timescale for the submission of the Development Consent Order (DCO) and the final ES submission is challenging given the complexity of the project. Acknowledging the status of the material as PEIR, the scale of challenge is emphasised by the quantity of outstanding survey and assessment work to be undertaken.

National Grid should be encouraged to maintain a degree of flexibility around their DCO programme as the Environmental Impact Assessment (EIA) develops. National Grid’s proposal to engage with the Joint Councils regarding draft chapters of the DCO is welcomed in this respect and this consultation response has been framed around achieving this proposal alongside the agreed objectives set out in the Planning Performance Agreement and associated work packages.

Health impacts

During the Joint Councils informal engagement with communities, concern has been raised over the potential health impact in its widest sense of the connection during the construction and operational phases. At scoping it was recommended by the Joint Councils that the ES should assess health implications via a Health Impact Assessment. It is noted that National Grid has not taken the opportunity to provide this information as part of the PEIR submission and it is recommended that this should be provided in advance of the formal DCO submission.

Proposed Route Options and Alternatives

National Grid has set out their process of assessing options and alternatives for the current proposed scheme, from strategic, through to more detailed routing and siting studies. At the strategic level National Grid has undertaken a variety of studies to evaluate whether the use of underground/undersea cables instead of an overhead line could be justified for parts of the route. At the Draft Route Consultation, National Grid investigated different options of undergrounding and overhead lines along the entire route.

T pylon: A key distinction between previous consultations and the current consultation is the confirmation that the ‘T pylon’ is proposed to be extensively included within the project. The use




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of the T pylon is set out as the key visual mitigation measure for the scheme relative to the lattice pylon. However, the T pylon option has been introduced relatively late into the EIA process and there are considerable uncertainties relating to its construction as it is largely untested within the British environment. As the T pylon has not been used before, there is a lack of existing evidence available to support conclusions drawn in relation to the relative merits of the T pylon vs. the lattice pylon.

Similarly the 400kV route alignment has been developed in accordance with the Holford Rules, which were developed for overhead lines constructed using the more visually permeable lattice pylon structure. National Grid should provide comment on the applicability of the Holford Rules to the new structure and this be provided to the Councils for consideration in advance of an application for Development Consent.

National Grid has provided a Pylon Design Options Report as part of the proposals and sets out basic design, construction and operation principles for the pylon in the PEIR. The material highlights the potential for the reduced height of the T pylon to reduce visual impacts, allowing it to hide more easily behind topography and woodland. This is offset by the acknowledgement that due to its solid structure the T pylon has potential to be more visually intrusive than a traditional pylon in near distance views and where it is backgrounded against terrain. There is potential that the solid structure of the T pylon tower also has potential to be more visually intrusive over long distance views relative to the more porous lattice tower.

In addition, there remains uncertainty regarding:

The difference in construction and operational impacts on landscape character and elements, including trees and hedgerows due to the wider maximum clearance required for the pylon arms and the greater lateral limits of deviation required for the T pylon (an additional 20m lateral deviation);

The different construction, access and operational maintenance requirements of the T pylon;

Possible differences in noise characteristics of the T pylon during wet conditions;

The potential for stability issues associated with construction in deep peat in the levels; and

The potential implications for bird flight paths of the new line arrangement, as highlighted in EN-5.

Given the extensive uncertainty around the T pylon, National Grid should provide a clear mitigation strategy tailored to the T pylon design and make appropriate provision for mitigating any unforeseen impacts of the T pylon. In accordance with the requirements of EN-5 the mitigation strategy should include both on and offsite mitigation planting as one consideration in relation to landscape impacts.

Mendips AONB undergrounding

National Grid’s commitment to minimising visual impacts on the Mendips AONB is recognised through undergrounding of this section of the route. Undergrounding proposals for the Mendips are largely presented in terms of benefits through reduced visual and landscape impact on the Mendips. Whilst the removal of overhead cables is welcomed, the increased hedgerow loss and associated ecological impact, archaeological impacts, drainage impacts, Grade 1 agricultural land take and the longer term operational impact of the 400kV undergrounding are considered to be substantial. National Grid should further consider the extent to which these effects could




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be moderated as part of the DCO submission in conjunction with agreement of appropriate mitigation with the Joint Councils.

The PEIR sets out potential means of crossing watercourses through undergrounding sections but lacks certainty regarding the approach that will be adopted. The choice of directional drilling versus cable bridges has a potentially significant implication for landscape, ecology and surface water management as well as any planning requirements and obligations, which the Joint Councils will wish to engage with National Grid on.

Portbury vs. Portishead Options

The Portishead route alignment largely follows the existing overhead line alignment, with some modifications to the alignment increasing the offset distance of the alignment from properties relative to the 132kV route alignment. Given the current context of overhead power lines in the landscape it is considered that route option B will be less sensitive to change and the landscape better able to accommodate the proposed 400kV alignment.

Whilst the relative merit of different 132kV undergrounding routes to Portishead substation has been set out, it is considered that insufficient attention has been given to the assessment of specific impacts relating to the 132kV (green route) underground works on the Portbury Wharf Nature Reserve (designated as a Site of Nature Conservation Importance and located adjacent to the Severn Estuary European Marine Site). This information should be provided as part of further structured engagement prior to the main DCO submission.

Somerset Levels and Moors route alignment

The proposed route alignment generally moves the route away from larger areas of settlement and in some cases provides a substantial offset from existing communities relative to the pre-existing route alignment (e.g. at East Huntspill). However, locally isolated receptors such as Cripps Farm would be much closer to the proposed development and require detailed mitigation proposals.

There are concerns regarding the route through Mark and Tarnock. National Grid should provide full details of mitigation options available in this area. Where mitigation is not possible, National Grid will need to set out appropriate compensatory measures.

National Grid has opted to use lattice pylons for the 132kV route from the proposed Sandford Substation to the 132kV Weston-super-Mare AT route, which avoids the potential ecological, landscape and archaeological impacts associated with undergrounding this section of route. This is considered to be appropriate, although local receptors such as Rookery Farm would be closer to the alignment and require detailed mitigation proposals.

The existing 132kV route in the vicinity of Moorland Park runs close to the existing gypsy and traveller site. The opportunity should be taken to move the proposed higher voltage 400kV T pylon route further eastwards to create a greater offset distance between the proposed line and the gypsy and traveller site rather than drawing the route closer to the community of Moorland Park.

National Grid should confirm that statutory safeguarding zones have been observed, where the route alignment approaches much closer to properties than the 132kV route.

National Grid has stated that overall, the proposed development would have an adverse effect on archaeological remains, built heritage and the historic landscape in the areas around




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Tickenham and Stone Edge Batch. Listed structures around Tickenham Church and the listed buildings in the vicinity of Stone Edge Batch may experience adverse effects. Further assessments are required to minimise the impact on Tickenham Church and a clear mitigation strategy agreed upon to lessen any impacts on this listed building.

Substations and Cable Sealing End (CSE) Compound

The CSE compound near the M5 at Biddisham has potential to impact on visitors’ views of Sedgemoor when travelling on the M5. As currently presented the landscape screening proposed for the CSE compound requires further consideration, particularly in light of the uncertainty regarding site levels, which could require elevation of the CSE compound above its current proposed levels to address flood risk. Detailed mitigation proposals should be provided to the Joint Councils and consulted upon as part of a structured engagement process prior to submission of the application for Development Consent.

The general location of the proposed Sandford Substation has been agreed and supported by a previous North Somerset Planning and Regulatory committee (25 July 2012), which made recommendations for reducing the visual intrusion of the buildings and contributing to sustainable development through inclusion of a grass roof and measures to assist bat roosting and foraging. As a result of the proposed substation, NSC will be providing specifications to National Grid regarding any realignment to the Strawberry Line so that the proposals for the substation to be submitted within the DCO will be able to include updated and agreed details on the continuation of the Strawberry Line through the site and refined landscape planting proposals, which would contribute to mitigation of the landscape and visual amenity impacts that will arise from the introduction of a new built form into the rural landscape.

Temporary Construction Infrastructure

There are a number of uncertainties relating to the proposed temporary construction infrastructure. These include:

The potential impacts of the temporary transmission line diversions, which may require full size temporary pylons to be constructed;

The environmental criteria used to select the substantial temporary site compounds and the likely impact of the compound operation on local residents;

The potential impact of temporary haul roads and associated accesses (bellmouths); and

Further detail is required in relation to the potential impacts and mitigation of this temporary infrastructure on the local road network and particularly on tourism.

The PEIR indicates a significant requirement for land take associated with temporary haul roads and bellmouths, in relation to both the new route option and the removal of existing overhead lines. At present, there is a lack of information supplied to validate the design and footprint of the proposed access arrangements. Detailed technical audits will be required for each access and it is envisaged that formal agreement on access design will be sought from the Highways Authority prior to submission of the DCO.

As part of further structured engagement, National Grid should also provide clarification regarding the potential need for retention of the temporary access infrastructure to allow for maintenance during the operational period.




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Construction mitigation measures should be clearly articulated within the Construction Environmental Management Plan (CEMP) referred to in Schedule 2 Article 11 of the draft DCO. This document should be made available as part of a structured engagement process prior to submission of the DCO.

Public rights of way and tourism impacts

The PEIR provides limited information in relation to path management; alternative routing options; the impact on PRoW used as, and crossed by construction access routes; and the definition of what constitutes a short duration closure. This information should be submitted for structured engagement prior to the main DCO submission. It is imperative that engagement is undertaken with the Highways Authority and Joint Councils in advance of the submission to ensure that mitigation proposals for the extensive diversions, two identified closures and footpath alterations are robust and appropriate and do not impact adversely on the important tourism offer of the affected area.

Particular focus is required on the cumulative effect of the proposals on the PRoW network around Hinkley Point, which has been subject to extensive revision relating to the new nuclear build proposals and will also see a reduction and changes to the PRoW network in the locality due to the proposed Bristol Ports Company’s compensatory habitat scheme.

Additional cumulative impacts of the proposals where users of PRoW may experience sequential visual and landscape impacts several times over a journey are also considered to be key to the PRoW user experience. The current assessment would benefit from a clear assessment of sensitivity of each receptor and the magnitude of change that will be experienced.

Given the extent of impacts on the PRoW network, it is considered that the formal application for Development Consent would benefit from a separate chapter addressing this issue and that National Grid should undertake structured engagement on this material in advance of formal submission.

Cumulative effects

The cumulative effects assessment is considered to be of limited scope at present and does not adequately consider:

Changes in landscape character from one with electrical infrastructure present, to one dominated by electrical infrastructure (e.g. around the Hinkley Point power stations and at Horsey Levels);

The cumulative construction traffic impact on the C182 and the local road network crossing Wick Moor;

Local residential receptors affected by HPC construction works;

Further impacts on the PRoW network around HPC; and

Cumulative construction worker transport impacts.

Consequently mitigation proposals may be underestimated at present.

In addition, the assessment does not touch on the additive effect of multiple new bellmouths, temporary accesses and vegetation clearance that could contribute to more significant




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ecological, visual and amenity impacts. This requires further consideration in the final DCO submission and through on-going structured engagement.

The potential for the cumulative projects to amplify amenity effects related to traffic and noise is recognised in the socio-economic section of the PEIR. This is a major concern for the Joint Councils especially regarding the reputational risk and the impacts of traffic, landscape and noise on tourism within the region.




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1 Joint Councils s42 Response

1.1 Introduction 1.1.1.1 Somerset County Council (SCC), North Somerset Council (NSC), Sedgemoor

District Council (SDC) and West Somerset Council (WSC) hereafter referred to as “the Joint Councils” have commissioned a technical review of the draft proposals and Preliminary Environmental Information Report (PEIR) prepared by National Grid in respect of the Hinkley Point C (HPC) Connection Project. This technical review has been prepared by Arup, JMP (traffic and transport) and SCC (historic environment) on behalf of the Joint Councils. The technical review relates primarily to the administrative areas of the Joint Councils. The Joint Councils have also worked closely with both Bristol City Council (BCC) and South Gloucestershire Council (SGC) in reviewing the consultation material. Traffic and transport comments in this report are made on behalf of BCC and SGC as well as the Joint Councils.

1.1.1.2 This report has been prepared to help inform a response to National Grid regarding the draft proposals and PEIR for the HPC Connection Project. The PEIR precedes submission of an application for Development Consent by National Grid, which we understand is scheduled for early 2014.

1.1.1.3 This report is intended to complement individual responses that may have been made or may be made by individual authorities and does not seek to prejudice those responses.

1.1.1.4 This report also references on-going discussions between National Grid and the Joint Councils through the thematic group meeting sessions.

1.1.1.5 This report is subdivided into four main sections:

Section 1: Introduction;

Section 2: Providing a thematic commentary on the s42 consultation material;

Section 3: Providing commentary in relation to the proposed route (and route options) and associated infrastructure; and

Section 4: Providing a topic by topic commentary of the PEIR material.

1.2 Draft Development Consent Order (DCO) 1.2.1.1 A review of the Document 4.1 Draft DCO and the Explanatory Memorandum will be

submitted by the joint Councils separately to this report.




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2 PEIR and associated consultation material

2.1 Context 2.1.1.1 The consultation material includes a preliminary assessment of effects associated

with the approximately 55km, 400kV route connection between Hinkley Point in West Somerset and Seabank Substation near Avonmouth in the City of Bristol and associated works including:

Construction of new substations at HPC, Shurton in West Somerset, near Sandford in North Somerset and at Aust in South Gloucestershire;

New Cable Sealing End (CSE) compounds near the M5 in Sedgemoor District and on the Horsey Levels;

New 400kV overhead connection between the proposed Shurton Substation and the existing 400kV lines north of Zipe Farm, West Somerset using lattice pylons and between the existing Hinkley Point 400kV Substation and Shurton Substation;

New 400kV overhead connection between the 275kV overhead line north of Horsey and the 400kV overhead line to Melksham using lattice pylons;

New 400kV overhead connection from the Melksham 400kV line to the new CSE compound near the M5 using T pylons;

New 400kV underground line connection from the M5 CSE Compound, through the Mendips to the proposed Sandford Substation;

New 400kV overhead connection from the proposed Sandford Substation to Seabank substation using T pylons;

New 132kV connections from the proposed Sandford Substation to the Weston-super-Mare 132kV existing line using lattice pylons;

New 132kV underground line connection from Nailsea to Portishead substation; and

Removal of existing 132kV Western Power Distribution overhead lines between the existing Bridgwater Substation and Portishead Substation, between Portishead Substation and Avonmouth Substation and on part of the route between Avonmouth Substation and Seabank Substation.

2.1.1.2 A full, detailed description of the proposed works is presented in PEIR Document 2.1, Chapter 3.

2.2 Content 2.2.1.1 The consultation material comprises:

Volume 1: A guide to the consultation

2.2.1.2 This section includes plain English documents to explain the proposals. It includes Project News, an Overview Report, the Feedback Form and Document Navigation Booklet. National Grid's effort to make the consultation material accessible to a wide audience is welcomed.




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Volume 2: Preliminary Environmental Information Report (PEIR)

2.2.1.3 The PEIR includes draft survey and assessment material that will form the core of the formal Environmental Statement (ES) submission to accompany the DCO. It contains methodological and thematic sections that are consistent with the headings set out in National Grid’s Scoping Report. This material is the main subject of this technical review.

Volume 3: Plans

2.2.1.4 The detailed plans show where National Grid proposes to undertake work. The plans include information such as the maximum potential extent of vegetation loss during construction.

Volume 4: Draft Development Consent Order (DCO)

2.2.1.5 The DCO details the legal powers National Grid are seeking in order to build and operate the connection. It proposes certain draft ‘Requirements’, similar to planning conditions, which will apply if consent is granted. Key mitigation strategies are referred to within the draft, in particular Schedule 2 requirements, such as landscape and ecological management plans. However, those strategies have not been provided for consultation, which has prevented the Joint Councils from developing a full understanding of the environmental effects of the project. There is also a Draft Explanatory Memorandum which explains the purpose of the Draft DCO. Considerable work is required to develop the DCO articles and requirements until they are fit for purpose to authorise, control and mitigate a project of national significance.

Volume 5: Other documents

2.2.1.6 This volume includes a series of technical reports that discuss the impact of different pylon options, environmental appraisal of different route sections such as 132kV undergrounding, 132kV local diversions and details other pylon types to be used e.g. the Cable Sealing End Platform Pylon (CSEPP).

2.3 PEI definition 2.3.1.1 According to the Planning Inspectorate’s Advice Note 73, PEI is defined in the

Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 (hereafter referred to as “the EIA Regulations 2009”) as: “information referred to in Part 1 of Schedule 4 (information for inclusion in environmental statements) which (a) has been compiled by the Applicant; and (b) is reasonably required to assess the environmental effects of the development (and of any associated development).”

2.3.1.2 The advice note states that “Applicants should be aware that the level of detail provided in the PEI may affect the level of detail provided in the consultees’ responses and how useful this is to inform the EIA and the design of the proposed development.”

3 Advice Note Seven: Environmental Impact Assessment: Screening, Scoping and Preliminary Environmental Information Version 4. Planning Inspectorate, July 2013.




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2.3.1.3 Schedule 4 of the EIA Regulations 2009 requires the following information to be provided:

“Description of the development, including in particular –

(a) a description of the physical characteristics of the whole development and the land-use requirements during the construction and operational phases;

(b) a description of the main characteristics of the production processes, for instance, nature and quantity of the materials used;

(c) an estimate, by type and quantity, of expected residues and emissions (water, air and soil pollution, noise, vibration, light, heat, radiation, etc) resulting from the operation of the proposed development.

An outline of the main alternatives studied by the applicant and an indication of the main reasons for the applicant’s choice, taking into account the environmental effects.

A description of the aspects of the environment likely to be significantly affected by the development, including, in particular, population, fauna, flora, soil, water, air, climatic factors, material assets, including the architectural and archaeological heritage, landscape and the inter-relationship between the above factors.

A description of the likely significant effects of the development on the environment, which should cover the direct effects and any indirect, secondary, cumulative, short, medium and long-term, permanent and temporary, positive and negative effects of the development, resulting from:

(a) the existence of the development;

(b) the use of natural resources;

(c) the emission of pollutants, the creation of nuisances and the elimination of waste, and the description by the applicant of the forecasting methods used to assess the effects on the environment.

A description of the measures envisaged to prevent, reduce and where possible offset any significant adverse effects on the environment.

A non-technical summary of the information provided under paragraphs 1 to 5 of this Part.

An indication of any difficulties (technical deficiencies or lack of know-how) encountered by the applicant in compiling the required information.”

2.3.1.4 The advice note also references Department for Communities and Local Government (DCLG) Guidance4 which advises applicants to provide ‘sufficient preliminary environmental information to enable consultees to develop an informed view of the project. The information required will be different for different types and sizes of projects and it may differ depending on the audience of a particular consultation… The key issue is that the information presented must provide clarity to all consultees.”

4 DCLG Guidance – Planning Act 2008: Guidance on the Pre-Application Process (January 2013), paragraph 73.




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2.3.2 Outstanding information 2.3.2.1 The PEIR highlights the outstanding information that National Grid requires to

complete a statutory EIA under the EIA Regulations 2009. National Grid sets out in paragraph 1.3.4 of PEIR Document 2.1 that the outstanding information identified within the PEIR is the information that it “currently anticipates will subsequently be provided in the ES to accompany the DCO”. Since the presentation of a different scope of information would tend to undermine the value of PEI (and the consultation it is intended to inform), this technical response is based on the assumption that the outstanding information will be the minimum additional information provided by National Grid.

2.3.2.2 Key information that is considered to be essential to understand the full impact of the proposals includes:

Photomontages from all agreed viewpoints but in particular for key views such as the crossing of the Polden Hills;

A landscape scheme (as referred to in Schedule 2, Article 4 of the draft DCO) and according with the principles set out in paragraph 2.8.11 of the National Policy Statement (NPS) for Electricity Networks Infrastructure (EN-5)5 and paragraph 5.10.20 of the NPS for Energy EN-16;

An ecological management strategy (as referred to in Schedule 2, Article 10 of the draft DCO) and according with the principles set out in Section 2.7 of NPS EN-5;

Ecological survey data and impact assessment of green route proposals for the 132kV undergrounding near Portishead;

A Construction Environmental Management Plan (CEMP) (as referred to in Schedule 2 Article 11 of the draft DCO);

A Transport Assessment (TA);

Access details (as referred to in Schedule 2, Article 6 of the draft DCO) including details of construction access routes and accesses as well as proposed traffic flows to validate the design layouts;

Construction Traffic Management Plan (as referred to in Schedule 2, Article 12 of the draft DCO);

A construction method statement;

Bat and otter detailed survey data;

A robust assessment of the impacts on PRoW including a route wide mitigation strategy and definition of path management proposals and the duration of RoW closures, supported by PRoW condition surveys;

5 National Policy Statement for Electricity Networks Infrastructure (EN-5). Department for Energy & Climate Change, July 2011. 6 National Policy Statement for Energy (EN-1). Department for Energy & Climate Change, July 2011.




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A footpath implementation plan (as referred to in Part 2, Article 17 of the draft DCO)(although it is recommended that this is extended to form a PRoW implementation plan);

The proposed surface and foul water drainage system (as referred to in Schedule 2, Article 8 of the draft DCO), in particular details of surface water management during construction and operation in areas of undergrounding;

Confirmation of river crossing options (e.g. whether bridging or directional drilling) in areas of undergrounding;

Detailed flood risk assessments (FRA) including specific detail in relation to topography, flood risk management, protection, resistance or resilience;

Historic environment data as listed in PEIR Chapter 11, Paragraph 11.9;

An assessment of the impact of temporary pylons;

Clarification of actual tree and hedgerow loss;

Substation site walkover survey data;

Air quality assessment of construction traffic movements;

Information regarding the methodology for assessment of tourism impacts;

Effects on land holdings of underground sections of the route;

Additional business survey data; and

A Health Impact Assessment (HIA).

2.3.2.3 In particular, it is not considered that meaningful detail has been provided in relation to landscape, transport, PRoW ecology or construction management to provide clarity regarding the residual environmental effects of the scheme and to enable informed responses to be provided in relation to these subjects. Consequently it is recommended that further, structured engagement is undertaken in relation to these and other matters highlighted within this technical review.

2.4 Consultation 2.4.1.1 The PEIR illustrates the previous consultations with the local community, local

authorities, other statutory bodies and consultees and reflects incorporation of certain recommendations made at scoping (e.g. in relation to hydrology and breaking out of pylon foundations). However we note that certain issues raised repeatedly through consultation still remain unresolved (including matters identified as outstanding information), for example:

The lack of a justified study area for landscape has been raised through the thematic group meetings and the Joint Councils’ Scoping Response;

Further detailed assessment of value, susceptibility and sensitivity of the landscape and visual receptors at a local rather than national character area to avoid averaging of effects. For example, the moderate sensitivity assigned to both the Polden Hills LCA and the Levels LCA, when the susceptibility of the two LCAs is different;




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Lack of reference to existing green infrastructure strategies in developing mitigation proposals;

The scope and extent of the Transport Assessment and the ability to complete such an assessment with a robust evidence base within the timescales of the proposed timetable;

The appropriateness of dormice survey methodologies has been raised through the thematic group meetings and the Joint Councils’ Scoping Response;

The limited scope of geophysical survey and trial trenching;

Temporary access locations, since the PEIR includes additional temporary accesses for pylon removal that have not been subject to previous consultation;

Effects on land holdings for the undergrounding section of the route;

The limited coverage of the business survey;

Effects on tourism; and

The lack of an accompanying Health Impact Assessment (HIA).

2.4.1.2 Although thematic group meetings have been held to address issues such as ecology and landscape, the dated nature of certain base datasets (e.g. air quality) suggests that a wider structured engagement process extending to other topic areas would improve the quality of the final DCO submission. No approach has been made by National Grid for information regarding any proposals resulting from public consultation for the SCC Rights of Way Improvement Plan (RoWIP), which was referred to in the Joint Councils response to the Scoping Report.

2.4.1.3 The provision of detailed route information and mapping is welcomed. It is noted that the summary level information provided in the Public Consultation Overview Report, which is likely to strongly inform the public view of the proposals, lacks a clear articulation of the scope, nature and duration of temporary works that will be required during construction of the proposed route. Features such as entrance bellmouths and the extensive range of temporary access roads are not clearly highlighted. As part of the DCO submission it is expected that this information would be clearly presented as part of the non-technical summary.

2.4.1.4 Key mitigation strategies referred to in the draft DCO as discussed under Section 2.3.2.2 would ideally have been available for public comment as part of the PEIR, to enable a more complete understanding the environmental effects of the project and the intended approach to mitigation.

2.4.1.5 National Grid should engage with the Joint Councils in the development of appropriate opportunities for mitigation as the scheme becomes more defined with more environmental data and analysis being available. This will enable the Joint Councils to achieve a greater focus on, and consensus through, the Statement of Common Ground.

2.5 Programme 2.5.1.1 Despite the considerable efforts expended to date in compiling the PEI and

developing the route options and the preferred route, the proposed timescale for the formal DCO submission as set out appears to be challenging given the complexity of




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the project and the quantity of outstanding information highlighted in sections 2.3.2.2 and 2.4 of this report.

2.5.1.2 National Grid should provide a programme for provision of these documents to ensure that there will be sufficient time and opportunity to meaningfully influence the strategies - and related requirements and planning obligations - prior to submission of the DCO application. This is considered to be key in relation to landscape and ecology where a considerable proportion of vegetation (currently indicated as maximum extents of potential loss) will be removed for safety clearances during construction and maintenance of overhead lines (Chapter 3 paragraph 3.5.70); and undergrounding works where there is currently only a commitment to replanting of hedgerows ‘where possible’ and tree planting elsewhere only where it has been agreed (Chapter 3 paragraph 3.6.13). Given the concerns of and direct impacts upon communities, the Joint Councils consider that a further structured engagement on these strategies is required.

2.6 Alternatives 2.6.1.1 Chapter 2 of the PEIR sets out the background to the project and highlights the

need for upgrade of the transmission network.

2.6.1.2 A key alternative option promoted in the previous route connection studies is the undergrounding of the 400kV route within the Mendips AONB and the removal of the existing 132kV overhead route as set out in Section 2 of this report. Key aspects of the undergrounding giving rise to alternative options such as the method of crossing watercourses should be clearly articulated within the final DCO submission.

2.6.1.3 The assessment of alternatives within PEIR Document 2.1 lacks reference to the alternative pylon options (T pylon vs. lattice pylon and CSEPPs). This information is in part provided within Volume 5, although not cross referenced in the alternatives discussion. Given that the T pylon would be a new structure in the English countryside, it is considered that the alternatives assessment submitted with the DCO should clearly set out the reasons for selection of the T pylon, including discussion as to whether the character of these structures will be at odds with, contribute to or reinforce the character of the receiving landscapes. This could lead to additional mitigation requirements or contributions to landscape scale mitigation.

2.6.1.4 National Grid should also set out what the use of new pylon technology means for standard routing guidelines such as the Holford Rules7, which were developed for the lattice pylon and whether additional factors such as noise emissions from pylons during wet conditions may be more significant for the T pylon technology.

7 The “Holford Rules” are a series of planning guidelines first developed in 1959 by Lord Holford, adviser to the then Central Electricity Generating Board on amenity issues. They were reviewed in the 1990s by National Grid. The rules are not published as a single work but they are referred to in a number of planning publications including Visual Amenity Aspects of High Voltage Transmission by George A. Goulty (1989) and Planning Overhead Power Line Routes by RJB Carruthers (1987) Research Studies Press Ltd, Letchworth. Notes and explanations of the Holford Rules are available on the National Grid website http://www.nationalgrid.com/NR/rdonlyres/E9E1520A-EB09-4AD7-840BA114A84677E7/41421/HolfordRules1.pdf




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2.7 Policy Context 2.7.1.1 The PEIR sets out the national policy context for consideration of the scheme

proposals and states that local planning policy does not set the tests for the acceptability of nationally significant infrastructure projects (Document 2.1 paragraph 4.1.5). However, the document acknowledges the potential for relevant local policies to inform the assessment of effects and lists local policy at Appendix 4a. Beyond providing a policy summary, the reporting lacks reference to how specific local policy, guidance and strategies have informed the assessment and clarity on this point is considered necessary, particularly in light of relevant landscape scale policy such as SDC’s Policy D20 Green Infrastructure.

2.8 Methodology 2.8.1.1 The overarching methodologies for assessment are broadly in line with that set out

in the National Grid Scoping Study and address some comments raised previously by the Joint Councils in relation to scope of assessment (e.g. in relation to hydrology, ground environment and traffic and transport). The clarification of temporary /short term effects having a duration of up to 5 years is welcomed, although it is noted that the HPC new nuclear project defined 1-5 years as Medium term, rather than short term, acknowledging the more significant effect of longer duration impacts.

2.8.1.2 However, the PEIR does not address certain methodological concerns raised previously by the Joint Councils as highlighted in Section 2.4 Consultation of this report. In part, these issues can be attributed to the preliminary nature of the reporting (e.g. where data collection is on-going), however it is unclear why the landscape and visual study areas and dormice survey methodology issues remain unresolved, given the previous focus on these issues.

2.8.1.3 Further topic specific issues are identified within Section 3.3.2.4 of this report.

2.9 Baseline 2.9.1.1 As would be expected for PEI, the baseline material requires further expansion.

Additional survey and baseline information to be provided is listed within the relevant topic chapters. This information should be provided as part of a structured engagement process prior to National Grid’s application for Development Consent.

2.10 Impact Assessment 2.10.1.1 The absence of certain baseline information highlighted above means that

conclusions drawn in relation to impacts and mitigation in the relevant topic chapters must be acknowledged as preliminary at this stage (in line with their status as PEI). The preliminary conclusions focus heavily on the beneficial aspects of the proposals for example, undergrounding in the Mendips and removal of 132kV overhead lines reducing landscape impacts, however the adverse effects of the undergrounding on landscape and views due to loss of tree and hedgerow cover are not considered to be fully articulated at this stage.




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2.10.1.2 The assessment of the 400kV route is reasonably comprehensive given the stage of assessment, however aspects of the proposals such as the 132kV undergrounding near Portishead lack detail at this stage. Consequently the impact on sensitive receptors in this location such as Portbury Wharf Site of Nature Conservation Interest (SNCI) is not fully presented at this stage.

2.10.1.3 It is also considered that temporary construction effects, e.g. in relation to erection of temporary pylons near Horsey Deserted Medieval Village (DMV) and in relation to the presence and operation of temporary construction compounds have not been fully articulated at present (e.g. the air quality assessment lacks reference to the establishment and operation of construction compounds).

2.10.1.4 The conclusions drawn in relation to the landscape and visual impact of the T pylon vs. the lattice pylon require further justification. Instances where impacts may be underestimated are identified in relation to the historic environment (refer to Section 5.5 of this report) and on the PRoW network (refer to Section 5.6 of this report).

2.10.1.5 The scale of development and the focus on route sections has the potential to dilute or obscure key local effects for example by focusing on national character area rather than on local landscape character areas impacts. This is noted in the landscape assessment for Puriton Ridge where the susceptibility of adjacent character areas has been averaged, leading to a potential underestimation of the overall impact of the proposals. It is considered that increased focus on local landscape character area impacts is required.

2.10.1.6 The potential impact of contamination on workers during construction and decommissioning in potentially contaminated sites (such as existing substations) is not fully considered at present and should be addressed within the final DCO submission.

2.10.1.7 It is considered that potential effects associated with the T pylon foundation lack detail as presented. The final DCO should include detailed consideration of stability, groundwater and drainage impacts.

2.10.1.8 Critically, the assessment of environment effects assumes application of mitigation such as a landscape and ecological strategy that have yet to be developed or consulted upon. Therefore conclusions drawn must be treated with considerable caution. It is considered that planting to replace mature vegetation lost during construction will take longer than 15 years to establish therefore the current conclusions of no impact after 15 years are considered to be inappropriate and should be reconsidered in the final DCO submission.

2.10.1.9 At present, only a limited view can be given as to the adequacy of the transport impact. There is concern that until the source of the material for the proposed access routes/site enabling works have been identified that the traffic assignment within the Transport Assessment would at best be flawed and potentially miss out key junctions that would need to be assessed. This information is essential to enable an appropriate impact assessment of the proposal for traffic, air quality and noise.

Cumulative effects

2.10.1.10 The cumulative effects assessment does not consider the extent that the Hinkley Point C proposals could lead to a change in landscape character from one with electrical infrastructure present, to one dominated by electrical infrastructure (e.g.




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around the Hinkley Point power stations and at Horsey Levels). In relation to traffic the cumulative construction worker transport impacts are not considered. Consequently the extent of the impact may be underestimated at present.

2.10.1.11 No specific cumulative effects have been stated for PRoW. The sequential cumulative impact that might occur several times to receptors, e.g. using the local footpath network, has been touched on within the assessment. However, the assessment would benefit from a clear assessment of sensitivity of each receptor and the magnitude of change that will be experienced. In addition, the assessment does not consider the totality of effect resulting from new bellmouths, temporary accesses and vegetation clearance that could contribute to more significant visual and amenity impacts. This requires further assessment in the final DCO submission and through on-going structured engagement.

2.10.1.12 Consideration also needs to be given to the effect of further impacts on the rights of way network in the vicinity of the Hinkley Line Entries as noted in the Secretary of State’s Scoping Opinion. Site preparation works for Hinkley Point C have resulted in the long term closure of approximately 9km of PRoW in the parish of Stogursey. In addition the Bristol Ports Company’s habitat creation scheme will also see a reduction and changes to the PRoW network in the locality. Therefore this area is already subject to a significant reduction in the number of PRoW available to residents and visitors to the area, including the South West Coast Path. Further interference or reduction in the number of paths available for use in this area will impact on local users. It is considered that at present the significance of effects in relation to footpaths may be underestimated. Detailed discussions are required with both the Highways Authority and the Joint Councils in this respect.

2.10.1.13 National Grid’s consideration of the potential impact of the Bristol Port Company scheme proposal, which will see parts of the road network closed in the later part of the 2010’s, within the final TA to accompany the ES is welcomed, National Grid should consider the cumulative impact of HGV movements associated with the proposed development, with Hinkley Point C and with the Bristol Port Company scheme especially in relation to the C182, local residential receptors affected by HPC construction works and the local road network crossing Wick Moor. Whilst these routes may be periodically subject to HGV traffic, the sheer volume of activity during construction of HPC has the potential to significantly affect the local community.

2.10.1.14 Paragraph 15.5.3 of the socio-economic chapter acknowledges the ‘potential for the cumulative projects to amplify amenity effects related to traffic and noise’. This is a major concern for the Joint Councils especially regarding the reputational risk and the impacts of traffic, landscape and noise on tourism within the region.

2.11 Mitigation 2.11.1.1 The PEIR references fundamental mitigation strategies that have yet to be provided

or consulted upon. This includes strategic mitigation mentioned in the draft DCO, such as:

Landscape scheme (Schedule 2, Article 4);

Surface and foul water drainage system (Schedule 2, Article 8);

Ecological management strategy (Schedule 2, Article 10);




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A Construction Environmental Management Plan (CEMP) (Schedule 2 Article 11);

Access Details (as referred to in Schedule 2, Article 6);

Construction Traffic Management Plan (Schedule 2, Article 12);

Footpath implementation plan (Part 2, Article 17); and

Archaeology (Schedule 2 Article 17).

2.11.1.2 The adequacy of these key mitigation proposals cannot therefore be commented on at this stage (although detailed comments in relation to archaeological mitigation are set out in Section 4.5.7 of this report). In addition, mitigation measures are presented as a definitive list. Based on the nature of the information supplied and outstanding information identified by National Grid, the mitigation proposals must be regarded as substantially incomplete and work in progress.

2.11.1.3 Further detailed engagement is required between the Joint Councils and National Grid to ensure that the mitigation proposals adequately reflect the scale of impact experienced at a local level. Mitigation measures should be specific to a location, be based on the mitigation hierarchy (avoid, minimise, abate, repair, compensate) approach and comprise a mixture of on- and offsite measures. Detailed engagement on this subject will support the Joint Councils desire to achieve a higher level of agreement in the Statement of Common Ground.

2.11.1.4 Mitigation proposals not currently provided within the PEIR are not available for public comment through the PEIR process. National Grid propose in their response to the Secretary of State’s Scoping Opinion (Appendix 5b) that “A landscape strategy for project-wide mitigation proposals will be discussed and produced as necessary in consultation with the Landscape and Views Thematic Group between September and December 2013”. At present the Joint Councils are not in receipt of this strategy and there is in any event no proposal by National Grid to consult with the wider public.




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3 Design Commentary

3.1 The T pylon Option 3.1.1.1 A key distinction between previous consultations and the current s42/s47

consultation is the confirmation that the T pylon is proposed to be included within the project. Given the new design of the T pylon structure, there is a lack of evidence available to support conclusions drawn in relation to the relative merits of the T pylon vs. the lattice pylon. As such, it is difficult to establish the degree of certainty with which impact assessment conclusions have been drawn and therefore whether a particular pylon type is appropriate. Key areas of concern regarding the T pylon that should be addressed prior to submission of the DCO application are:

The T pylon is a new structure in the English countryside having not been deployed elsewhere and it may be considered by some to be ‘uncharacteristic’. This element is not considered to be fully addressed in the landscape section of the assessment of effects;

There is an over reliance within the text regarding the mitigating potential of the T pylon given the uncertainty surrounding the new design;

The proposed overhead route has been designed in accordance with the Holford Rules, however the Holford Rules are based on a more visually permeable lattice pylon structure;

The difference in construction and operational effects on landscape elements, including hedgerows and trees (due to the wider maximum clearance required for the pylon arms);

The different construction, access and operational maintenance requirements of the T pylon;

Whilst National Grid argues that views of overhead lines will diminish to such an extent over 3 km as to not be prominent in views, it is considered that the T Pylon may be easily visible for up to 10 km due to it being a more solid structure. In addition, whilst the T pylon may be less visible at distance due to its reduced height, the T pylon options report acknowledges that the T pylon may be more prominent in near distance views;

The potential impact of the T pylon on collision and electrocution risk for bird life as highlighted in EN-5 (Section 2.7);

The ability of the T pylon to adapt to climate change as set out in EN-5 (Section 2.4), including wind and storm effects;

The T pylon design life, e.g. in comparison to the lattice pylon 80 year life expectancy; and

The impact of T pylon foundations on ground conditions in the levels due to the mono-pile nature of the structure is unclear.

3.1.1.2 It is recommended that National Grid provide further information to support the use of the T pylon as an alternative, including an assessment of the continuing applicability of the Holford Rules to the T pylon option. This should be provided prior to the submission for Development Consent. Given the uncertainty associated with




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the T pylon structure, National Grid should ensure that appropriate provision is made within relevant mitigation strategies (i.e. landscape and ecology) to address any impacts relating to the T pylon option (whether foreseen or otherwise) to ensure that any adverse effects of the T pylon introduction into the landscape are fully mitigated.

3.1.1.3 There remains a clear need for the provision of strategic landscape scale planting to mitigate the visual and landscape impact of the 400kV route, including the impact of undergrounding on landscape character within the Mendips.

3.1.1.4 The use of the lattice tower is supported in West Somerset where it is currently indicated for use.

3.2 Proposed Route Options 3.2.1.1 Mendips AONB undergrounding: The Joint Councils acknowledge National Grid’s

commitment to minimising visual impacts on the Mendips AONB through undergrounding of this section of the route. The Joint Councils consider that on-going dialogue is essential for the continuing design development of the underground route. In particular, the Joint Councils would encourage National Grid to engage in the development of appropriate opportunities for mitigation and enhancement that would naturally follow from a more detailed assessment of a defined project (and as more environmental data and analysis becomes available).

3.2.1.2 Undergrounding proposals for the Mendips are largely presented in terms of benefits through reduced visual and landscape impact on the Mendips. Whilst the removal of overhead cables is welcomed, the increased hedgerow loss and associated ecological impact, archaeological impacts, Grade 1 agricultural land take and the longer term operational impact of the 400kV undergrounding are considered to be substantial. National Grid should further consider the extent to which these effects could be moderated as part of the DCO submission in conjunction with agreement of appropriate mitigation with the Joint Councils.

3.2.1.3 Of particular concern is the approach to surface water management, silt control and temporary and permanent alteration of shallow ground water flows and land drainage systems. This has potentially significant implications where the route alignment crosses areas of Grade 1 (Best and Most Versatile) agricultural land.

3.2.1.4 The PEIR sets out potential means of crossing watercourses through undergrounding sections but lacks certainty regarding the approach that will be adopted. The choice of directional drilling versus cable bridges has a potentially significant implication for landscape, ecology and surface water management as well as any planning requirements and obligations, which the Joint Councils will wish to engage with National Grid on.

3.2.1.5 Portbury vs. Portishead Options: The route alignment via Portishead (route option B) is North Somerset Council’s (NSC) preferred route. The Portishead route alignment largely follows the existing overhead line alignment, with some modifications to the alignment increasing the offset distance of the line from properties (e.g. at the Ashlands development, residential properties will benefit from being 150m further away from the 400kV route alignment than they were from the 132kV route alignment). Given the current context of overhead power lines in the




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landscape it is considered that route option B will be less sensitive to change and better able to accommodate the proposed 400kV alignment.

3.2.1.6 Whilst the relative merit of different 132kV undergrounding routes to Portishead substation has been set out, it is considered that insufficient attention has been given to the assessment of specific impacts relating to the 132kV (green route) underground works on the Portbury Wharf Nature Reserve (designated as a Site of Nature Conservation Importance and located adjacent to the Severn Estuary European Marine Site). This information should be provided as part of further structured engagement prior to the main DCO submission.

3.2.1.7 Somerset Levels and Moors South (Section B): The proposed route alignment generally moves the route away from larger areas of settlement and in some cases provides a substantial offset from existing communities relative to the pre-existing route alignment (e.g. at East Huntspill). However, locally other receptors such as Cripps Farm would be closer to the proposed development and appropriate mitigation should be provided.

3.2.1.8 There are concerns regarding the proposals in Mark and Tarnock it is considered that further evaluation of detailed technology design is required in these locations. Due to the nature and proximity of the proposals to properties in the settlements, there is concern that little mitigation is possible. National Grid should provide a full justification for the route alignment proposed through Mark and Tarnock setting out details of mitigation options available in this area. This should include alternative pylon heights and positions as well as screening, footpath and offsite improvements as well as compensation.

3.2.1.9 Somerset Levels and Moors North (Section D): National Grid proposes to use lattice pylons for the new 132kV route from the proposed Sandford Substation to the 132kV Weston-super-Mare AT route. This avoids the potential ecological, landscape and archaeological impacts associated with undergrounding this section of route but it will be much closer to isolated properties such as Rookery Farm and appropriate mitigation should be provided. National Grid has considered whether to use steel monopoles or lattice pylons within this route section. Whilst the steel monopoles are lower in height than the steel lattice pylons (approximately 22m compared to approximately 29m), there would be three times the number of monopoles in the landscape compared to the steel lattice structures. The use of monopoles would also require two separate sets of overhead lines extending across the landscape in parallel approximately 25m apart, whereas a steel lattice pylon would only require one set of lines. Steel lattice pylons also have greater visual permeability than the monopoles allowing views of background features through the pylons. They are also present in the existing landscape.

3.2.1.10 The existing 132kV route in the vicinity of Moorland Park runs close to the existing gypsy and traveller site. The opportunity should be taken to move the proposed higher voltage 400kV T pylon route further eastwards to create a greater offset distance between the proposed line and the gypsy and traveller site rather than drawing the route closer to the community of Moorland Park.

3.2.1.11 National Grid should confirm that statutory safeguarding zones have been observed.

3.2.1.12 National Grid have stated that overall, the proposed development would have an adverse effect on archaeological remains, built heritage and the historic landscape in the areas around Tickenham and Stone Edge Batch. Listed structures around




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Tickenham Church and the listed buildings in the vicinity of Stone Edge Batch may experience adverse effects. Further assessments are required to minimise the impact on Tickenham Church and a clear mitigation strategy agreed upon to lessen any impacts on this listed building.

3.2.2 Substations and Cable Sealing End (CSE) Compound 3.2.2.1 Cable Sealing End Compound: Sedgemoor District Council expressed

reservations at draft route consultation stage about the potential impact of the CSE compound on visitors’ first views of Sedgemoor when travelling southbound on the M5. As currently presented it is considered that the landscape screening proposed for the CSE compound requires strengthening, particularly in light of the uncertainty regarding site levels, which could require elevation of the CSE compound above its current proposed levels to address flood risk. Once the levels have been confirmed an appropriate mitigation package should be consulted on with SDC landscape officers.

3.2.2.2 Sandford Substation: The general location of the proposed substation has been agreed and supported by a previous North Somerset Planning and Regulatory committee (25 July 2012), which made recommendations for reducing the visual intrusion of the buildings and contributing to sustainable development through inclusion of a grass roof and measures to assist bat roosting and foraging. As a result of the proposed substation, NSC will be providing specifications to National Grid regarding any realignment to the Strawberry Line so that the proposals for the substation to be submitted within the DCO will be able to include updated details on the continuation of the Strawberry Line through the site and refined landscape planting proposals, which would contribute to mitigation of the landscape and visual amenity impacts that will arise from the introduction of a new built form into the rural landscape.

3.3 Temporary Construction Infrastructure 3.3.1.1 Site Compounds: A number of substantial site compounds are indicated within

route sections B to D (Somerset Levels and Moor and the Mendips Hills). At present it is not clear how environmental criteria have influenced the compound locations and this should be set out in the alternatives assessment of the final ES. It is imperative that the Joint Councils are able to understand the evolution of the project through to preferred solution.

3.3.1.2 Temporary pylons: Temporary transmission line diversions within Section A Puriton Ridge require new full size pylons, which have potential to give rise to environmental effects. Further detail is required in relation to the impacts and mitigation of this temporary infrastructure and should be clearly articulated within the Construction Environmental Management Plan (CEMP) referred to in Schedule 2 Article 11 of the draft DCO. This document should be made available as part of structured engagement prior to submission of the DCO.

3.3.1.3 Temporary haul roads: The PEIR indicates a significant requirement for land take associated with temporary haul roads and site accesses (bellmouths), in relation to both the new route option and the removal of existing accesses. All proposed access arrangements will need to be subject to detailed technical audits. It is envisaged that work in this area will continue with National Grid prior to the DCO




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submission. In the event that full technical approval cannot be granted prior to the DCO then such details will be determined through the articles with the DCO in consultation and agreement with the local highway authorities. As part of further structured engagement, National Grid should provide clarification regarding the potential need for retention of the temporary access infrastructure to allow for maintenance during the operational period.

3.3.1.4 Closure of footpaths: The PEIR provides limited information in relation to path management; alternative routing options; the impact on PRoW used as, and crossed by, construction access routes; and the definition of what constitutes a short duration closure. This information must be submitted for structured engagement prior to the main DCO submission. It is imperative that engagement is undertaken with the Highways Authority and Joint Councils in advance of the submission to ensure that mitigation proposals for the extensive diversions, identified closures and footpath alterations are robust and appropriate and do not impact adversely on the important tourism offer of the affected area. Particular focus is required on the cumulative effect of the proposals on the PRoW network around Hinkley Point, which has been subject to extensive revision relating to the new nuclear build proposals and the Bristol Ports Company’s compensatory habitat scheme.

3.3.2 Limits of deviation 3.3.2.1 The need for limits of deviation to be applied to the route alignment is standard

industry practice to allow flexibility in the event of unforeseen constraints to the route alignment.

3.3.2.2 National Grid proposes limits of deviation as follows:

Overhead line lattice pylons (400kV and 132kV) – 60m (30m either side of the centreline);

Overhead line T pylon – 80m (40m either side of the centreline);

Underground 400kV cables – 100m;

Underground 132kV cables – 60m; and

Vertical deviation of +4m. National Grid states that final pylon designs may be lower in height and place no restriction on downward deviation.

3.3.2.3 The additional 20m limit of deviation required for the T pylon relative to the lattice tower means that any change in alignment from existing has potential to significantly increase the impact of proposals. National Grid should clarify their proposed process for evaluating the likely significant effects of deviating route alignments during construction where changes are proposed to the locations of pylons. The implications of downward deviation should also be set out.

3.3.2.4 In particular, National Grid should identify where the sensitivity of the route is such, that reduced limits of deviation would be appropriate. Should the limits of deviation result in the change of access points then further technical work will be required to validate the access points for highway impacts and road safety.




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4 Preliminary Environmental Information Report and Topic Based Plans

4.1 Landscape and Visual Effects 4.1.1.1 This section reviews Document 2.2, Chapter 6 (Landscape) and Chapter 7 (Visual

Effects) of the PEIR and relevant technical material submitted in Volume 5, in particular Document 5.1 Pylon Design Options Report. Where a point refers to only one of the chapters, reference has been made to the appropriate part of the relevant chapter.

4.1.2 Topic Summary 4.1.2.1 The PEIR chapters 6 and 7 presented for consultation require a considerable

amount of further work prior to submission of the final ES.

4.1.2.2 The assessments are often difficult to interpret and lack clear and structured explanation of the judgements considered. The assessment text is very much summary narrative, with little clear and reasoned justification behind the judgements made for each receptor on sensitivity, magnitude and significance of effect.

4.1.2.3 The terminology used and the scoring of factors such as the magnitude, nature and reversibility of effects is inconsistent and requires clearer justification throughout the assessment.

4.1.2.4 The use of summary tables would help a great deal with the reader’s ability to quickly access information. In particular:

Tables describing the criteria for assessing the sensitivity of receptors and magnitude of change to landscape receptors; and

An overall assessment table summarising sensitivity, magnitude, significance, mitigation and residual effects for each receptor.

4.1.2.5 Chapters 6 and 7 only discuss measures proposed to mitigate impacts associated with some elements of the development. National Grid has stated that a full Landscape Strategy will be provided with the final ES and consulted on with the Joint Councils in the meantime.

4.1.2.6 The full scope of impacts associated with undergrounding has not been considered. Further work is required in this respect to fully understand the potential effects and to inform or justify the option for undergrounding, particularly through the Mendip AONB.

4.1.2.7 Several aspects of cumulative effects assessment have not been covered in the PEIR in sufficient detail at present e.g. sequential effects on PRoW users or the additive effect of vegetation loss along the route alignment.




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4.1.3 Adequacy of information and further information requirements

4.1.3.1 The scope of information considered in Chapters 6 and 7 is considered to be insufficient at present to draw conclusions regarding residual effects. Further work is recommended in the following areas.

General

4.1.3.2 It is considered that the consultation material supplied requires further detail in respect of the assessment of the baseline sensitivity of local landscape character areas and of visual receptor sensitivity on an individual basis.

4.1.3.3 The photomontages that have been provided are well presented but the majority are missing. Where photomontages have been provided they have been cross referenced in tables within the relevant sections of the assessment but the judgements and discussions leading to the relevant assessments seldom refer to the photomontages, consequently it is unclear how they have influenced the assessment at this stage.

Construction effects

4.1.3.4 The PEIR does not fully assess the effects of the temporary overhead lines installed in sections A, B, D F and G. It is not clear how long these will be present for, nor is the nature of the temporary pylons/masts and other temporary infrastructure such as laydown areas and access tracks described. This information should be incorporated into the assessment of construction effects with a clear statement on the duration of effects, retention of temporary construction infrastructure and the cumulative landscape impact during construction.

Effects on vegetation

4.1.3.5 Loss of existing vegetation is likely to have a significant effect on the character of the landscape and the visual environment. The PEIR presents plans at Volume 3.8, which show the extent to which existing vegetation may be effected. These appear to simply highlight all vegetation within the application boundary and do not state which trees and hedgerows will be lost and which are to be retained and protected. Without this information it is not possible to fully assess the development’s effects on the character of the landscape, visual environment or indeed many ecological receptors. It would be helpful for example to set out a worst case position in respect of potential losses to inform discussions on a possible mitigation strategy.

4.1.3.6 For example in Volume 3.8, Section G Avonmouth, drawing G/TR/PS/5 shows that trees and vegetation may be lost over an area around 1km wide, just north of the M5/M49 junction. Clearly this would be a significant impact which has not been fully addressed within the assessment.

4.1.3.7 Another example of the importance of clearly defining the extent of potential tree losses is at Avonmouth, where the entirety of the existing wedge of mature trees on the disused railway sidings is highlighted as potentially affected on drawing G/TR/PS/3 in Volume 3.8, but is identified in the assessment as a key element of the existing view that will help filter views of the proposed 400kV line routed around the edge of the settlement.




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4.1.3.8 Plans of the entire development (including limits of deviation) should be provided clearly showing vegetation to be lost, retained and planted. These plans should also detail any partial or complete effects on vegetation such as hedgerow works due to scaffolding at road crossings. These plans could illustrate degrees of certainty. For example, where certain elements of the scheme such as the precise footprint of a pylon or access road cannot be reliably defined, a small proportion of the planting could be shown as ‘potentially’ affected. This information should then be incorporated into the assessment for the ES.

4.1.3.9 National Grid may opt to take a worst case scenario approach and carry out an assessment on the basis of total vegetation removal within the areas shown.

Undergrounding

4.1.3.10 In Chapter 6 paragraphs 6.5.30-31, 6.5.94 and 6.5.107-111 there appears to be no detailed consideration of the potential for a residual ‘scar’ to be visible in the landscape following the construction phase and any mitigation planting. Reinstated ground, ground cover, loss of and replacement of hedgerows and trees, new fencing and walls will all convey a visual clue as to the route of the cables for a considerable period of time. This aspect of undergrounding should be considered in the ES accompanying the DCO.

4.1.3.11 The CSE compound south of the Mendips AONB in Section B has been located within the setting of the AONB and very close to the M5. There has been no update presented in the PEIR for the selection of the location of this element of the development following concerns raised at the draft route stage when a siting options report was presented.

4.1.3.12 There are many instances where it will be necessary for underground cables to cross watercourses such as the River Axe, Lox Yeo River and many smaller ditches/rhynes. It is currently unclear from the assessment how National Grid proposes to cross rivers and ditches. The methods used for crossing watercourses may give rise to a range of effects including landscape and visual, ecological, drainage, PRoW, etc.

4.1.3.13 Within the AONB, there is concern that link boxes, associated fencing, temporary and on-going access arrangements and any other ancillary equipment at joint bays/crossing points could potentially give rise to significant landscape and visual effects. These have not been considered adequately within the PEIR.

Cumulative Effects

Comments below are made with reference to Chapter 7 of GLVIA 3rd Edition (GLVIA3) 8 and with reference to the Joint Councils' Scoping Response.

4.1.3.14 There is currently no assessment of whether any part of the landscape would be subject to cumulative impacts with existing infrastructure development to the extent that the landscape character would change, for example from one with electrical infrastructure present, to one dominated by electrical infrastructure. Instances where this may be a risk would be the landscape around Hinkley Line Entries (Section H)

8 Guidelines for Landscape and Visual Impact Assessment (Third edition), Landscape Institute and Institute of Environmental Management and Assessment, 2013.




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as depicted by the photomontage of VPH1, the approach to Seabank (adjacent to the M49) and at Horsey Level, south of Puriton Ridge.

4.1.3.15 NPS EN-1 states that “When considering cumulative effects, the ES should provide information on how the effects of the Applicant’s proposal would combine and interact with the effects of other development (including projects for which consent has been sought or granted, as well as those already in existence).” As such it is considered that existing lines, not removed as part of the scheme should form part of the assessment of cumulative landscape and visual effects.”

The cumulative effects section should contain a specific, more detailed consideration of the cumulative effects of the proposed development, in particular for the T-pylon with proposed wind turbine developments along the route. For example, with reference to cumulative visual effects in Section B, Chapter 7 paragraph 7.10.34 states: “There is the potential for cumulative effects in Section B if either of the proposed wind turbine projects (ref 14 and 22) were developed on the Somerset Levels and Moors. The turbine applications, if successful at appeal, would result in the introduction of additional tall structures (up to 130m high) into the flat Levels landscape where cumulative effects could arise from the intervisibility of the turbines and the Proposed Development. The wind turbines would however form taller vertical structures than the overhead line pylons and would give rise to the greater effect.”

4.1.3.16 However, no assessment of the significance of the potential cumulative effects has been provided.

4.1.3.17 Chapter 6 Table 6.4 relates to cumulative impacts on landscape receptors, but does not refer to the construction and decommissioning effects of the various phases of the Hinkley Point facilities on the landscape resource. It will be important for construction phase activity to be considered and assessed alongside the construction phase of the Hinkley Point C project as they will be taking place together. Operational phase effects for both projects can be considered from 2023 when the permanent landscaping works at Hinkley Point C will have been completed (based on currently understood timescale).

4.1.3.18 No detailed assessment of potential sequential cumulative visual effects, such as those that might occur several times to receptors on a long journey along long distance recreational routes, roads or railways has been provided within the PEIR. This was raised at the Landscape Thematic Group Meetings as an area to be included in the assessment of visual effects. As part of the visual effects assessment the assessor has considered and briefly described a sequence of viewpoints along many of the routes through each Section. For example, the M5 motorway through Section B, Paragraph 7.5.163 states that “Receptors travelling north typically would experience a minor adverse significance of effect during operation where views are available beyond embankment trees across fields. Views north would include a new 400kV overhead line visible beyond the existing VQ Route 275kV overhead line across Horsey Level and on Puriton Ridge. At Horsey Level views would include the two CSE compounds at the connection to the existing 275kV overhead line. The existing 132kV overhead line would be removed from views parallel and beyond the existing VQ Route 275kV overhead line. Views south would be similar however a new 400kV overhead line would only be visible to the northern section of the route with the overhead line on Puriton Ridge in rear views.”




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4.1.3.19 These visual effect assessments do not clearly discuss the sensitivity of each receptor nor do they state what magnitude of change will take place. It is recommended that this information should be provided to aid the reasoned justification of effects. It should include an assessment of the combined effect of these individual ‘sequential visual effects’ on, for example, motorists travelling the length of the M5 between Bridgwater and Aust, or on users of the long distance cycle route 26, part of which follows the Strawberry Line.

4.1.3.20 The proposed development includes works to highways and to existing agricultural tracks as well as the creation of new routes within the application site to enable temporary construction and some permanent operational access. Neither chapters 6 or 7 make detailed assessment of the effects of route widening and bellmouth openings on the character of the landscape or on visual amenity.

Character of the T-Pylon

4.1.3.21 The T pylon is a new structure not previously seen in the English countryside. The assessments have not considered or described whether the character of these structures will be at odds with, contribute to, or reinforce, the character of the receiving landscapes and further assessment is required in this respect.

4.1.4 Methodology 4.1.4.1 As raised in the Joint Councils' Scoping Response (paragraph 3.3.2), a landscape

and visual study area has still not been defined. The figures provided in support of chapters 6 and 7 show 1km and 3km ‘buffers’, but no clear study area.

4.1.4.2 Whilst chapter 7 argues that views of overhead lines will diminish to such an extent over 3km as to not be prominent in views, pylons are tall structures and T-pylons in particular may be visible in the landscape over considerable distances, even up to 10km due to it being a more solid structure. It is therefore essential that the study area and its extent should be clearly presented and justified.

4.1.4.3 The Joint Councils' Scoping Response paragraph 3.2 states “A study area for the consideration of landscape effects is not defined within the Scoping Report; although it is acknowledged that the Zone of Theoretical Visibility (ZTV) plan extends up to 10km from the proposed route. This is considered to be a suitable study area for the initial consideration of visual effects. The Initial Visual Assessment plans supplied with the Scoping Report (Figure 14) illustrate that, in general, views within 3km have been considered, although this is difficult to verify due to the resolution of the base mapping on which the information is presented. While it is accepted that this may be the distance within which the most significant effects would occur, views outside this distance, particularly relating to large scale features such as CSE compounds and 400KV pylons and especially from viewpoint locations that may contain great concentrations of sensitive receptors such as within the Mendip Hills AONB, should also be considered with the assessment.”

4.1.4.4 Paragraph 5.4.5 of the PEIR also suggests that a wider study area may be needed for some topics such as visual effects.

4.1.4.5 Whilst the actual description of sensitivity (which also introduces the term susceptibility) in the methodology [paragraphs 6.3.12 to 15], accords with GLVIA 3, the application of scores in the various sections is confusing (see baseline comments below for an example).




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4.1.4.6 In places the terms ‘sensitivity’ and ‘susceptibility’, which have specific meanings in LVIA are used interchangeably (e.g. paragraph 6.4.206) and elsewhere they are scored separately (e.g. paragraph 6.4.206 & 207). Where referring to a receptor's susceptibility, care should be taken to avoid confusion between this and the overall sensitivity of a receptor.

4.1.4.7 Under paragraph 5.4.8 “sensitivity of receptors”, National Parks are classified as “very high”, whereas, AONBs are classified as “high sensitivity”. It is unclear why there would be a distinction between National Parks and AONBs. Both designations are made for the same purpose in relation to conserving and enhancing an area’s natural beauty, although National Parks have the additional purpose of being designated for recreation. Natural England’s Guidance for assessing landscapes for designation as National Park or Area of Outstanding Natural Beauty in England9 states at paragraph 2.9 “It is Natural England‘s view that the practical application of the natural beauty criterion is identical in National Park and AONB designation, despite there being differences in the degree to which the criterion is clarified in the legislation”

4.1.4.8 National Parks and AONB designations appear to be given equal weight in landscape quality / value in EN-1.

4.1.4.9 There should be a consistency of method adopted to assessing sensitivity throughout the ES. Chapter 5, EIA Approach and Method stipulates the use of a five-point word scale for assessing degrees of sensitivity. A justification for the use of a different four point scale in the Chapters 6 and 7 should be provided.

4.1.4.10 No reference appears to have been made to existing Green Infrastructure and landscape strategies (e.g. as set out in Sedgemoor Policy D20). These would be particularly helpful in identifying potential opportunities for offsite landscape enhancement where impacts might be hard to mitigate through on-site planting.

4.1.4.11 Two ZTV maps have been generated, one for the T-pylon and the other for the lattice pylon. It would be helpful to have a composite map with the difference indicated.

4.1.5 Baseline 4.1.5.1 The general approach to collection of baseline data appears broadly adequate, but it

is recommended that the assessments of value, susceptibility and overall sensitivity of the landscape and visual receptors are carried out in more detail.

Landscape Character Baseline

4.1.5.2 The landscape character baseline sensitivity has been assessed on the basis of Sections A to I, which broadly conform to the national scale National Character Areas10. While the baseline does reference local character areas there is no consistent assessment made of the value, susceptibility or sensitivity of the landscape at this finer-grained local level. It is considered that the whole assessment on landscape character should be carried out at the more detailed local

9 Guidance for assessing landscapes for designation. Natural England. March 2011. 10http://www.naturalengland.org.uk/publications/nca/default.aspx. Accessed October 2013.




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level. Whilst the scale of this task is appreciated, it is an inevitable product of the linear type and large scale of the proposed development. The Joint Councils note that EDF Energy considered and assessed impact on local character areas within their ES for their DCO for Hinkley Point C.

4.1.5.3 For example, Section A contains the Polden Hills Landscape Character Area (LCA) and parts of the Levels LCA to the north and south of it. These two very different LCAs should not be assessed as one. The PEIR recognises this in Table 6.9 Summary of the Preliminary Assessment of Effects on Landscape during the Operation of the Proposed Development (at Year 0 and Year 15). Under Section A stating that “Puriton Ridge has a higher susceptibility to change than the Levels landscape to the south and north but sensitivity remains moderate”

4.1.5.4 The statement highlights the different character of the two areas, but no justification is provided for the assessment of overall moderate sensitivity. Use of a more detailed assessment at the local scale would result in a more robust assessment.

4.1.5.5 The importance of the difference between these two areas is clear in the Sedgemoor Landscape Assessment and Countryside Design Summary (2003). This document assigns a high value to the Polden Hills LCA, especially in the west. With a high value and a ‘higher’ moderate susceptibility to change as identified in the PEIR, it is considered that the Polden Hills LCA would have a high sensitivity.

4.1.5.6 The baseline descriptions that compare one part of an area within a Section with another, do not help the understanding of effect on a given landscape character area (e.g. paragraph 6.4.205-207, identify that the Levels & Moors LCA is a large scale flat landscape with lower susceptibility to change when compared with the adjacent ridge landscape, however they do not provide information on how capable the Levels and Moors LCA are of accommodating change).

4.1.5.7 In order to better understand the baseline, it is recommended that the comparisons between areas should be removed and information provided on the key characteristics, value, condition, detractors and susceptibility. Where the two LCAs have a direct relationship (e.g. the Levels and the Puriton Ridge; the Mendip Ridge and the Lox Yeo Rolling Valley Farmland; and the Tickenham Ridge and Clapton Moor), then following separate descriptions, a paragraph should be provided setting out their interrelationship.

Visual Baseline

4.1.5.1 Table 7.2 describes sensitivity ratings for different types of visual receptor. However, as recommended in GLVIA 3, sensitivity should be assessed on the basis of the value attached to a view and the susceptibility of visual receptors to changes in views. In the PEIR all PRoW are ascribed a high sensitivity, without further justification this could be considered to be overly simplistic. It could be considered, for example, that a frequently-used, waymarked, long-distance route through tranquil, unspoilt countryside might be given a higher sensitivity rating than a short fragment of inaccessible footpath adjacent to a busy motorway.

4.1.5.2 The viewpoint photographs so far presented in the Document 2.8 Photomontages vary between those taken in summer, when vegetation is in full leaf and those in the winter when vegetation is not in leaf. The photographic baseline should be consistent and ideally show winter views (i.e. the worst case scenario), if not both




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winter and summer views for comparison purposes. The photography is generally considered to be of appropriate quality.

4.1.6 Impact assessment 4.1.6.1 The landscape and visual impact assessments would benefit from tabulation of data

allowing a more transparent view of the conclusions drawn. Two route sections are discussed to illustrate this point.

Section F - Route Options A and B

4.1.6.2 The conclusions drawn in the visual assessment for Sections E and F, from which views of the Section E Route Options A and B are discussed, are difficult to interpret.

4.1.6.3 For example; in Table 7.32 Summary Comparison of Preliminary Assessment of Operational Effects Proposed Route Option A and Alternative Route Option B, receptors using the footpaths LA15/1, 15/2 and 15/5 in and around the village of Portbury are assessed as experiencing moderate adverse effects from Option A, and minor adverse effects from Route B. It is not clear how operational effects of Option B are assessed to be minor adverse when compared to those arising from the presence of the existing 132kV infrastructure, which is to be removed. The assessment does not state the magnitude of change predicted (high, medium, low or negligible). Paragraph 7.5.884 states that operational effects on PRoW LA15/2 will be negligible adverse in the case of Option B, a conclusion that conflicts with the entry of ‘minor’ in the summary table quoted above.

Paragraph 7.5.918 states “Properties on the southeast edge of Portishead, including on Moorgate and from the southern parts of Conference Close, Cheviot Meadow and Heron Gardens would experience a minor beneficial significance of effect on views from Alternative Route Option B as described for Proposed Route Option A. The 400kV overhead line on Alternative Route Option B to the southeast would be taller than the 132kV overhead lines that would be removed but would be further to the east and the F Route 132kV overhead line would have been removed in the foreground of views. There would be adverse effects of minor significance from upper storey views from these properties.”

4.1.6.4 The latter minor adverse effect is presented in Table 7.32 as the visual effect experienced by properties on the southeast edge of Portishead. Considering the removal of two existing lines, one of which is particularly close (235m) to these properties and the introduction of a new, single, albeit 25% taller, line approximately 650m from these properties, it is not clear how the assessment of a minor adverse effect on these receptors has been reached. Further clarification is required in respect of the magnitude of change predicted and the nature and significance of the effects.

Table 7.32 states that there will be moderate adverse effects experienced by receptors using PRoW LA15/22 in the case of Route Option B, but paragraph 7.5.883 states “The significance of effect during operation of the Proposed Development using Alternative Route Option B on views from PRoW LA15/22 running northeast from Sheepway towards the estuary generally would be minor adverse as hedges and trees screen and filter views. Views from a short part of the right of way experiencing effects of moderate adverse significance...”




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4.1.6.5 Clarification is required as to whether this table is representing the worst case scenario. If so, justification is sought as to whether or not it is appropriate to ascribe this higher level of significance, predicted for a short section of the PRoW, to its entire length.

Table 7.32 states that there will be negligible adverse effects to residential properties in Sheepway. Paragraph 7.5.912 states “The residential property with boarding kennels and cattery Cole Acre, west of Station Road and close to its junction with The Portbury Hundred road, has views which generally are contained by surrounding trees and outbuildings. There would be beneficial effects on views of negligible significance from removal of the 132kV overhead lines to the west. A new 400kV overhead line on Proposed Route Option A to the south of the property would largely be screened by trees with the upper parts of the overhead line visible above. This would be an adverse effect on views of minor significance however adverse effects may be greater depending on tree loss in relation to the proposed 400kV overhead line.”

4.1.6.6 Further investigation and justification is recommended to improve the robustness of the assessment. Further assessment should be carried out in respect of the actual proposed tree loss and potential for mitigation of effects on properties at Cole Acre and the potential for winter views being more open when trees are out of leaf.

4.1.6.7 It is noted that the assessment makes little acknowledgement that an alignment (Option A) bordering the M5 has the potential to impact on a visitor’s initial view of North Somerset, when southbound on the motorway.

4.1.6.8 Subject to the results of further assessment, it is considered that although longer, Route Option B could be a more suitable option. The two existing 132 kV pylon lines have long been a part of this landscape and many of the relevant receptors are accustomed to their presence. Removing both of these lines from view and replacing them with one slightly taller 400kV T-pylon line may result in fewer adverse impacts on the landscape and on visual receptors than the propose Route Option A.

4.1.6.9 Additionally the substation at Portbury Wharf and the existing 132kV line between it and Portbury Dock will be retained and so maintain the presence of electrical infrastructure in the landscape of Portbury Wharf. In contrast Option A will result in adverse effects being experienced by receptors in an area not currently containing pylons, around Cole Acre, Portbury Village and the southern end of Sheepway.

Section H Hinkley line entries

4.1.6.10 There are several different types of visual receptor within 1 km of the development, which will have views of the line entries into the Hinkley C Power Station. These include private dwellings, PRoW, rural roads, as well as visitors to the Pixies Mound Scheduled Monument. The sensitivity of each type of receptor is not discussed in any detail.

4.1.6.11 The description of the magnitudes of changes to their views is limited to a brief mention in each case, this will need a full consideration for the final ES submission.

Pixies Mound Scheduled Monument

4.1.6.12 The ‘visual setting’ of the Scheduled Monument is not discussed in either the landscape or visual assessment, but has been assessed in the Historic Environment




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chapter. The conclusion in the Historic Environment chapter is that Pixies Mound would experience a moderate adverse significance of effect as a result of a low magnitude of changes to its very highly sensitive visual setting.

4.1.6.13 Chapter 7 states that visual impacts to the public visiting Pixies Mound would be minor adverse. The receptors here are users of a permissive footpath accessing a Scheduled Monument. According to Table 7.2 such receptors should be assigned a high level of sensitivity. Therefore it is assumed that the magnitude of change predicted within the assessment is negligible

4.1.6.14 These two assessments are not consistent in respect of their prediction of magnitude of change and further work is required for consistency and robustness.

Private Dwellings

4.1.6.15 The residential properties just south of the line entries are assessed as experiencing moderate and minor adverse significance effects as a result of the proposed development. Once again there is no justification or description given for the sensitivity of these receptors or magnitude of change predicted. It is considered that their sensitivity is high in line with Table 7.2.

4.1.6.16 It is considered that the magnitude of change would be, at best low but in some cases medium (for example, residential properties, on the rural road between Doggets and Wick) where construction and operation of the development would lead to adverse effects of between moderate, and in some instances major significance on visual amenity.

4.1.6.17 There are several further cases in this chapter where it is considered that the assessments made and the conclusions drawn are not justified or robust.

T-pylon vs. lattice pylon

In respect of the differences between the two pylon types in Section F, paragraph 7.5.965 states “A new 400kV overhead line using the steel lattice pylon or the T-pylon would result in the same significance of effect on views. Overall in Section F the T-pylon would give rise to lower levels of effect because the existing Bridgwater to Avonmouth 132kV and W Route 132kV overhead lines would be removed from views above trees and effectively replaced with a new line using the T-pylon that would tend to be less visible than the equivalent line built using steel lattice pylons due to it being 12m shorter with less of the structure visible above trees, built form and ridge backgrounding. The T-pylon would also be more readily screened by landform and trees than the steel lattice pylon due to the lower height. However the T-pylon would be more prominent in near distance views of receptors with limited screening due to the solid column and cross beam and the close conductor configuration.”

4.1.6.18 This paragraph is confusing because it first states that either pylon type would result in the same significance of effect, but then goes on to say they T-pylons would lead to lower levels of effect in longer distance views but potentially a greater effect in close distance views. Clarification is sought as to whether the assessor is suggesting that, despite reducing the magnitude of impact, the reductions would be so slight as not to change the significance rating.

4.1.6.19 The PEIR (including Document 5.1) discusses the visual effects of the two different pylon types experienced by visual receptors but there is only limited assessment




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made about how the character of the pylon design will influence effects on landscape character.

4.1.6.20 Additionally no assessment has been made on the difference between the two pylon types in respect of temporary and permanent effects on vegetation and other landscape features arising from the construction and decommissioning phases.

Residual effects

4.1.6.21 The residual landscape effects section is brief and accounts for the extremely limited mitigation measures proposed so far (e.g. landscape proposals relating to CSE compounds). Significant further work is recommended.

4.1.6.22 The assessment of residual effects does not adequately consider the fact that any replacement planting for the mature trees lost in the construction of the underground section will take longer than 15 years to mature and replace these local landscape features. As such it is considered that the assessment of ‘no impact’ after 15 years should be revised to take this into account. The PIN’s Scoping Opinion paragraph 3.33 states “Where mitigation measures lead to a reduction in impacts, clear justification should be provided for the assessment of residual effects, including stated assumptions about heights that will be achieved by proposed planting over stated time frames”. This information should be provided to support the conclusions drawn.

4.1.7 Mitigation The Landscape and Visual Effects chapters only discuss measures proposed to mitigate impacts associated with CSE compounds and substations and do not discuss any measures associated with the main route or any receptor specific measures. The PEIR states that “A ‘Landscape Strategy’ for mitigation planting along the proposed 400kV overhead line route in Sections A to G will be produced as part of the ES” and that “these will be factored into the landscape and visual assessments”.

4.1.7.1 Loss of vegetation and other features leading to changes in the character of the landscape and views must be considered, since a considerable quantity of vegetation (currently indicated as maximum extents of potential loss) will be removed for safety clearances during construction and maintenance of overhead lines (Document 2.1 3 paragraph 3.5.70) and undergrounding works where there is currently only a commitment to replanting of hedgerows ‘where possible’ and tree planting elsewhere only where it has been agreed (Document 2.1 paragraph 3.6.13).

4.1.7.2 In accordance with the principles set out in EN-5, the Landscape Strategy should comprise both localised planting to screen immediate views of the proposals and offsite tree and hedgerow planting to soften the landscape and visual impacts.

4.1.7.3 No information is provided regarding measures in place to ensure a quick and effective ‘healing’ of the landscape following construction of the 400kV and 132kV undergrounding routes to reduce the residual impact landscape and visual ‘scar’. This is of particular importance within the Mendips and should be covered in detail in the Landscape Strategy. Where appropriate suitable mitigation measures, such as vegetation translocation or use of advanced stock for replanting should be incorporated by National Grid. The document should also describe the general approach to mitigation of effects to be applied in each area of distinct landscape




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character along the route, on a fine grained local scale. The outcome of this work could take the form of a series of typical details to be used for restoration of landscape elements such as hedgerows, walls, trees, etc.

4.1.7.4 At present no mitigation is proposed to address the effects of kiosks and other visible aspects of the underground routes. National Grid should provide kiosk siting plans explaining their approach to siting and typical mitigation measures to be employed to reduce adverse effects.

4.1.7.5 At present no landscape proposals are set out in relation to the treatment and enhancement of new routes following PRoW closure and diversion, aside from the requirement to divert and provide new PRoW routes. Further detail is required setting out how these will be provided and what measures will be put in place to assimilate these features into the landscape in order to make them valuable routes.

4.1.7.6 The new route has potential to impact negatively on the character of the landscape as viewed from the Strawberry Line and on the visual amenity of users of this footpath. Appropriate use of offsite planting to reinforce landscape character and on site planting to screen the worst effected views of the proposed development and to enhance and open up views out from the route. Mitigation details should be provided in advance of the application for Development Consent and agreed with NSC.

4.1.7.7 The new route has potential to impact negatively on the local character of the landscape and visual amenity of receptors (including PRoW users around the Line Entries in Section H, West Somerset. New screen planting to augment and geographically extend existing and planned woodland extents would be consistent with policies set out in West Somerset local plan (LC3, TW1 and TW2) and the HPC supplementary planning document (Boxes 17 and 36bw) and play an important role in assimilating the new overhead line proposals into the landscape.

4.1.7.8 Landscape proposals to address landscape character effects arising from the new the CSE compound south of the Mendip Hills are considered to be insufficient at present. The CSE compound is very close to the M5 at the point where southbound views open out over the levels landscape and is clearly visible in middle distance open views from the Mendip hills. In line with Sedgemoor District Core Strategy Policies SO8; MIP1, D14 and D20 it is considered that additional measures are required in order to adequately mitigate these effects. These should include:

Planting between existing trees on and near the top of the embankment (rather than on lower ground beside it), for 100 m further south and for 300 m further north along the east side of the M5 and as close to the carriageways as possible and on the embankment to enhance its effectiveness; and

Adding fast growing and taller species to the planting mixes such as Alder and willow.

4.1.7.9 The PEIR Predicts significant effects on landscape character and visual receptors at Mark, Rooksbridge, Biddisham and Tarnock There are significant adverse effects on visual amenity in and around this area, but no mitigation measures are proposed. On-site and off-site planting to mitigate views of the development, should be included within the proposals. Within Sedgemoor District, these proposals should clearly contribute to the Green Infrastructure Strategy objectives of habitat creation; forestry and forestation; and linkage and mobility.




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4.1.7.10 National Grid’s response to the PINS Scoping Opinion (Appendix 5b) stating that “A landscape strategy for project-wide mitigation proposals will be discussed and produced as necessary in consultation with the Landscape and Views Thematic Group between September and December 2013” is welcomed. However, the Joint Councils are not yet in receipt of this information.

4.1.7.11 It is important that on and off site mitigation proposals, including reinstatement of landscape features following construction are informed by consultation with the Local Authorities and the Landscape Thematic Group and by further structured engagement. Any proposals should be thoroughly integrated with the ecological mitigation strategy where appropriate. The Landscape Strategy proposed in Schedule 2 of the draft DCO should be prepared and agreed with the Joint Councils. This will enable Joint Councils to achieve a higher level of agreement in the Statement of Common Ground.




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4.2 Biodiversity and Nature Conservation 4.2.1.1 This section reviews Document 2.3, Chapter 8 (Biodiversity and Nature

Conservation) of the PEIR. It also considers ‘other documents’ presented in Volume 5, in particular Document 5.2 132kV route undergrounding options report.

4.2.2 Topic summary 4.2.2.1 Although a substantial amount of data has been collected concerning biodiversity

there are still surveys that have yet to be completed. Much of the data that is presented in the PEIR has not been analysed in a rigorous fashion in order to assess the impacts of the options chosen and it is unclear from the document about how ecological considerations have influenced choices concerning cable routes and undergrounding versus overhead options.

4.2.2.2 Whilst it is clear that a considerable effort has been made to survey the areas likely to be affected by the proposed 400kV connection, it is not clear if similar effort has been made to the proposed undergrounding of the existing 132kV cable (green route) from Nailsea to Portishead, where at present only an options report has been presented in Volume 5. The assessment of impacts on the Portbury Wharf Nature Reserve SNCI does not include the loss of habitats, effects on invertebrates or water voles, all of which are reasons for the designation of this area. The potential effects listed on this site are restricted to birds in terms of collision with overhead wires or displacement through disturbance.

4.2.2.3 In addition the PEIR does not provide an adequate assessment of the significance of effects or details of mitigation proposals, resulting in uncertainty as to what significant effects would occur and whether the mitigation proposed would be sufficient to reduce the impacts to acceptable levels.

4.2.2.4 With regards to the undergrounding of the route in the Mendip Hills, this is potentially the more damaging option with regards to potential impacts on hedgerows that form ecological networks in the AONB and wider landscape. The route in the Mendips has the capacity to affect European Sites, most notably the North Somerset and Mendip Bats Special Area of Conservation (SAC). Radio-tracking work conducted in 199911 indicates that bats from the SAC feed extensively and commute along hedgerows and it is likely that hedgerows on the route are important in linking hibernation sites to other areas of the bats’ home range. In their response to National Grid’s Scoping Report produced in May 2013, the Joint Councils recommended that there should be specific surveys to establish usage of the local hedgerow network by Horseshoe Bats. It does not seem that this recommendation has been acted upon and there is a risk therefore that insufficient information will be available to be able to ascertain that there will not be a significant effect on SAC bats due to the proposed undergrounding. It should be noted that many of the hedgerows that could be potentially affected are important in their own right according to surveys reported in the PEIR.

11 Jones G. & Billington G. (1999). Radio Tracking Study of Greater Horseshoe bats at Cheddar, North Somerset. English Nature Contract No. F14/01/572.




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4.2.2.5 The surveys reported within the documents have broadly been undertaken in accordance with relevant published guidance. However the method for assessment lacks detail regarding the determination of effects that are significant and therefore effects that might require mitigation measures. Some of the protected species surveys that are reported in the PEIR were planned before information from habitat surveys was fully assimilated and analysed. For example, decisions concerning where to focus searches for Dormice were made in advance of all the information being available about the status of hedgerows along the route. The hedgerow surveys reported in the PEIR have revealed concentrations of hedgerows in some parts of the route (e.g. in the Mendips) that are species-rich or which are comprised predominantly of species favoured by Dormice. It is possible that some of these hedgerows support Dormice yet might not have been surveyed for this European Protected Species.

4.2.2.6 There is confusion in the reporting of residual impacts as the residual effect on European Sites is reported in Habitats Regulations Assessment (HRA) terms rather than EIA terms. The conclusion of no adverse effects on integrity on the SPAs within the study area is of concern, given the absence of specific detailed mitigation measures and issues regarding the certainty of effects on bird species from the new T-pylon design.

4.2.2.7 The detail of the proposed mitigation measures outlined in Table 8.16 is not sufficient to determine if the measures are adequate to alleviate the potential impacts identified. Given the inconsistencies and omissions within the baseline and assessment it is not possible to determine what significant impacts may occur and therefore what mitigation measures would be required.


4.2.3.1 The information within the consultation documents does not include the full results of all surveys for protected species, nor does it provide a detailed interpretation of the results or assessment of the potential impacts of the proposed development. In addition the information on the mitigation measures that are proposed lacks sufficient detail to determine whether they are adequate to reduce the scale of any potential impacts. Whilst the status of the information as PEI is acknowledged, the spring date for DCO submission appears to be challenging in light of the residual survey data to be collected and assessed and the current lack of any quantitative assessment.

4.2.3.2 It is apparent that a substantial amount of survey effort has been undertaken for the 400kV connection, but it is not clear if a similar level of effort has been applied to the proposed undergrounding of the 132kV Western Power Distribution line from Nailsea to Portishead, which is currently illustrated as routing through parts of the Avon Wildlife Trust Reserve and SNCI.

4.2.3.3 Local Wildlife Sites (LWS) are treated throughout the Report as being of ‘County level’ importance. This blanket approach to the assessment of the importance of ‘local sites’ obscures the fact that many LWSs play important roles in supporting prime examples of nationally important habitats and contain important populations of protected and BAP priority species. Some of Somerset’s County Wildlife Sites, for example, provide the ‘stepping stone’ habitats between and contribute to the




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ecological networks connecting national and international sites together. The ES submitted with the DCO will have more credibility if the evaluation of sites is based on separate assessments of the attributes of each LWS individually rather than upon a prior assumption that they are of local significance only.

4.2.3.4 Details of the mitigation being proposed are not clear. For example Table 8.16 in the PEIR document does not mention the mitigation of hedgerow removal for undergrounding (only to create access), but does list re-instatement of habitat within the proposed mitigation. In order to determine if the proposed development is likely to result in significant effects on receptors or that the mitigation proposed is adequate to alleviate impacts, details of what re-instatement would occur in terms of species composition and habitat management regime are required.

4.2.4 Methodology 4.2.4.1 The surveys reported within the documents have broadly been undertaken in

accordance with relevant published guidance. However the method for assessment does not explain in sufficient detail how significant impacts will be identified and therefore, which effects require mitigation.

4.2.4.2 The absence of information regarding the significance of effects within Table 8.14 of the PEIR means that it is not clear what, if any, mitigation would be put in place. As mitigation is proposed within the PEIR it is assumed that some of the impacts are deemed to be significant.

4.2.4.3 Furthermore the assessment of potential impacts does not provide information on the degree of certainty as set out in Paragraph 8.3.11. These could be considered as an omission in light of the aims and requirements of PEI.

4.2.4.4 Comments have previously been made on the adequacy of the survey methodology, especially relating to dormice, and the assessment methodology as part of the Joint Councils’ Scoping Consultation Response and during Thematic Group Meetings. It is disappointing that these comments do not appear to have been taken on board at this stage.

4.2.4.5 Within Table 8.17 of the PEIR there is confusion in the reporting of residual impacts as the residual effect on European Sites is reported in HRA terms rather than using EIA terminology. It is considered that the conclusion of no adverse effects on integrity on the SPAs and horseshoe bat features of the SACs within the study area is not fully evidenced, given the absence of specific detailed mitigation measures and issues regarding the certainty of effects on bird species from the new T-pylon design.

4.2.5 Baseline 4.2.5.1 The baseline information is incomplete as some survey results are outstanding or

have not been completed. Of particular note is the absence of certain legally protected and notable species surveys, especially in light of the presence of high bat assemblages and otters which are European Protected Species.

4.2.5.2 While Table 8.11 of the PEIR provides an indication of the habitats present within the various Route Sections (Sections A – I), it is not clear to the general readers how these relate to the actual route corridor or the zone of influence from the




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construction of the proposed development. A similar approach is adopted in Table 8.13 with regard to species and the same comments apply.

4.2.5.3 Whilst it is acknowledged that further information is provided in appendices to the PEIR, the level of condensing of baseline information is considered to be restrictive in terms of allowing the reader to make a detailed consideration of the potential effects. This section would have benefited from confining the information to the presence of habitats and species beneath the footprint of the development and those present elsewhere within the survey area.

4.2.6 Impact assessment 4.2.6.1 As described above the assessment of impacts within Section 8.5 of the PEIR does

not include details of the significance of impacts

4.2.6.2 The list of potential effects set out in Paragraph 8.5.1 is confusing as the effects on European Sites are separated from the impacts on habitats, which might give rise to effects on the sites. This was raised in the Joint Councils’ Scoping Response. For example the “effects on bat species associated with the North Somerset and Mendips Bats SAC and the Mendip Limestone Grassland SAC during construction, operation and decommissioning of the development” are likely to occur as a consequence of the “loss of habitats and death or injury to species through permanent habitat changes along the easement of the overhead line (e.g. tree loss required for electrical safety clearances) and along the easement of the underground cable…”.

4.2.6.3 Table 8.14 setting out the assessment of impacts on receptors contains a number of inconsistencies. For example the effect of loss of bat foraging habitat through vegetation removal in the Exmoor and Quantocks Oakwoods SAC is considered to be low, “as substantial hedgerow removal is unlikely”. However the effect of fragmentation of bat commuting corridors from vegetation removal is considered to be “high assuming worst case scenario of hedgerow removal”. It is therefore difficult to determine the magnitude of impacts or their significance given the confusion in the potential scope of vegetation removal. In addition, the documentation lacks formal commitment to reinstatement of vegetation, committing only to reinstatement, where possible.

4.2.6.4 The assessment of the potential for death or injury of birds from the Severn Estuary European Marine Site or the Somerset Levels and Moors SPA as being neutral does not appear to take into account the potential movement of birds between the two sites. It is acknowledged that National Grid has commissioned surveys and literature reviews to try to establish what the impacts might be of overhead power lines on birds. The results from vantage point bird surveys conducted in 2011 seem to be at odds with those from radar studies conducted independently in the same area at the same time with regards to the numbers of birds recorded moving between the SPAs. The PEIR acknowledges that large, local movements of birds may occur in especially adverse weather conditions yet the risk of collision is not included in the assessment of impacts. Given that the T-pylon is a new design that has not been tested to any degree in the UK it is not clear how this conclusion has been made. Furthermore in terms of the Habitats Regulations, it would be necessary in light of the Sweetman judgement (Sweetman v An Bord Pleanála C-258/11) to conclude beyond reasonable scientific doubt that the proposed development would not give




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rise to an adverse effect on the integrity of the European Sites. This issue will need to be addressed within the ES and information for a Habitats Regulations Assessment that might be submitted to PINS as part of National Grid’s submission for Development Consent.

4.2.6.5 The assessment of impacts on the Portbury Wharf Nature Reserve SNCI does not include the loss of habitats, effects on invertebrates or water voles, all of which are reasons for the designation of this area. The potential effects listed on this site are restricted to birds in terms of collision with overhead wires or displacement through disturbance. The inference of this is that the potential effects of the 132kV undergrounding have not been considered, although there is reference to open cut works and permanent changes to hydrology. We would recommend that the assessment of impacts within the ES is separated out in to the assessment of the impacts from the different proposals in terms of the impacts from the 400kv overhead lines, the 132kV removal, 132kV undergrounding and the substations and Cable Sealing End Compounds and the overall impact of these proposals.

4.2.7 Mitigation 4.2.7.1 The detail of the proposed mitigation measures outlined in Table 8.16 is not

sufficient to determine if they are adequate to alleviate the potential impacts. Given the inconsistences and omissions within the baseline and assessment it is not possible to determine what significant impacts may occur and therefore what mitigation measures would be required. . Paragraph 3.6.13 of PEIR Document 2.1 states in relation to reinstatement of vegetation that “Where possible, hedgerows would be replanted or replaced although trees cannot be planted on the top of cables. Where trees have been removed from the cables swathe and planting elsewhere has been agreed, this would be undertaken.” Detailed engagement is required with the Joint Councils in relation to the planting strategy to ensure that agreement has been reach in relation to the vegetation reinstatement strategy and that this adequately mitigates both ecological and landscape impacts.

4.2.7.2 The ecological management strategy (referred to in Schedule 2, Article 10 of the draft DCO) should be consulted upon as part of structured engagement with National Grid prior to the submission for Development Consent, to ensure that the proposals are appropriate to the scale of impact identified within the assessment material and that they form part of an integrated landscape and ecological strategy.

4.2.7.3 It is envisaged that detailed mitigation will be required in relation to the proposed undergrounding within the AONB and the effects on horseshoe bat species for which the SACs are designated. Similarly detailed mitigation will be required for the other legally protected species which are present and may be affected by construction works. The effects on the local wildlife sites will also need further consideration and mitigation measures to protect these important sites.

4.2.7.4 With the exception of the issues relating to European Sites, there is the potential that Section 106 contributions may be required, in particular for the impacts on Sites of Nature Conservation Importance to compensate for the loss and permanent effects on habitats and interests. This is most likely to be the case for Portbury Wharf Nature Reserve where permanent changes to hydrology can be expected from the undergrounding of the 132kV cables.




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4.2.7.5 The results from amphibian, Water Vole and Otter surveys that are presented in the PEIR suggest that the power line route crosses or comes close to many ditches and ponds supporting significant populations of protected species (particularly of Great Crested Newts and Water Voles). It is not clear from the PEIR how this emerging information has been used in planning the precise routing of the line, but the assumption seems to be made throughout the Report that potential adverse impacts upon protected species and their habitats can be mitigated for without the necessity to vary the route. It should be pointed out that in the ‘mitigation hierarchy’ embodied in the CIEEM’s EIA Guidance and in the NPPF avoidance of impacts is always to be preferred to specific mitigation measures. This is partly because the effectiveness of mitigation measures cannot always be guaranteed.

4.2.7.6 The PEIR lacks any truly quantified information regarding habitat loss (either permanent or temporary) that will be caused by the proposed development. For this reason, it is difficult to be sure that the mitigation measures that are proposed in outline only will be sufficient to ensure no net biodiversity loss. The Councils consider that some form of biodiversity offsetting is likely to be necessary to compensate for residual impacts that cannot be mitigated adequately. We suggest that the ‘Somerset metric’ developed by Somerset County Council is used in the EIA to calculate any off-setting requirements that may arise due to impacts associated with the development. Off-setting and compensation is the last resort in the ‘mitigation hierarchy’ and, as above, avoidance of impacts is always to be preferred if possible.




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4.3 Ground Environment 4.3.1.1 This section reviews Document 2.3, Chapter 9 (Ground Environment) of the PEIR. It

also considers preliminary risk assessment presented in Appendix reports 9A to 9I.

4.3.2 Topic summary 4.3.2.1 The level of detail of assessment and supporting information provided in relation to

the ground environment is considered to be broadly adequate for a PEIR level assessment.

4.3.2.2 The methodology used for the desk based collection of baseline information and the assessment of effects is consistent with the process set out in the National Grid Scoping Report and comprehensive material is provided. It is stated that site visits were also undertaken but that these did not cover the substation sites. This is considered to be an omission as the existing substations are a potential source of historic contamination.

4.3.2.3 The assessment of effects section concludes that operational effects are unlikely to be significant, which is considered to be appropriate. Construction and decommissioning effects are considered to have a similar impact and relate primarily to disturbance of contaminated land or creation of contamination pathways during piling works. The scope of effects identified is considered to be appropriate.

4.3.2.4 On-going consultation is required in relation to the impact of the scheme on the proposed Mendip Hills Geopark.

4.3.2.5 Mitigation measures are primarily generic in nature and thus it has not been possible to assess fully the environmental effects for this topic. Further work is needed to develop more specific mitigation details for consultation.


4.3.3.1 The baseline information presented is based on the preliminary risk assessments presented in Appendices 9A to 9I. The reporting lacks clear and consistent cross referencing to this material, which would aid the reader’s understanding of the documentation.

4.3.4 Methodology 4.3.4.1 The adopted EIA methodology presented in Section 9.3 is in accordance with the

principles set out in the National Grid Scoping Report and addresses concerns raised in the Scoping Consultation Response.

4.3.4.2 Information gaps are listed in Sections 9.3.5-8. It is considered that intrusive ground investigations will be necessary prior to construction works to characterise potentially contaminated land and to provide information for geotechnical design. The planned inclusion of a coal mining risk assessment with the formal DCO submission is welcomed.




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4.3.5 Baseline 4.3.5.1 Baseline information concerning the proposed scheme alignment and locations of

surrounding sensitive receptors has been based on desk based studies and walkover surveys at certain locations. This is considered adequate for the purpose of the PEIR.

4.3.5.2 It is considered that reference should be made to the preliminary risk assessments presented in Appendices 9A to 9I as these include further details to those summarised in Chapter 9.

4.3.5.3 It is stated that site visits were undertaken but these did not cover the substation sites. Sites which have historically housed substations have the potential for contamination e.g. with PCBs and it is considered that these should be assessed in detail for potential contamination issues.

4.3.5.4 Sites designated for their geological value are identified within each section of the route. The route appears to avoid designated sites and this is welcomed.

4.3.6 Impact assessment 4.3.6.1 The general approach to assess the potential impacts is considered appropriate.

4.3.6.2 The consistency of terms used in the assessment should be reviewed throughout Section 9.5. Paragraph 9.5.10 describes the magnitude of effect as low, a term not included in Table 9.1 and therefore not consistent with National Grid’s own criteria.

4.3.6.3 The potential to create contamination pathways along piled foundations and through ground disturbance is identified in relation to both pylon types. The proposal to undertake piling risk assessments prior to construction is welcomed. The creation of contamination pathways is considered to be of importance particularly where sensitive surface and groundwater receptors are present, particularly in light of the potential depth of piling required for T pylons in the levels.

4.3.6.4 It is considered that the potential risks associated with the stability of pylons due to the encountered ground conditions should be assessed. Consideration should be given to the required ground investigations and selection of foundation options.

4.3.6.5 The potential risk to construction, operation and decommissioning workers is not mentioned in the assessment of effects section. Given the presence of contaminated sites along the route, it is considered that risks to worker should be considered further.

4.3.7 Mitigation 4.3.7.1 The mitigation detailed in Section 9.8 is considered to be generic for the

construction phase, and specific details of the mitigation proposed for each of the potential effects presented in Section 9.5 should be provided. It is stated that the proposed development has been selected to avoid mineral extraction sites. However, no details of mitigation measures that will be used when the development does cross these sites have been given, such as the Fourteen Acre site within Section A.

4.3.7.2 It is considered that on-going consultation should be undertaken to ensure that any impact on the proposed Mendip Hills Geopark is appropriately mitigated.




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4.3.7.3 The proposal to use measures such as bog matting and geotextiles to mitigate the damage to soil is welcomed.

4.3.7.4 It is noted that National Grid will consider appointment of agricultural liaison officers or soil specialists during the construction of the proposed development and this is welcomed.

4.3.7.5 It is considered that the first step that should be taken as part of mitigating the risk presented by contaminated sites within the proposed development area will be an appropriate ground investigation. It is considered that the requirement for ground investigations, risk assessment and where necessary remediation strategies should be secured by requirements in the DCO.

4.3.7.6 There is no mention of mitigation measures during operation or decommissioning. Whilst these mitigation measures may be similar to those employed during the construction phase, in the absence of specific proposals, it is not possible to have a full understanding of the project's environmental effects.

4.3.7.7 Section 9.9 details the predicted residual effects, however, the reporting would benefit from increased clarity as to the specific mitigation measures proposed over and above the more generic mitigation set out.

4.3.7.8 Schedule 2, Article 9 of the draft DCO sets out the requirement for all works to be subject to a written scheme of investigation to deal with contamination of land and groundwater that is approved by the relevant planning authority. The Joint Councils consider that this is an appropriate mechanism for dealing with contamination.




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4.4 Hydrology and Water Resources 4.4.1.1 This section reviews Document 2.3, Chapter 10 (Hydrology and Water Resources)

of the PEIR. It also considers aspects raised in Chapter 9 Ground Environment and in relation to flood risk, Preliminary Flood Risk Assessments (PFRA) for two cable sealing end compounds (CSE), three substations and the route in Appendices 10A to F.

4.4.2 Topic summary 4.4.2.1 The technical coverage and physical extent of the PEIR is considered to be broadly

appropriate at this stage of the development of the project. However, some key information gaps are identified in relation to water crossings (specifically the construction means for crossings) the potential for creation of drainage barriers due to undergrounding and the detail of flood risk management measures. Drainage impacts have potential to impact significantly on areas of Grade 1 agricultural land.

4.4.2.2 The methodology for the establishment of baseline conditions and for the assessment of effects has been set out.

4.4.2.3 The PEIR subdivides the route from Bridgwater to Seabank into seven sections and two further areas cover Hinkley Entry Substations and Sandford and Aust Substations. For each section of the route and associated elements such as CSEs and substations, the approach relating to the considerations undertaken of the sensitivity of the receptor, the magnitude of the effect and thus the significance of the effect is clearly set out.

4.4.2.4 As the PEIR is a high level assessment, there is the potential that notable local impacts are diluted in the overall evaluation, resulting in a less significant impact assessment due to the scale of the proposal. This is a concern which has been expressed by drainage consultees.

4.4.2.5 Possible mitigation measures have been proposed for the construction and operational phases, however in light of outstanding design detail (e.g. the nature of watercourse crossings) it is unclear whether these proposals are sufficiently robust. At present it is not considered that operational mitigation is set out in any level of detail. Further detail will be required in due course as specific elements of the project are developed. It is considered that particularly during the construction phase, proper supervision of the installation, use and maintenance and subsequent removal of access structures, works compound facilities etc is an important form of mitigation. Contribution to the costs of ensuring an adequate level of supervision by the local drainage authorities will be sought as a mitigation item.


4.4.3.1 The information presented is considered to be broadly appropriate for a PEIR and many aspects of concern have been clarified regarding possible local interactions between pylon bases/foundations and ditches, rhynes and watercourses and the potential for modification or mitigation explored.

4.4.3.2 However, options as yet undecided, for example for directional drilling (underground) or bridged (overground) crossings of rivers, need to be resolved to




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allow full assessment of local impacts. In particular the crossings of the River Axe, River Lox Yeo and Towerhead Brook need clarification. Further information requirements will be identified as necessary as the scheme proposals are refined. This further detailed information and clarification should be supplied as soon as possible to enable the Joint Councils to understand the full impact of the proposals.

4.4.3.3 A significant area of uncertainty is the measures associated with undergrounding and the measures and impacts that may result temporarily during construction, or permanently during operation from modification or redirection of local land and surface water drainage systems, this includes the impact of temporary construction infrastructure (such as haul roads and accesses) and the operational impact of the undergrounded cable on drainage. Further detail is required regarding the techniques and methods of containing silt laden runoff in the topsoil stripped area of the undergrounding corridor. This would include both runoff generated internally from the topsoil mounds and from over surface flows from upslope areas.

4.4.3.4 The IDBs continue to express concern over the potential creation of an impermeable layer in the undergrounding corridor from the cement bound sand surround and other protection to the cables. This is thought to be of particular concern in the flatter sections near watercourses where lateral shallow groundwater flows may be impeded. No information has been provided on artificial land drainage systems, their disruption or reinstatement.

4.4.3.5 In addition, although termed ‘Draft Flood Risk Assessments’, Appendices 10A to F do not provide any substantive detail of the proposals. The documents prepared may be classed as ‘Screening’ or Scoping Studies, as they present some readily available flood level information but lack detail.

4.4.3.6 The Sequential Test is cursorily addressed, identifying that much of the route and some of the associated elements of the route are located in High Probability Flood Zones but not justifying their presence there, given the particular circumstances and nature of the project.

4.4.3.7 The Exception Test is briefly addressed at a high level without the site specific mitigation measures being detailed that are required by the second part of the Test.

4.4.3.8 The ‘Draft FRAs’ refer to the NPPF, guidance documentation, and the criteria to be met for Energy and Electricity Networks Infrastructure (EN-1 and EN-5) but provide little information on the national and local bodies responsible for consenting the flood risk management elements within the proposal. The National and Local Planning Policy Framework is covered within the PEIR.

4.4.3.9 In addition the ‘Draft FRAs’ do not provide site specific, current or future topographic information or plans illustrating specific measures relating to flood risk management, protection, resistance or resilience, surface water management etc.

4.4.3.10 There are some factual errors within the ‘Draft FRA’ documents. For example CSE Compound to the South of the Mendip Hills is incorrectly identified as being in the North Somerset Internal Drainage Board (IDB) area and reference is made to the North Somerset Preliminary PFRA and Strategic Flood Risk Assessment (SFRA). The site is within the Lower Axe IDB area of the Somerset Drainage Boards Consortium and the Sedgemoor SFRA is the relevant strategic flood risk management document.




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4.4.4 Methodology 4.4.4.1 In general, the EIA methodology adopted for the PEIR is in accordance with the

principles set out in the National Grid Scoping Report and addresses concerns raised in the Joint Councils' Scoping Response.

4.4.5 Baseline 4.4.5.1 The baseline data collection has sought to collate relevant public data present that

for each section and sub-division of the route and the associated CSEs and substations. In this way, particular local aspects may be identified for which impacts and mitigation measures may need to be specifically addressed subsequently, without diluting their significance in the overall assessment. Taken as a whole, the approach to baseline data collection is considered appropriate.

4.4.5.2 Further detailed information is required for the River Axe crossing (Sedgemoor DC) and the River Lox Yeo and Towerhead Brook crossings (North Somerset), all within the undergrounded section. It is not clear whether these crossings will be by directional drilling or by bridge crossing. Local impacts could be significant at these locations and interact with other EIA parameters.

4.4.6 Impact assessment 4.4.6.1 Further detailed information is needed for the undergrounding corridor, in particular

relating to surface water management, silt control and temporary and permanent alteration of shallow ground water flows and land drainage systems. This applies to both the impact of temporary construction infrastructure such as haul roads and the operational effect of undergrounding. There are potentially significant implications for land quality where the route alignment crosses areas of Grade 1 agricultural land.

4.4.6.2 In addition, confirmation is required of the form of the River Axe crossing within Sedgemoor District and the River Lox Yeo and Towerhead Brook crossings within North Somerset, which are undergrounded sections. It is not clear whether these crossings would be by directional drilling or by bridge crossing. Local impacts could be significant at these locations and interact with other EIA parameters.

4.4.6.3 The gaps in the current scheme information do not allow a full assessment of the likely significant effects of the scheme, however where this information is available, the significance of effects attributed to impacts is in line with parameters previously established and appropriate for the level of assessment by the PEIR. Construction and Operational phases are considered.

4.4.7 Mitigation 4.4.7.1 Overall, in light of the baseline and impact assessment procedures, the range of

physical mitigation measures indicated for use during the construction phase in particular, is considered appropriate. However, the scale of the mitigation at particular sites where impacts may be significant will need to be developed further once the design has been developed.




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4.4.7.2 Supervision and control of temporary works during the construction phase, which it is understood could last four years for the overall project is likely to require input from the local authorities and appropriate provision will need to be made in requirements and the s106 agreement in this respect.

4.4.7.3 No specific operational phase mitigation has been identified. The details of the permanent changes to drainage systems e.g. around the undergrounding corridor, need to be developed further as design progresses.

4.4.7.4 The order seeks to restrict the decision period on any notification of works to 28 days from receipt. This is in conflict with the normal flood defence and land drainage consenting period which is two months. National Grid must amend this clause in line with standard working practice.




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4.5 Historic Environment 4.5.1.1 This section reviews Document 2.4, Chapter 11 (Historic Environment); Appendix

11A – Historic Environment Desk Based Assessment; and Appendix 11B – Assessment of Effects Within the Settings of Heritage Assets of the PEIR.

4.5.2 Topic summary 4.5.2.1 Statements that further assessment will be carried out including Geophysical Survey

and Trial Trench Assessment are repeated throughout the document. This indicates that full assessment has not yet taken place and suggests assessments of impacts are based on insufficient information representing at this stage estimates of significance of impacts. It is acknowledged that this is a PEIR, however considering that geophysical survey is stated to have commenced in April 2013, it is disappointing that the initial results of this have not been incorporated into the PEIR. The final ES submitted with the DCO must fully describe the results of these surveys, and the results of these should be shared with the relevant LPA archaeological officers and other relevant statutory bodies as they become available.

4.5.2.2 In terms of accessibility the PEIR does not address issue 5.18 of the Joint Councils' Scoping Response: “The cumulative effects on assets of local significance should be assessed for each study area and across local government areas based on Historic Environment Record (HER) responsibility. For example there should be a statement concerning the impacts on all assets within the county of Somerset.” It would assist greatly if a statement could be included regarding impacts within each district council area.

4.5.2.3 For clarity it would be preferable if the final EIA is divided into separate Topic sections rather than the existing PEIR sections that put Historic Environment with Traffic and Transport.

4.5.2.4 Where sufficient information has been acquired many of the impact assessments are sound. However, it is considered that the magnitude of effect on certain assets of high and very high significance has been under-assessed resulting in inappropriate significance of effect statements and therefore level of impact.

4.5.2.5 Mitigation statements lack detail and in some cases indicate a lack of understanding of the assets impacted (PEIR Section 11.7). This means that mitigation strategies are not adequate in terms of the National Planning Policy Framework and section 5.8.10 of NPS EN-1.

4.5.2.6 The Draft DCO requirements for Archaeology (Schedule 2 Requirement 17. 1-4) are repetitive and lack clarity. Requirements should better reflect mitigation and be clear in their meaning. The requirements should not include and/or statements such as “field-work and/or watching brief” as this is both factually incorrect (watching briefs are fieldwork) and introduce the potential for options of mitigation rather than requiring specific forms of mitigation. A requirement requiring a suitably qualified body/individual is welcomed but needs clarification concerning the terms qualified and suitable.




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Recommendation

4.5.2.7 Overall the document recognises some of its weakness in assessment of direct impacts to heritage assets and details further studies that will be included in the DCO application. Further consultation between National Grid (and their consultant) and the LPAs concerning the level of fieldwork assessment and a positive mitigation strategy is likely to enable a higher level of agreement in the Statement of Common Ground.


4.5.3.1 Paragraph 11.9 within the document lists the outstanding information and the Councils urge the production and dissemination of this information as soon as possible. The scope of these further assessments must be agreed with LPA Historic Environment Officers for each LPA in order to ensure adequacy of information and proper consultation. Locations and scale of surveys must be approved, as required by Institute for Archaeologists (IfA) standards and guidance.

4.5.3.2 The assessment of impacts on assets could be divided into areas based on LPA boundaries to enable an easier understanding of cumulative impact. This will improve the efficacy of consultation and LPA response as well as clarifying post-determination roles and responsibilities (it will also address scoping report response 5.18).

4.5.3.3 Figure 11.2 appears to have been scanned at a low resolution and is too unclear to be useful in relating the report text to figures. Figures 11.1 and 11.3 however are clear and useful.

4.5.3.4 The acceptance within the document that further assessment is required shows that at present there is insufficient information, particularly in regard to non-designated assets. The Councils consider that the consultation material supplied requires further detail/clarification in respect of the impacts on assets not assessed through field evaluation.

4.5.4 Methodology 4.5.4.1 The initial desk-based, field reconnaissance and the geophysical survey

assessment methodologies are in line with national practice, professional guidance and LPA requirements. They accord with the principles set out in the scoping study.

4.5.4.2 The limited scope of the geophysical survey carried out at the time of the PEIR submission and the lack of trial trenching means that the methodology does not adequately address the Joint Councils’ Scoping Response on issue points: 5.3, 5.4, 5.15, 5.17, 5.18, 5.30, 5.32, 5.33 and 5.38.

4.5.4.3 Appendix 11B contains the methodology for the setting assessment. There are issues with the method applied in understanding the contribution made by setting to designated assets. For example the assessment of Horsey DMV (SM45) does not introduce any further information/data than is recorded on the Somerset Historic Environment Record (SHER), but statements are made concerning the contribution made to the asset by its historic value. This statement appears unsupported as no detailed documentary or cartographic research has been carried out as part of this




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assessment. The asset’s setting is a predominantly flat, rural landscape subject to recent impacts such as the M5. However, the slight earthworks of the DMV are appreciable due to the surrounding flat landscape. Its association with Crook medieval village (AR25) is apparent because of the relatively uninterrupted open space between them. The inclusion of more modern vertical structures will further degrade the setting (as stated PEIR 11.2.46). Therefore the magnitude of effect is moderate not low adverse, hence the significance of effect should be major adverse (this leads to underplaying of Impacts: see 1.1.5 below).

4.5.4.4 Similar unsubstantiated statements concerning heritage value are made for Wick Barrow (SM87). Also there is no assessment of cumulative impacts (i.e. in relation to Hinkley Point C). Contrary to the setting assessment statement the perceptible setting is a major attribute to understanding the monument and its relationship with its immediate landscape.

4.5.4.5 As above the assessment of effects on the setting of Brent Knoll (SM96) appears to underplay the magnitude of effect. The PEIR assesses this as negligible for lattice pylons resulting in a minor/moderate magnitude but is presented as minor. The Joint Councils disagree with this assessment of effect magnitude and hence with the assessed significance of effect. Brent Knoll relationship is primarily with the Levels and the Severn Estuary. It forms a major defensive Iron Age monument on the interface between the two zones. It is not its relationship with other hills or similar sites that is its main attribute (as indicated in the setting assessment). Vertical intrusion into the flat landscape has a significant impact on the setting of the monument as shown by Planning Appeal decision APP/V3310//06/2031158 in which the inspector states, “the proposed turbines would represent an unacceptable visual intrusion into the flat landscape of the Somerset Levels, particularly in respect of the harm to the views to and from Brent Knoll. A defining characteristic of this part of the Somerset Levels is their flat and level nature; the verticality of the proposed turbines will be at odds with this character and will significantly undermine it. The character of the landscape will be significantly undermined and harmed in a location which constitutes a key gateway to Somerset. This adverse landscape impact cannot be mitigated against with additional landscaping or other measures.”

4.5.5 Baseline 4.5.5.1 The baseline datasets for desk-based assessment, historic map regression, field

reconnaissance survey and setting assessment (as detailed PEIR 11.3.18 to 11.3.22) are appropriate and comprehensive. The datasets utilised comply with IfA guidance and the requirements of the Somerset Archaeological Handbook12.

4.5.5.2 Baseline data for geophysical survey, palaeo-environmental, geo-archaeological potential and archaeological trial trenching survey is incomplete. Paragraphs 11.3.10/11 and 11.3.23 & 28 state that further assessment will be carried out but lack detail concerning locations. NPPF and NPS EN-1 (Section 5.8.9) require desk based and field survey where necessary in order to understand the significance of an asset and to be able to assess the impact of the proposals upon heritage assets. National Grid’s consultant should liaise with the LPA Historic Environment Officers to ensure that the surveys are undertaken in sufficient detail to satisfy the

12 SCC to provide reference




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requirements of NPPF and NPS EN-1. This is the minimum required to be able to assess the impact of the proposals upon archaeological assets.

4.5.6 Impact assessment 4.5.6.1 Where the assessment is lacking in detail (i.e. where geophysical survey and trial

trenching has not been carried out) the assessments of impacts statements are merely estimated (see PEIR 11.5.15).

4.5.6.2 There are issues with impact assessment that appear to understate the adverse effect. For example, the assessment of impacts on SM45 (Table 11.11) as moderate adverse underplays the impact on the setting of the monument. It takes no account of the fact that it will result in an increase in dominant structures between the two assets (SM45 and AR23) creating a sense of separation (contrary to the statement in the setting assessment). It also underplays the contribution made by the flat, rural landscape to the slight visible earthworks. Therefore, the magnitude of effect is not low adverse. The development in this area will dominate the site and it is considered that the impact should be assessed as moderate adverse. The significance of effect should therefore be major adverse. This also seems to be the case for the possible Roman Villa (AR172) where a moderate-high significant asset with a potential impact of total loss the significance of effect is assessed at minor adverse rather than major adverse.

4.5.6.3 Historic environment plans include data from the SHER including non-designated and designated assets and have an associated gazetteer. Plans should include (either as separate or integrated) records of the palaeochannels recognised through LiDAR (held by the SHER). These records will be submitted by the SHER to National Grid (or their consultant) for inclusion in the DCO EIA submission.

4.5.7 Mitigation 4.5.7.1 Some mitigation strategies are insufficient to accord with paragraph 141 of NPPF

and NPS EN1 5.8.20 as they will not “advance understanding … of heritage assets” and at this stage lack the detail to consider whether they are capable of compliance with paragraph 5.8.20 of National Policy Statement EN-1. For example Roman salt mounds and potential buried sites (AR 41 and AR 18 Table 11.8). The proposed mitigation for impacts on Roman Salt Mounds is to carry out watching briefs. These particular assets are complex, deeply stratified features composed of materials associated with an industrial practice. They contain discrete elements such as kilns and settling tanks, deposits or artefacts and have high potential for well preserved organic material and paleoenvironmental remains. The potential impacts of the development include the truncating of the asset (removing the later phases of the archaeology) through stripping of the lay-down area and deeper impacts caused by pylon foundations. The level and nature of these impacts on a complex site require mitigation based on investigation aimed at understanding the asset and the processes that created it. This cannot be achieved through only recording during development. A watching brief cannot provide the level of detail required and will result in severe damage to an asset without properly advancing understanding as required by NPPF paragraph 141.

4.5.7.2 The adverse impact on the setting of Horsey DMV (SM45) and associated settlement (AR23) and the loss of connection between the assets is not sufficiently




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recognised or mitigated within the PEIR. Further structured engagement is required in relation to localised repositioning of the development in this location.

4.5.7.3 The mitigation strategy can be designed and agreed only when geophysical survey and trial trenching has been completed, and the location and significance of archaeological deposits are understood. It is understood that the survey work will be completed during November 2013 and therefore the Councils strongly recommend to National Grid that they are consulted on the proposed mitigation strategy as soon as practicable but in any event, prior to formal submission of the DCO application.

4.5.7.4 Mitigation should seek to ensure any loss or harm to assets is offset by advancing understanding of the assets (as required by NPPF and NPS EN-1) not just recording as damage is incurred. Due to the nature of assets on the development route, a reactive mitigation strategy will result in uncontrolled damage to assets with recording based on impact area and not as an attempt to understand the asset. The strategy should be based on the understanding of all the assets impacted in order that controlled investigation can take place. This strategy could be flexible utilising offsetting of damage to some assets by investigating more fully assets of similar nature. For example full excavation of one Roman salt mound would improve understanding of that asset class allowing impacts on other mounds to take place with only limited recording. This form of strategy is mentioned in PEIR 11.7.14 but needs refinement and more detailed proposals need to be agreed; in particular the approach to offsetting must be applied consistently and will require the agreement of the Historic Environment Officers for all LPAs affected by the proposed development. Monitoring of the strategy would require input from Historic Environment Officers, which would need to be considered as part of a s106 agreement.

4.5.7.5 The cumulative impact of loss or harm to designated and non-designated heritage assets requires further consideration. Outreach opportunities discussed in paragraph 11.7.13 require more detail. An outcome based outreach programme involving partners and stakeholders that identifies audiences and methods of engagement should be developed and consulted on in advance of an application for Development Consent. This programme could be achieved (and partially delivered by the Councils) through a s106.




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4.6 Traffic and Transport 4.6.1.1 This section reviews Document 2.4, Chapter 12 (Traffic and Transportation). Please

note therefore that all references to paragraphs refer to this chapter. In relation to PRoW, additional comments are included in the Socio-Economic and Land Use Chapter.

4.6.1.2 In addition to the areas within North Somerset, Sedgemoor District and West Somerset, this section of the technical review represents commentary on transport related impacts in South Gloucestershire and Bristol City on behalf of South Gloucestershire Council and Bristol City Council.

4.6.2 Topic summary 4.6.2.1 The Councils consider that the consultation material supplied to date requires more

details relating to the TA, CTMP and a CMS as these will form the key elements of the DCO submission. At present, only a limited view can be given as to the adequacy of the transport impact. There is concern that until the source of the material for the proposed access routes/site enabling works is identified that the traffic assignment within a Transportation Assessment would at best be flawed and potentially miss out key junctions that would need assessment. This information is essential to enable an appropriate assessment of the proposal.

4.6.2.2 Within the TA there should be details of all the highway structures that are within proximity of the works/access routes; and details of agreed routing to avoid weak structures and/or mitigation measures to ensure their integrity would need to be included.

4.6.2.3 Trip generation figures relating to each distinct parcel of works (access point) are required so that the impact of the proposed development locally can be assessed. In addition to this the origin of where these trips are coming from is also required so that the impact on the highway network can be assessed.

4.6.2.4 The adopted methodology addresses many of the points set out in the Joint Councils' Scoping Response for the ES chapter. In this respect the chapter is considered to be acceptable, however a full TA and CMP are still required to validate the findings within the chapter.

4.6.2.5 The impact assessment shows that the construction will have a detrimental impact upon PRoWs as well as the Nailsea link. However, the impact assessment remains incomplete and invalidated until a full TA has been prepared.

4.6.2.6 As the impact assessment is still incomplete, full commentary on the acceptability of the proposed mitigation cannot be given at this stage.

4.6.2.7 The number of PRoW affected by the proposed development is considerable. For the paths affected National Grid proposes “path management” for paths which will be unavailable for up to six months. This is despite a number of the paths being used as access routes/haul roads for works traffic resulting in alterations to the surface of those paths. Paths are suggested for formal closure with a diversion being provided “if possible”. No discussion has taken place with SCC on the details of any proposed diversions or alternative routes or on how the path management would work. There are limited details in relation to the impacts on the PRoW network for those paths affected by the dismantling of the existing 132kV line. It is imperative




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that engagement takes place with the Highway Authority before any further proposals are considered on the PRoW network.

4.6.2.8 The consultation document contains a range of information relating to the proposed highway accesses, only some of which have been subject to discussion with the various local highway authorities. It is not possible at this stage for approval in principle to be given to all the proposed accesses due to the limited amount of information that has been provided for the purposes of this consultation. All proposed access arrangements will need to be subject to detailed technical audits. However, it is envisaged that work in this area will continue with National Grid prior to the submission of the DCO for the schemes. In the event that full technical approval cannot be granted prior to the DCO then such details will be determined through the articles within the DCO in consultation and agreement with the local highway authorities.

4.6.2.9 In terms of safeguarding the highway network for safety and efficiency, it is envisaged that a set of requirements will be included in the DCO. Further detailed engagement is required between the Joint Councils and National Grid to ensure that the mitigation proposals adequately reflect the scale of impact. The draft DCO that has been included in the consultation document contains a number of articles that have particular regards to the management and implementation of access requirements for construction purposes. It is important to note that these articles as they are currently drafted have financial implications for the Joint Councils and will require resourcing from the developer. Provision/funding needs to be made for the supervision and agreement of any traffic management works necessary to enable the development to be acceptable as it is not clear how this will be managed, leaving this to the utilities without agreement and supervision of the Highway Authority would not be acceptable.

4.6.2.10 Whilst it is unlikely that any Traffic Restriction Orders or Stopping Up Orders would be needed within the various highway authorities’ areas, given that the details of the TA have yet to come forward then appropriate provision and funding requirements would need to be included.

4.6.2.11 The extent of these funding requirements is still to be determined in its entirety but the Joint Councils will ensure that such information is discussed and agreed with the developer.


4.6.3.1 The Joint Councils recognise that National Grid intends to produce a TA in line with DfT’s “Guidance on Transport Assessments” (paragraph 12.1.9).

4.6.3.2 This document is critical to the assessment impact of the proposed development on the transport network during peak hours; and will serve to identify key junctions with existing capacity issues that may require further mitigation.

4.6.3.3 Key areas for assessment in the TA are identified within the chapter provided for the consultation (paragraph 12.1.11). It is noted that, this list is not extensive and reference should be made to previous scoping discussions before the TA is produced.




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4.6.3.4 A CTMP and CMS should be prepared to accompany the TA for the DCO application and the Joint Councils expect National Grid to engage them on the content and detail of these documents prior to formal submission.

4.6.3.5 It is noted that the urgency of agreeing the scope of the TA and CTMP is stated in paragraph 8.4.

4.6.3.6 The Joint Councils consider that the consultation material supplied to date requires more detail relating to the TA and CMP as these will form the key elements of the DCO submission. At present, only a limited view can be given as to the adequacy of the transport impact.

4.6.3.7 Paragraph 12.1.13 provides a list of meetings with Local Authorities. However, further meetings have taken place, which are not included within the list.

4.6.3.8 The Councils consider that the consultation material supplied does not provide adequate detail in relation to what constitutes ‘path management’ in relation to PRoW. It is necessary to have further information in relation to paths which require formal closure and the provision of an alternative route. Further engagement with the Councils should therefore be undertaken prior to the submission of the ES.

4.6.3.9 Appendix 12A is a list which provides details of paths affected by the proposed development. The list is however incomplete in relation to some of the affected paths, as the legal status of each path within the list should be shown. Appendix 12A also contains a column entitled ‘Discussed with LPA’ to which the answer in every case is “Yes”. Yet no specific discussion has taken place with the Highway Authorities on path management or any other aspect of the proposed development affecting PRoW.

4.6.3.10 Article 17 of the draft DCO refers to a “Footpath Implementation Plan”. It is suggested that the title of this document is changed to “Rights of Way Implementation Plan” to be more inclusive. The Highway Authorities need to be consulted on the forthcoming plan in advance of the DCO and ES submission.

4.6.4 Methodology 4.6.4.1 The adopted methodology addresses many of the points set out in the Joint

Councils' Scoping Response for the ES chapter. Points still requiring clarification are set out below.

4.6.4.2 Paragraph 12.3.12 of the draft chapter states that traffic data collection took place in June. While this is generally considered to be a neutral month, it should be noted that background traffic flows may be inflated by summer tourist traffic. In particular there is a demand placed upon the M5 during July and August. The HA may be best placed to advise on flows. However, the operation of the motorways directly affects driver behaviour and consequently the operation of more local routes in turn becomes affected. There may be some requirement for sensitivity testing, given the pressure on the M5 particularly during July and August. It should be noted that data collection for the purposes of junction assessment has not been undertaken and this will be required for the purposes of the completion of the TA and for the purposes of defining any required mitigation.

4.6.4.3 The Joint Councils accept the proposed years of assessment as stated in paragraph 12.3.22 (Baseline 2013, future years 2016 to 2020). However it is noted that




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National Grid state that their start date could be extended to 2024/25 and in such case, sensitivity tests would be required to be undertaken by National Grid to evaluate background traffic growth that would occur in these revised timescales.

4.6.4.4 However, it is not clear how these future years translate into the vehicle numbers that have been provided. The vehicle numbers are labelled as ‘Peak Construction Two-Way Flows’, it is assumed that the peak will occur at different times on different parts of the network.

4.6.4.5 Paragraph 12.3.24 of the chapter states that the impact of decommissioning cannot be assessed at this stage. However, the councils view is that some consideration should be made of how the effects of decommissioning and maintenance can be reduced through the design of the proposed infrastructure.

4.6.4.6 Paragraph 12.3.31 states that three years of accident data has been analysed to assess road safety along construction routes. The Joint Councils require an assessment to consider five years of accident data, and this especially should be carried out along routes with sensitive receptors.

4.6.4.7 The accident data that has been analysed does not appear to cover all routes. The coverage of the accident data should be agreed with the Joint Councils and revised and extended appropriately.

4.6.4.8 The impact assessment methodology laid out in paragraph 12.3.37 and 12.3.39 is approved based on IEMA guidelines and the Design Manual for Roads and Bridges. This is considered to be an acceptable methodology for the ES. The impact criteria used for EIAs stipulates the fairly crude margins of 30%, 60% and 90% in terms of slight, moderate and substantial change respectively. However, it is noted that these thresholds rarely fit well when considering impacts as part of a TA. The TA should be completed in accordance with TA guidance.

4.6.4.9 Commentary should be included throughout the chapter relating to any key issues that have been formally scoped out, to ensure that they have not simply been overlooked.

4.6.4.10 The scope of the chapter should be increased to include the effects of construction routes utilising and crossing PRoW. The TA should propose relevant and location-specific mitigation measures to minimise disruption to horse-riders, pedestrians and cyclists at these points, and ensure their safety.

4.6.4.11 Paragraph 8.21 of the Joint Councils' Scoping Response suggests that the development impact may be greater on national trails and promoted paths. The chapter should assess these PRoW separately, and provide justification for the approach taken.

4.6.4.12 It is accepted that the survey methodology for PRoW user counts is as set out in Design Manual for Roads and Bridges (DMRB) Vol 1, Section 3, Part 8. However we note that this document is very specific to pedestrians impacted upon by new roads, and does not necessarily relate to recreational users of the PRoW. This should be reflected in the forthcoming ES.

4.6.5 Baseline Environment 4.6.5.1 Further clarity should be provided on the construction routes. The uncertainty over

the access points means that the construction routes have not been fixed at present,




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which does not allow the Joint Councils to fully understand the environmental effects.

4.6.5.2 Table 12.2 lists highways affected by construction by route section, and predicts the sensitivity of receptors along each highway section. Evidence supporting the sensitivity classification is given for each highway section under paragraph 12.4 of the baseline. This approach is appropriate and the Joint Councils support the classifications assigned based on the evidence presented.

4.6.5.3 The Joint Councils preliminarily accept the number, location and timescales of ATC (Automatic Traffic Counter) surveys. However, given the uncertainty over the access locations, the Joint Councils reserve the right to ask for the collection of further traffic flows.

4.6.5.4 The cumulative assessment appears to only consider the construction impacts of the associated development for Hinkley Point C and does not take account of the construction workforce impacts which should also be included within this assessment. The cumulative impact should also consider the impact of the delivery of the Section 106 mitigation for Hinkley Point C which includes key infrastructure improvements for pedestrians, cyclists and road safety measures along key routes that will be used by the Hinkley Point C Connection construction traffic.

4.6.5.5 It is provided that PRoW condition surveys are to be submitted as part of the ES; however no indication is given as to when that information will be forthcoming. National Grid should share this information with the Joint Councils prior to its formal inclusion in the forthcoming ES.

4.6.5.6 Effects on allocations relating to recreational routes will be assessed through the PRoW assessment as will pedestrian/cycling delay and amenity. It should be noted that there is no mention of horse riders in the document. Horse riders are regular users of rural lanes and should be taken into account. For example, paragraph 12.4.273 refers to the UCR north of Wick on which it is anticipated that there will be a significant increase in traffic flows. This UCR is a quiet lane which is used by horse riders in the area and it should be noted that the impact on horse riders will be as much as it is for pedestrians and cyclists as a result of the significant increase in HGV movements.

4.6.6 Somerset County Council construction access and routing 4.6.6.1 SCC in working with National Grid and their appointed consultants have considered

the outline designs of a number of proposed access points that will allow the construction of the new pylon lines. Whilst a number of these are generally outlined in this consultation document, there are some proposed accesses indicated which have not been the subject of debate and others which have been agreed as inappropriate which are still shown.

4.6.6.2 Of specific concern is the indication within this consultation that there are two pylon lines to be considered. The first is the proposed new route that has been subject to detailed discussion and consideration; with the second being the removal of the existing pylons and line. The removal of the existing line seems to include the introduction of access points on the highway network that have not been discussed in any detail with the Highway Authority. This is of particular concern, given some of the points of access that have been broadly identified.




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4.6.6.3 Engineering drawings and supporting information will be required for each of the individual proposed locations, to include:-

A topographical survey of the access location;

Extent of existing and proposed highway boundary and National Grid ownership identified (or red line where notice has been served);

Demonstration that appropriate visibility splays have been secured;

Swept path diagrams to demonstrate that all vehicles can enter and exit the site safely;

Details of any alterations to the accesses that may be proposed (including but not limited to; widths, levels, construction, drainage, structures/culverts, fencing, passing places, lay-down areas, parking and turning provision, anticipated no and type of vehicles, etc.);

Duration of works at a specific location and the anticipated level of use at that location should be identified;

Any mitigation schemes that are required to the existing highway network to facilitate the use of the proposed access (including strengthening works to the existing carriageway construction as necessary, passing places, etc.);

Swept path drawings should be provided for all accesses at a scale of 1:200;

Swept path drawings should show all movements in and out for the largest Freight Transport Association vehicle expected to use the access;

Visibility splays should extend to the nearside edge of the carriageway and not to the centre;

‘x' distances of 2.4m should be provided and detailed on all accesses; and

All watercourses will need to be investigated, where necessary consent for alterations/crossings will need to be secured from the EA, IDB or SCC.

4.6.6.4 The project delivery programme remains unknown; confirmation will be required in order that adequate consideration can be given to this project in context with both HPC and non-associated committed development. Access locations may conflict with committed development and require adjusting accordingly.

4.6.6.5 It should be noted that no reference to route maintenance, either re-active or pro-active appears to have been included within the consultation document. Upon receipt of the transport assessment, further discussion will be required regarding route maintenance proposals, given the rural/unclassified nature of many of the access locations and the anticipated frequency of HGV traffic it is possible that pro-active enabling maintenance works may be required.

4.6.6.6 It is recommended that a baseline route condition survey is undertaken at the earliest opportunity, to include assessment of any existing structures along the route. The findings of the survey will assist in determining route maintenance proposals and will inform detailed design process.

4.6.6.7 Utility apparatus will require detailing on individual access design proposals. Where works conflict with existing apparatus locations, the utilities will require diverting,




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protecting to the satisfaction of both the statutory undertaker and the highway authority.

4.6.6.8 The A39 is a dedicated abnormal loads (ALs) route within Somerset, the designer should consult with Avon & Somerset Police regarding movement of any ALs.

4.6.6.9 Full consideration will need to be given to environmental & ecological sensitivity when assessing proposed access locations.

4.6.6.10 Further details will be required regarding duration of works at a specific location and the anticipated level of use.

4.6.6.11 Legacy use for these accesses must be identified and where necessary appropriate provision to facilitate legacy use will need to be included within the individual access legal agreements.

4.6.6.12 Where access locations are to be returned to existing layout upon completion of construction, appropriate provision will need to be included within the individual legal agreements.

4.6.6.13 SCC understand that the highway works are to be undertaken having regard to Articles within the DCO. One of these articles makes particular reference to the street authority & the undertaker entering into agreements. At this consultation stage the developer should be made aware that SCC (as street authority) fully expect to enter into individual legal agreements for the many elements of work on the highway. Where practical individual schemes or elements may be combined however it is anticipated that the legal agreements will take the general form of an agreement as if it were made using Section 278 of the Highways Act, albeit that SCC acknowledges that the phrasing of some clauses will need to differ to reflect the specific DCO requirements.

4.6.6.14 It is noted that the accesses can only be discussed in principle at this stage and that they will be subject to a detailed design review before they are formally agreed.

4.6.6.15 A detailed commentary on the proposed accesses is set out in Appendix A of this report. The commentary considers feasibility in context of layout and road safety for individual access locations only. Some general observations have been included regarding the route in the proximity of some of the locations, however, no consideration has been given to feasibility of overall strategic route. The SCC report at Appendix A also provides detail in relation to technical issues and information that will need to be submitted in order to secure technical approval.

4.6.7 North Somerset Council construction access and routing 4.6.7.1 North Somerset Council has reviewed the proposed access locations that have

been subject to on-going discussions with National Grid and their consultants. The comments listed below in detail relate solely to previous discussions with National Grid regarding proposed access arrangements. The level of detail provided in the consultation document has meant that North Somerset Council is not in a position to provide a view on these access arrangements but will continue technical discussions with National Grid as the scheme progresses.

4.6.7.2 It should be noted that the approval process for North Somerset Council will require the Applicant to provide a detailed design package that will need to consider the following:-




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Proposed traffic movements to and from each of the proposed temporary access, details of the construction traffic vehicle types, size and wheel loadings including specific details of the Lorries that will bring pre-fabricated steel lattice-work parts on to the site;

Information relating to traffic flows and classifications has been provided for comment. However, there does not appear to be any speed readings;

National Grid will need to provide mean and 85th percentile speed measurements for all locations where vehicle counts have been carried out;

A joint technical review and audit of the construction routes, temporary access and reinstatement works;

Localised highway widening, improvements to passing places to be agreed;

Signage and traffic management (temporary traffic signals);

Hours of use of the temporary access points (suitability of the routes in hours of darkness). It is important that we ensure a safe and effective route that is well maintained in all weather conditions for all seasons;

Pre-treatment/corrective work prior to the use of the construction access routes;

Pre-works condition surveys will be required of all the roads to be used for construction routes and inspection reports provided for all relevant structures affected by site traffic using those routes; and

Monitoring of the construction routes ‘cumulative traffic impacts’ possible ‘wear and tear’ agreement.

4.6.8 Detailed Comments 4.6.8.1 The following highway comments are provided based on the information submitted

by Curtins Consulting on the 11 June 2013 relating to the proposed temporary access points to the haul road within the boundary of North Somerset.

4.6.8.2 Details have been provided for access points BM 19 to BM 41 only.

4.6.8.3 The following initial comments are to be read in con-junction with the outline drawings submitted:-

Bellmouth Drawings MMD-320558-C-DR-CLD39-XX-0211 to 0222, 0226 to 0229 & 0240 to 0246;

Construction Access Plans MMD-320558-C-DR-CLD39-XX-0117 to 0139; and

Standard Drawings MMD-320558-C-DR-001 to 006.

BM 19 – A370

4.6.8.4 The access is located on the southern side of Weston Road (A370) approximately one mile to the west of the village of Congresbury. It is proposed to create a temporary access to serve towers 39 to 50.

4.6.8.5 Speed Limit: The A370 is a single carriageway for the majority of its length. The section of road between Congresbury and junction 21 of the M5 has a long history of




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accidents and for this reason sections of the road including the section outside the application site were subject to a reduced speed limit of 50 mph in 1999.

4.6.8.6 Road Traffic Accidents: There have been 6 recorded accidents (RTA’s) in the last 5 years on the section of Weston Road (A370) within 400m of the site. These accidents included 2 serious and one involving a vulnerable road user.

4.6.8.7 Access: The A370 (class A highway) is a busy major distributor road that links Weston-Super-Mare (M5 junction 21) with Bristol. The location for the access is at a location where the road alignment comprises a long sweeping bend to the east.

4.6.8.8 The section of the A370 adjacent to the site carries some 10,000 vehicles per day. The proposed temporary access is likely to involve peak hour movements by persons unfamiliar with the road.

4.6.8.9 The visibility at the access from the standard 2.4m set-back is limited to approximately 47m. The drawing incorrectly indicates the visibility to the east to the centre of the carriageway as 73m. Visibility should be based on actual speeds where available, which may be higher than the indicated speed limit, however, as the road is subject of a 50 mph speed limit, the recommended visibility distance would be 160m Stopping Sight Distance (SSD) in each direction. The visibility to the east is considered to be substandard.

4.6.8.10 There are double white lines in the centre of the carriageway at the access to the site which prohibits overtaking and parking. Two of the RTA’s recorded near to the site involved vehicles turning in the carriageway.

4.6.8.11 A vehicle wishing to turn right into the site is likely to cause the following traffic to come to a complete standstill while the right turning vehicle waits for a safe gap in the opposing traffic lane.

4.6.8.12 The Department for Transport Document TD 42/95 is clear on the matter of when the provision of a ghosted right turn lane is required. Clause 2.16 states ‘upgrading should always be considered where vehicles waiting on the major road to turn right inhibit the through flow and create a hazard’. It is considered that turning movements to the proposed temporary access should be strongly resisted without the provision of a ghosted right turn lane junction. This form of layout would considerably reduce the risk of the rear end shunting accidents as well as considerably reducing the inconvenience and delay to the A370 east bound traffic.

4.6.8.13 Without the provision of the above recommended junction improvement and adequate visibility splays, it is considered that the access would be prejudicial to highway safety and is therefore not acceptable.

4.6.8.14 Consideration should be given to diverting the haul road a short distance to the west to join with the existing access arrangement to Moorland Park where a right turn lane exists on the A370.

BM 20 & BM 21 Dalemoor Lane

4.6.8.15 Dalemoor Lane at the point of the proposed temporary access is an unadopted lane that is used for agriculture purposes.

4.6.8.16 This is a crossing point only with no access along Dalemoor Lane.

BM 22 & 23 Drove Way, Sandford




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4.6.8.17 It is proposed to create two temporary access points onto Drove Way (class C highway) on opposite sides of the road as a crossing point on the haul road. The road width is between 3.5 and 4m.

4.6.8.18 Subject to the necessary removal of the vegetation within the proposed visibility splays to a maximum height of 900mm above ground level, the visibility at the proposed accesses is considered to be acceptable.

4.6.8.19 Drove Way has not been identified as a construction traffic route, it is therefore assumed that the proposed access off the A370 (BM 19) will be the traffic route to serve the haul road for overhead tower line C-LD39 to CL-LD50.

4.6.8.20 Appropriate advanced warning signage of the crossing point on the public highway and the haul road will be required on all the approaches.

4.6.8.21 Droveway Bridge has been included on list of structures required to be inspected.

BM 24

4.6.8.22 The proposed access point is to the north side of the A370 approximately 50m to the west of the access point BM 19.

4.6.8.23 The comments as noted above for BM 19 in relation to A370 at this location are applicable for this proposed access point.

4.6.8.24 It is noted that the proposed visibility (subject to the clearance of the vegetation) is reasonable however, without the provision of a ghost right turn lane it is considered that the access would be prejudicial to highway safety and is therefore not acceptable.

4.6.8.25 Consideration should be given to diverting the haul road a short distance to the west to join with the existing private road between Mendip Poultry Farm and Beacon Works where a right turn lane exists on the A370.

BM 25

4.6.8.26 It is proposed to create a temporary access point to the south side of Lampley Road (class C highway) on a fairly straight section of the road. The road width at the proposed access point is 5.8m.

4.6.8.27 There are a number of properties that front onto the road, but they are either isolated single properties or in small groups set back from the highway.

4.6.8.28 The visibility available at the proposed access is considered to be acceptable.

4.6.8.29 The character of the road at the proposed access point with its straight alignment lends its self to higher vehicle speeds. It is considered that appropriate advanced warning signage of the access point onto the public highway is essential.

4.6.8.30 Lampley Bow Culvert has been included on list of structures required to be inspected.

BM 26 & 27

4.6.8.31 It is proposed to create two temporary access points onto Wemberham Lane (unclassified highway) on opposite sides of the road as a crossing point on the haul road.




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4.6.8.32 Wemberham Lane is subject to edge failure and general subsidence. It has not been identified as a route for construction traffic. It is assumed that it will only be used as a crossing point.

4.6.8.33 The visibility available at the proposed accesses is considered to be acceptable.

4.6.8.34 Appropriate advanced warning signage of the crossing point on the public highway and the haul road will be essential on all the approaches.

4.6.8.35 Osmond Railway Bridge has been included on list of structures required to be inspected.

TOWER ROUTE LD54 BM 05 & BM 06 Lampley Road

4.6.8.36 It is proposed to create two temporary access points on opposite sides of Lampley Road (class C highway) on a fairly straight section of the road. The road width at the proposed access point is 5.8metres.



4.6.8.39 The character of the road at the proposed access point with its straight alignment lends its self to higher vehicle speeds. It is considered that appropriate advanced warning signage of the access/crossing point on the public highway and on the haul road approaches is essential.

BM 30 & 31

4.6.8.40 Rust Lane is an unadopted lane that is used for agriculture access purposes.

4.6.8.41 No comments.

BM 32 & 33

4.6.8.42 It is proposed to create two temporary access points on Kennmoor Road (class C highway) on a straight section of the road. The road width at the proposed access points is 5m.

4.6.8.43 Kennmoor Road is a rural road with a few isolated single properties set back from the highway. The proposed access points are on a long straight section of the road where the vehicle speeds are very high.

4.6.8.44 Road Traffic Accidents: There have been a number of RTA’s over the years at the road junctions of Kennmoor Road with Ham Lane, Kenn Street and Nailsea Wall, which are directly related to high speeds due to the nature of the road.

4.6.8.45 The visibility available at the proposed accesses (subject to the vegetation clearance) is considered to be acceptable.

4.6.8.46 The character of the road at the proposed access points with its straight alignment lends its self to very high vehicle speeds. It is therefore considered that appropriate advanced warning signage of the access point onto the public highway and on the haul road approaches is essential.

4.6.8.47 There are a number of structures identified on the construction route to these temporary access points that are required to be inspected.




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BM 33A

4.6.8.48 It is proposed to form a temporary access onto Nailsea Wall lane (class C Highway) on the outside of a bend in the road where there is an existing access to North Drove an unadopted unmade up lane.

4.6.8.49 Nailsea Wall Lane is subject to edge failure and general subsidence.

4.6.8.50 The visibility at the proposed access subject to the necessary vegetation clearance is considered to be acceptable.

4.6.8.51 Due to the required turning movement for vehicles accessing and exiting the North Drove consideration should be given to widening the west side of the bell mouth.

4.6.8.52 Access for construction traffic will be too/from the west only. Nailsea Wall Lane to the east of the access is unsuitable.

BM 33B, 34, 35, 36 & 37

4.6.8.53 All the above proposed access points are onto North Drove an unadopted unmade up lane that is used for agriculture purposes.


BM 37A

4.6.8.55 It is proposed to create two temporary access points onto Causeway (class C highway) on opposite sides of the road as a crossing point on the haul road. The road width is 4.2m.

4.6.8.56 The Causeway is subject to edge failure and general subsidence. It has not been identified as a route for construction traffic. It is assumed that it will only be used as a crossing point.

4.6.8.57 The visibility to the north side of the east side access is slightly impeded by the existing bridge structure however the available visibility at the proposed accesses is considered to be acceptable.

4.6.8.58 Appropriate advanced warning signage of the crossing point on the public highway and the haul road will be required on all the approaches.

4.6.8.59 There are a number of local structures that are required to be inspected.

BM 38

4.6.8.60 The proposed temporary access is located on the southern side of Clevedon Road (B3130) a class B highway that is a busy road that links Clevedon with Nailsea. The location of the access is on a section of the road where there are a number of tight bends in the road alignment both to the east and west. The road width is 6.5m with boundary walls running each side of the carriageway.

4.6.8.61 There has been one RTA on the bend to the east side of the proposed access point that involved a vulnerable road user a cyclist.

4.6.8.62 The visibility at the access from the standard 2.4m set-back is limited to approximately 37m. The drawing incorrectly indicates the visibility to the east to the centre of the carriageway as 65m. The speed limit for this section of the road is the national speed limit 60 mph, however, the vehicles speeds are fairly low in the




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vicinity of the access due to the road alignment with the tight bends acting as speed reducing features. The visibility to the east is considered to be substandard.

4.6.8.63 The drawing states that there is a low level boundary wall to the east side of the access, this wall is not considered to be low level as it measures 1.5m above the surface of the carriageway.

4.6.8.64 It is considered that the access would be prejudicial to highway safety and is therefore not acceptable.

4.6.8.65 Consideration is to be given to the possibility of relocating the access further to the west of the proposed site.

BM38A

4.6.8.66 It is proposed to use the existing access arrangement off Tickenham Hill (class B highway) which is on a straight section of the road approximately 20m to the west of the junction with Tower House Lane.

4.6.8.67 Tickenham Hill bypasses the main Town of Nailsea as a commuter route connecting Clevedon (M5 Junction 20) to Bristol. There are a number of properties that front onto the road, but they are set back from the highway. The proposed access point is on a long straight section of the road where the vehicle speeds are very high, and overtaking is common.

4.6.8.68 The visibility to the west side of the access is restricted by some street furniture namely; a traffic counter box, two WPD timber posts and a nameplate for Wraxall. Subject to the satisfactory removal/relocation of the street furniture and vegetation clearance the visibility is considered to be acceptable.

4.6.8.69 There have been 4 recorded accidents (RTA’s) in the last 5 years on the section of Tickenham Hill within 50m of the proposed access point. Two of the accidents involved vehicles turning at the nearby road junction; a major contributing factor was vehicle speeds.

4.6.8.70 The character of the road at the proposed access points with its straight alignment lends its self to very high vehicle speeds. It is therefore considered that appropriate advanced warning signage of the access point onto the public highway making it clear that large vehicles are slowing to turn into the access together with other suitable signage will be essential.

BM 39

4.6.8.71 It is proposed to create a temporary access point to the west of Whitehouse Lane (class C highway) on the outside of a bend in the road. The road width of Whitehouse Lane near to the proposed access point is 9m.

4.6.8.72 The access is not directly onto Whitehouse Lane but is to be formed within the existing wide junction arrangement with Cadbury Camp Lane. The relevant visibility to be reviewed is the existing junction arrangement on Whitehouse Lane not at the access as indicated on the drawing.

4.6.8.73 Due to the character of Whitehouse Lane near to the proposed access point a number of loss of control RTA’s have occurred over the last five years due to a combination of speed and the road alignment.




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4.6.8.74 It is considered that appropriate advanced warning signage of the access point onto the public highway is essential.

BM 40

4.6.8.75 It is proposed to create a temporary access point to the east side of Whitehouse Lane (class C highway) on the inside of a bend some 35m to the south of the junction with Caswell Hill. The road width of Whitehouse Lane near to the proposed access point is 5.5m.

4.6.8.76 The visibility indicated to the south of the proposed access as 50m is incorrect. The available visibility is measured to be 30m to a point where the vertical alignment (brow) severely reduces the visibility at the access. The visibility is substandard.

4.6.8.77 It is worth noting that currently the visibility for vehicles exiting Caswell Lane onto Whitehouse Lane heading south is extremely poor. Drivers carrying out this manoeuvre will be looking down Naish Hill to the north and would not be aware of traffic using the proposed access some 35m to the south.


BM 41

4.6.8.79 It is proposed to create a temporary access point to the south side of Caswell Hill (class C highway) on the outside of a slight bend in the road at an existing gateway access. The road width at the proposed access point is 6.8m.


4.6.8.81 There is a corrugated steel pipe culvert under Caswell Hill that has been included on the list of structures required to be inspected.

4.6.9 Structures 4.6.9.1 The following highway comments are provided based on the revised package of

information submitted by Curtins Consulting on the 5 August 2013 relating to the proposed temporary access points to the haul road within the boundary of North Somerset.

4.6.9.2 The following initial comments are to be read in con-junction with the drawings submitted and previous comments made by NSC (Highways) on the 24 June 2013.

4.6.9.3 For reference purposes the headings used for each of the proposed temporary access points are as stated on the submitted drawings.

TOWER ROUTE - BM 06 & 07 Max Mill Lane

4.6.9.4 It is proposed to create two temporary access points onto Max Mill Lane (unclassified highway) on opposite sides of the road as a crossing point on the haul road.

4.6.9.5 Max Mill Lane has not been identified as a route for construction traffic. It is assumed that it will only be used as a crossing point.

4.6.9.6 The visibility splays as indicated have incorrectly assumed the total removal of all obstructions.




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4.6.9.7 The visibility available at the proposed access points subject to the necessary removal of the vegetation are considered to be acceptable.

4.6.9.8 Appropriate advanced warning signage on the approaches to the crossing point on the public highway and the haul road will be essential.

UNDERGROUND ROUTE - BM 08 & 09 Castle Hill/Banwell Road (A371)

4.6.9.9 It is proposed to create two temporary access points on opposite sides of Castle Hill (A 371) approximately half a mile to the south of the village of Banwell.

4.6.9.10 Speed Limit: The A371 is a single carriageway. The section of road between Banwell and Winscombe has a long history of accidents including the section where it is proposed to create the temporary access points, which is subject to a reduced speed limit of 50 mph.

4.6.9.11 Road Traffic Accidents: There have been 3 recorded accidents (RTA’s) in the last 5 years on the section of the A371 within 600m of the proposed accesses. These accidents include a fatal that involved vehicles travelling at high speed on the bend immediately to the north of the proposed access points. A major contributory factor to the other two accidents (slight) was also high vehicle speeds.

4.6.9.12 Access points: The A371 (class A highway) is a busy Distributor road that links the East side of Weston-Super-Mare with the A38. The location for the temporary access points is where the road alignment comprises a long sweeping bend to the north and a long straight section of the road to the south. Vehicle speeds are very high, and overtaking is common.

4.6.9.13 The drawing incorrectly indicates the visibility splays to the north. Visibility should be based on actual speeds where available, which may be higher than the indicated speed limit, however, as the road is subject of a 50 mph speed limit, the recommended visibility distance would be 160m SSD in each direction. The visibility to the north where there is a bend in the road is considered to be substandard. It is considered that the access/crossing points would be prejudicial to highway safety and is therefore not acceptable.

4.6.9.14 Consideration should be given to positioning the access points for the haul road some distance to the south where there is an existing parking/lay-by feature. However, as this location would be subject to the national speed limit it is likely that a road safety audit would be required for any such alternative proposal.

UNDERGROUND ROUTE - BM 10 & 11 Towerhead Road

4.6.9.15 It is proposed to create two temporary access points on opposite sides of Towerhead Road (A368) just to the west of the Sandford village boundary.

4.6.9.16 Speed Limit: The A368 (class A highway) is subject to the national speed limit in the vicinity of the proposed temporary access points. The section of road is a single carriageway rural road that connects the villages of Banwell and Sandford.

4.6.9.17 Road Traffic Accidents: There has been 1 recorded accident (RTA’s) in the last 5 years in the vicinity of the proposed access points. The accident involved vehicles travelling at high speed.

4.6.9.18 There is confusion between the access points as indicated on the layout drawing and the position of the access points as photographed, they are not the same




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locations. Before any informed comments can be provided clarification is required as to the exact position proposed for the two access points on Towerhead Road.

UNDERGROUND ROUTE - BM 12 & 13 Mead Lane

4.6.9.19 It is proposed to create two temporary access points onto Mead Lane (unclassified highway) on opposite sides of the road as a crossing point on the haul road.

4.6.9.20 Mead Lane at the point of the proposed crossing is a narrow lane with high vegetation fronting onto both sides of the carriageway. The road surface is in poor condition. It has not been identified as a route for construction traffic. It is assumed that it will only be used as a crossing point.

4.6.9.21 Subject to the necessary removal of the vegetation as indicated on the bellmouth general arrangement drawing the visibility to be provided at the temporary access points is considered to be acceptable.


TOWER ROUTE - BM 04 & 05 Drove Way, Sandford

4.6.9.23 It is proposed to create two temporary access points onto Drove Way (class C highway) on opposite sides of the road as a crossing point on the haul road. The road width is between 3.5 and 4m.

4.6.9.24 Subject to the necessary removal of the vegetation within the proposed visibility splays to a maximum height of 900mm above ground level, the available visibility at the proposed access points is considered to be acceptable.

4.6.9.25 Drove Way has not been identified as a construction traffic route, it is therefore assumed that the proposed access off the A370 (BM 19 BM 01 Moorland Park) will be the traffic route to serve the haul road for overhead tower line C-LD39 to CL-LD50.

4.6.9.26 Appropriate advanced warning signage of the crossing point on both the public highway and the haul road will be required for all the approaches.

TOWER ROUTE - BM 02 & 04 Dalemoor Lane

4.6.9.27 Dalemoor Lane at the point of the proposed temporary access is an unadopted lane that is used for agriculture purposes.

4.6.9.28 It is assumed from the information provided that this is a crossing point only with no access along Dalemoor Lane.


TOWER ROUTE - BM 01 Un-named Road to Moorland Park

4.6.9.30 It is proposed to create a temporary access point onto a private unadopted road that serves the Moorland Park site. No comment.

4.6.9.31 It is required that the existing junction arrangement on the A370 is reviewed where vehicles will enter and exit into and from the un-named road. Details of the existing arrangement and any proposed improvements are to be provided.

TOWER ROUTE - BM 01 Iwood Lane




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4.6.9.32 It is proposed to form two temporary access points on opposite sides of Iwood lane (unclassified Highway) approximately 50m to the south of its junction with Stock lane (B3133)

4.6.9.33 The section of Iwood Lane is fairly straight in the vicinity of the proposed access points. No bellmouth arrangement has been indicated for the proposed access to the Sub-Station to the west side of Iwood lane.

4.6.9.34 The visibility at the proposed access points subject to the necessary vegetation clearance are considered to be acceptable.

4.6.9.35 Appropriate advanced warning signage of the crossing point on both the public highway and the haul road will be required for all the approaches.

TOWER ROUTE - BM 01 Puxton Road

4.6.9.36 It is proposed to create a temporary access point to the south side of Puxton Road (class C highway) on the outside of a slight bend in the road at an existing gateway access.

4.6.9.37 The visibility available at the proposed access subject to the proposed vegetation clearance works indicated is considered to be acceptable.

4.6.9.38 There are a number of associated structures that have been included on the list of structures required to be inspected relating to the construction access route to this proposed access.

UNDERGROUND ROUTE - BM 01 A370

4.6.9.39 The proposed access point is to the north side of the A370 opposite an existing Lay-by feature to the south side of the road. There is an existing street light and a raised platform bus stop arrangement at the proposed access point. Both of these will be required to be relocated whilst the works are in progress and replaced on completion of the scheme.

4.6.9.40 Speed Limit: The section of the A370 between Congresbury and junction 21 of the M5 has a long history of accidents and for this reason sections of the road including the section where this proposed temporary access is to be provided were subject to a reduced speed limit of 50 mph in 1999.

4.6.9.41 Road Traffic Accidents: There have been 11 recorded accidents (RTA’s) in the last 5 years on the section of Weston Road (A370) within 500m of the proposed temporary access point. These accidents included 1 serious involving a vulnerable road user.

4.6.9.42 Access: The A370 (class A highway) is a busy major distributor road that links Weston-Super-Mare (M5 junction 21) with Bristol. The location for the access is on the inside of a long sweeping bend. This section of the A370 carries some 15,000 vehicles per day. The proposed temporary access is likely to involve peak hour movements by persons unfamiliar with the road. However, it is noted that the vehicle movements proposed are left turn in and out. Confirmation is required that this is correct.

4.6.9.43 The visibility at the access from the standard 2.4m set-back is limited to approximately 50m to the west. Visibility should be based on actual speeds where available, which may be higher than the indicated speed limit, however, as the road is subject of a 50 mph speed limit, the recommended visibility distance would be




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160m SSD in each direction. The visibility to the east and west is considered to be substandard.

4.6.9.44 It is considered that this proposed access arrangement should be the subject of a road safety audit.

TOWER ROUTE - BM02 A370

4.6.9.45 The proposed access point off the A370 is approximately some 1500m north west of the temporary access point Underground Route BM 01. The access point is at the centre of a 300m straight section of road between two bends. There are no recorded accidents (RTA’s) on this section of road in the last 5 years.

4.6.9.46 There is an existing street light at the proposed access point, which will need to be relocated whilst the works are in progress and replaced on completion of the scheme.

4.6.9.47 The visibility splays indicated are incorrectly drawn.

4.6.9.48 The comments as noted above for BM 01 in relation to A370 are applicable for this proposed access point.

4.6.9.49 There are double white lines in the centre of the carriageway across part of the proposed temporary access which prohibits overtaking and parking. However, it is noted that the vehicle movements proposed are left turn in and out. Confirmation is required that this is correct.

4.6.9.50 As for BM01 Underground Route it is considered that this proposed access arrangement should be the subject of a road safety audit.

TOWER ROUTE - BM01 A370

4.6.9.51 Previous comments have been made on this proposed access (24.6.13 for BM 24).

4.6.9.52 The comments as noted above and previously for access points in relation to A370 are applicable for this proposed access point.

4.6.9.53 It is noted that the proposed visibility (subject to the clearance of the vegetation) is considered to be reasonable. It is noted that vehicles will access from the J21 direction left turn in and right turn out only. Confirmation is required that this is correct.

4.6.9.54 As for BM01 Underground and BM02 Tower route above it is considered that this proposed access arrangement should also be the subject of a road safety audit.

TOWER ROUTE - LD54 BM 01 & LD 59 BM01 Lampley Road

4.6.9.55 It is proposed to create two temporary access points on opposite sides of Lampley Road (class C highway) on a fairly straight section of the road. The road width at the proposed access point is 5.8m.



4.6.9.58 The character of the road at the proposed access point with its straight alignment lends its self to higher vehicle speeds. It is considered that appropriate advanced




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warning signage of the access/crossing point on the public highway and on the haul road approaches is essential.

TOWER ROUTE - BM 02 & 03 Wemberham Lane

4.6.9.59 It is proposed to create two temporary access points onto Wemberham Lane (unclassified highway) on opposite sides of the road as a crossing point on the haul road.

4.6.9.60 Wemberham Lane is subject to edge failure and general subsidence. It has not been identified as a route for construction traffic. It is assumed that it will only be used as a crossing point.

4.6.9.61 The visibility available at the proposed accesses is considered to be acceptable.


TOWER ROUTE - LD61 BM01 Lampley Road

4.6.9.63 It is proposed to create a temporary access point to the north side of Lampley Road (class C highway) on the inside of a bend in the road approximately 180m to the west of its junction with North End Road (B3133). The road width at the proposed access point is 5.5m not 7.3m as stated on the drawing.

4.6.9.64 There is a WPD post located within the proposed access bellmouth. This will need to be relocated if the access is considered to be acceptable.

4.6.9.65 The visibility splay to the west side of the proposed temporary access has been incorrectly detailed. The visibility actually available is considered to be substandard.

4.6.9.66 For further consideration to be given to this access arrangement it will be required to be the subject of a road safety audit.

UNDERGROUND ROUTE - LD62 BM 01 & 02 Kennmoor Road

4.6.9.67 As previously commented for BM 32 & 33:-

4.6.9.68 It is proposed to create two temporary access points on Kennmoor Road (class C highway) on a straight section of the road. The road width at the proposed access points is 5m.

4.6.9.69 Kennmoor Road is a rural road with a few isolated single properties set back from the highway. The proposed access points are on a long straight section of the road where the vehicle speeds are very high.

4.6.9.70 Road Traffic Accidents: There have been a number of RTA’s over the years at the road junctions of Kennmoor Road with Ham Lane, Kenn Street and Nailsea Wall, which are directly related to high speeds due to the nature of the road. The visibility available at the proposed accesses (subject to the vegetation clearance) is considered to be acceptable. The character of the road at the proposed access points with its straight alignment lends its self to very high vehicle speeds. It is therefore considered that appropriate advanced warning signage of the access point onto the public highway and on the haul road approaches is essential.

UNDERGROUND ROUTE - LD74 BM 01 Nailsea Wall




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4.6.9.71 It is proposed to form a temporary access onto Nailsea Wall lane (class C Highway) on a fairly straight section of road.

4.6.9.72 Nailsea Wall Lane is subject to edge failure and general subsidence.

4.6.9.73 The visibility at the proposed access is considered to be acceptable.

TOWER ROUTE - LD76 BM 01 North Drove/Causeway/Hanham Way

4.6.9.74 It is proposed to form a temporary access onto Causeway (class C highway) at an existing access arrangement to North Drove an unadopted unmade up lane that is used for agriculture purposes.

4.6.9.75 The Causeway is subject to edge failure and general subsidence.

4.6.9.76 The visibility available at the proposed access (subject to the vegetation clearance) is considered to be acceptable.

4.6.9.77 Appropriate advanced warning signage of the access point on the public highway and the haul road/North Drove will be required on all the approaches.

4.6.9.78 There are a number of local structures that are required to be inspected and have been included on the road structures schedule as set out below.

TOWER ROUTE - BM 01 Engine Lane, Nailsea

4.6.9.79 It is proposed to create a temporary access point to the south west side of Engine Lane (unclassified road) at its junction with Blackfriars Road.

4.6.9.80 The visibility splays have been incorrectly indicated. The visibility actually available at the proposed access point is substandard. It is considered that the access would be prejudicial to highway safety and is therefore not acceptable.

4.6.9.81 Consideration is to be given to the possibility of relocating the access further to the east of the proposed access point on the outside of the nearby bend in the road.

TOWER ROUTE - W Route BM02 Causeway Nailsea

4.6.9.82 The proposed access point is located on the Causeway (class C highway) approximately 100m to the north of LD76 BM01. The road width is 4.6m.

4.6.9.83 As noted above the causeway is subject to edge failure.

4.6.9.84 The visibility available at the proposed access (subject to the vegetation clearance) is considered to be acceptable.

4.6.9.85 Appropriate advanced warning signage of the access point on the public highway will be essential.

TOWER ROUTE - W Route BM03 & 04 Church Lane

4.6.9.86 It is proposed to create two temporary access points onto Church Lane (unclassified highway) on opposite sides of the road as a crossing point for the haul road. The road width is 3.5m.

4.6.9.87 There is a WPD pole within the proposed bellmouth that will need to be re-located whilst the works are in progress.

4.6.9.88 Church lane has not been identified as a route for construction traffic. It is assumed that the access points will only be used as a crossing point.




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4.6.9.89 The visibility for both access arrangements (subject to the lowering of the stone boundary walls) is considered to be acceptable.

4.6.9.90 It is therefore considered that appropriate advanced warning signage of the access points onto the public highway and on the haul road approaches is essential.

4.6.9.91 In order to lessen the impact on the existing stone wall consideration could be given to using the existing gateway and associated field tracks that are located some 20m to the east of the proposed bellmouths. The road carriageway is 5.3m wide at this point.

TOWER ROUTE - W Route BM 05 & 06 Clevedon Road

4.6.9.92 It is proposed to form two temporary access points on opposite sides of Clevedon Road (B3130) (class B Highway) a busy road that links Clevedon with Nailsea/south Bristol. The access points are located some 0 – 60m from a right angle bend in the road to the north.

4.6.9.93 The visibility splays have been incorrectly indicated. The visibility available even with the proposed removal of the vegetation is sub-standard.

4.6.9.94 The speed limit for this section of the road is the national speed limit 60 mph, however, the vehicles speeds are fairly low in the vicinity of the access due to the road alignment with the tight bends acting as speed reducing features.

4.6.9.95 There has been one RTA at on very close to each of the bends both north and south of the proposed access points.

4.6.9.96 It is considered that the access points would be prejudicial to highway safety and are therefore not acceptable.

4.6.9.97 Consideration could be given to locating the access to the west side at the existing access arrangement to the former Garden centre, with the other access re-located to the east opposite, this would result in the access positions being at a more central location between the two bends in the road.

4.6.9.98 It is considered that any proposed access arrangements on this section of the road should be the subject of a road safety audit.

UNDERGROUND ROUTE - LD 79 BM 01 Clevedon Road

4.6.9.99 The proposed temporary access is located on the southern side of Clevedon Road (B3130) a class B highway. The location of the access is on a section of the road where there are a number of tight bends in the road alignment both to the east and west. The road width is 6.5m with boundary walls running each side of the carriageway.

4.6.9.100 There has been one RTA on the bend to the east side of the proposed access point that involved a vulnerable road user a cyclist.

4.6.9.101 The speed limit for this section of the road is the national speed limit 60 mph, however, the vehicles speeds are fairly low in the vicinity of the access due to the road alignment with the tight bends acting as speed reducing features. The access point is centrally located between the two tight bends approximately 100m to the east and west. This position for the temporary access is considered to be an improvement on that previously proposed nearby for BM 38.




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4.6.9.102 As noted above it is considered that any proposed access arrangements fronting onto Clevedon Road should be the subject of a road safety audit.

TOWER ROUTE W ROUTE BM07 Whitehouse Lane/Cadbury Camp Lane

4.6.9.103 Previous comments provided for this proposed temporary access BM 39 are applicable to this temporary access point.

4.6.9.104 It is proposed to create a temporary access point to the west of Whitehouse Lane (class C highway) on the outside of a bend in the road. The road width of Whitehouse Lane near to the proposed access point is 9 m.

4.6.9.105 The access is not directly onto Whitehouse Lane but is to be formed within the existing wide junction arrangement with Cadbury Camp Lane.

4.6.9.106 It is considered that appropriate advanced warning signage of the access point onto the public highway is essential.

TOWER ROUTE - W ROUTE BM08 Whitehouse Lane

4.6.9.107 It is proposed to create a temporary access point to the east side of Whitehouse Lane (class C highway) on a fairly straight section of the road.

4.6.9.108 The access has been proposed following the refusal of the proposed temporary access nearby to the north BM 39 that was considered unacceptable on highway safety grounds as stated in the previous comments.

4.6.9.109 The visibility available at the proposed access subject to the proposed vegetation clearance works indicated is considered to be acceptable.

4.6.9.110 The provision of appropriate advanced warning signage of the access point on the public highway is essential.

UNDERGROUND/TOWER ROUTE - W ROUTE BM09, BM10 & LD92 BM01 Caswell Lane

4.6.9.111 It is proposed to create three temporary access points onto Caswell Lane (class C highway) as follows:-

i) At the junction with Caswell Hill.

ii) On the outside of a bend in the road just to the north side of the M5 over bridge.

iii) At an existing gateway on the outside of a bend some 250m to the west of the M5 over bridge on the north side.

4.6.9.112 The road width at all three proposed temporary access positions is between 6.5 - 6.8m.

4.6.9.113 The visibility available at the three proposed access points is considered to be acceptable.

4.6.9.114 The provision of appropriate advanced warning signage of the access points on the public highway is essential.

UNDERGROUND ROUTE - W ROUTE BM11 & 12 Sheepway

4.6.9.115 It is proposed to create two temporary access points onto Sheepway (class C highway) as follows:-




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i) To the south side of Sheepway on a straight section of in the road approximately 185m to the west of the bridge over the disused railway line at the location of an existing gateway.

ii) To the north side of Sheepway approximately 100m to the east of the bridge over the disused railway line at the existing off road public parking area. There is a bus stop to the east side of the proposed access. This will be required to be relocated whilst the works are in progress and replaced on completion of the scheme.

4.6.9.116 The visibility available at both of the proposed access points is considered to be acceptable.

4.6.9.117 The provision of appropriate advanced warning signage of the access points on the public highway is essential.

TOWER ROUTE - LD95 BM 01 Portbury Hundred

4.6.9.118 The access is located on the southern side of Portbury Hundred (A369) approximately 130m to the west of the Sheepway. It is proposed to create a temporary access to serve the proposed tower C-LD95.

4.6.9.119 Access: The A369 (class A highway) is a busy major distributor road that links Portishead with M5 junction 19. The section of the A369 adjacent to the proposed access carries some 27,000 vehicles per day.

4.6.9.120 The position of the proposed access is at an existing gateway on the outside of a long sweeping bend in the road.

4.6.9.121 The visibility available at the proposed access point is considered to be acceptable.

4.6.9.122 The character of the road at the proposed access point with its long sweeping bend lends itself to very high vehicle speeds. It is therefore considered that appropriate advanced warning signage of the access point onto the public highway is essential.

TOWER ROUTE - LD96 BM 01 Portbury Hundred

4.6.9.123 The access is located on the northern side of Portbury Hundred (A369) approximately 240m to the east of the Sheepway. It is proposed to create a temporary access to serve the proposed tower CLD96.

4.6.9.124 The comments as noted above for LD95 BM 01 in relation to A369 at this location are applicable for this proposed access point.

4.6.9.125 The proposed access is at an existing bellmouth gateway entrance on a straight section of the road. It is noted that the access will be used as left turn in and out. Confirmation is required that this is correct.

4.6.9.126 The visibility available at the proposed access point is considered to be acceptable.

4.6.9.127 The character of the road at the proposed access points with its straight road alignment lends itself to very high vehicle speeds. It is therefore considered that appropriate advanced warning signage of the access point onto the public highway is essential.

UNDERGROUND ROUTE - LD99 BM01 & 02 Wharf Lane

4.6.9.128 It is proposed to construct to access points onto Wharf Lane to form a crossing point for the haul road.




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4.6.9.129 The section of Wharf Lane where it is proposed to form the crossing is an unadopted unmade up lane that is used as a cycleway/footpath.

4.6.9.130 As the public use Wharf Lane it is considered that appropriate advanced warning signage of the access points onto the Lane and on the haul road approaches is essential.

TOWER ROUTE - BW37 R BM01 The Drove Portbury Docks

4.6.9.131 It is proposed to construct an access point onto The Drove an unadopted road that is within the boundary of land owned by The Bristol Port Company.


TOWER ROUTE W ROUTE BM 01.1 Hanham Way

4.6.9.133 It is proposed to form a temporary access onto Hanham Way (unclassified highway) just to the east of a bend in the road where the road becomes the Causeway at its junction with Parish Brook Road.

4.6.9.134 It is proposed to form the access arrangement over an existing attenuation pond, through a stone wall and across Watery lane (Class C highway) to access the field to the north.

4.6.9.135 The visibility available at the proposed access is considered to be sub-standard to the west side due to the close proximity of the tight bend in the road. Consideration could be given to repositioning the access slightly to the east at the mid point between the junctions of Rhyne View and Parish Brook Road. This would improve the visibility to the west and also provide an open area at the end of the existing headwall feature, removing the need to cover/pipe directly into the headwall arrangement.

4.6.9.136 Appropriate advanced warning signage of the access point on the public highway will be essential on all the approaches.

TOWER ROUTE W ROUTE BM 04.1 Washing pound Lane

4.6.9.137 It is proposed to create a temporary access point to the east side of Washing Pound Lane (class C highway) on a straight section in the road some 40m to the north of a sharp bend in the road over the Land Yeo. The visibility available at the proposed access is sub-standard.


4.6.9.139 As vehicle speeds will be low heading south from the junction with Clevedon Road (B3130) consideration is to be given to the possibility of relocating the access away from the blind bend towards the junction, this will increase the available visibility to the south.

TOWER ROUTE LD54 BM01A B3133 Kenn Road

4.6.9.140 The proposed temporary access is located on the west side of Kenn Road (B3133) a class B highway. The location of the access is on a fairly straight section of the road at the mid point between two tight bends in the road alignment that are approximately 130m to the north and south.




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4.6.9.141 The speed limit for this section of the road is 40 mph. The vehicle speeds are fairly low in the vicinity of the access due to the road alignment with the tight bends acting as speed reducing features.

4.6.9.142 The visibility available at the proposed access subject to the proposed vegetation clearance works indicated is considered to be reasonable.

4.6.9.143 Road Traffic Accidents: There has been 1 recorded accident (RTA) in the last 5 years on junction with the B3133 with Lamprey Road to the south that involved a vulnerable road user a cyclist and 3 RTA’s on the bend to the north fronting Hope Farm (2 slight and 1 serious) 2 involving motorcyclists.

4.6.9.144 There is longitudinal crack in the carriageway that runs along the west side of the carriageway across the proposed temporary access arrangement. This appears to be the result of subsidence along the embankment. The road gullies in the vicinity of the access are in poor condition.

4.6.9.145 It is considered that this proposed access arrangement should be the subject of a road safety audit.

Drawing No. 13/NG/0235

4.6.9.146 Caswell Hill is a steep sloping, narrow single track country lane that links the village of Portbury with the top of Naish Hill. It is considered that it would be inappropriate for the Lane to be used as a construction traffic route, due to the narrow width of the lane and lack of available passing places.

4.6.9.147 Consideration is to be given to using the haul road for construction traffic between BM08 on Cuckoo Lane and BM09 on Caswell Lane.

Drawing No. 13/HG/0234

4.6.9.148 The following roads are considered to be unsuitable for construction traffic due to restricted available road width, poor road alignment (tight bends), lack of suitable passing places and poor forward visibility at a number of junctions and bends:-

Nailsea Wall lane: To the east of the bend where there is an existing access to North Drove an unadopted unmade up lane;

Brockley Lane;

Chelvey Road; and

Netherwood Lane.

4.6.9.149 The following roads in Nailsea are also considered unsuitable for construction traffic due to the character of the roads with a combination of on street parking, narrow road widths, tight bends and sub-standard visibility.

Engine Lane;

North Street; and

Silver Street.

4.6.9.150 It is considered that using the above named roads for construction traffic to access the haul road would be prejudicial to highway safety. They are therefore considered not acceptable as a construction traffic route.

Alternative routes for consideration:-




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Access for construction traffic to the southern end of North Drove will be limited too/from the west only via Nailsea Wall;

The construction route to the northern end of the North Drove off Hanham Way from Clevedon Road (B3130) to be via Stock Way North – Stock Way South – Mizzymead Road – Queens Road – Hanham Way; and

Access for construction traffic to the proposed access off Engine Lane from Clevedon Road (B3130) will be via the route as noted in point 2 above to Queens Road then via Hannah More Road -Blackfriars Road to Engine Lane.

4.6.9.151 Manmoor Lane: The junction arrangement at the south end of Manmoor Lane where it joins with Nailsea Wall/Davis Lane is considered to be sub-standard for vehicles exiting onto Nailsea Wall. As a construction traffic route Manmoor Lane could only be used in a northerly direction.




4.6.9.153 Stock Lane (B3130):- There are sections of the Lane where stone boundary walls and buildings front directly on to the carriageway. A number of tight bends exist in the lane where Large Goods vehicles struggle to pass each other due to reduced road width and or buildings/walls fronting directly onto the carriageway.

4.6.9.154 There have been 13 recorded accidents (RTA’s) in the last 5 years on the 2.8km section of Stock Lane (B3133) immediately to the north of its junction with the A38 (1 Fatal, 1 serious and 11 slight).

4.6.9.155 Looking at the accident data 4 of the RTA’s involved Goods vehicles, 3 at bends in the road, the other involved a vulnerable road user a cyclist and a Large Goods vehicle (above 7.5 tonnes mgw), where the cyclist was injured against a boundary wall fronting onto the road due to a sudden movement by the lorry when overtaking the cyclist.

4.6.9.156 Other elements to consider in future discussions relating to construction routes are:

1. Pre-works condition surveys to be carried out jointly for all of the roads to be used for construction routes, including road structures inspection reports. Format and content to be agreed;

2. Pre-treatment/corrective work prior to the use of the construction access routes. Including minor localised highway improvement works to passing places, edge widening etc;

3. Safety Audits;

4. Monitoring the routes ‘wear and tear’. Cumulative traffic impacts;

5. Details of the construction traffic vehicle types, size and wheel loadings including specific details of the Lorries that will bring pre-fabricated steel T pylon sections on to the site;

6. TA to include proposed traffic movements on each section of the construction routes;




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7. In order to ensure that a safe and effective route is maintained in all weather conditions for all seasons consideration will need to be given to the following:

Routine sweeping of the public highway;

Temporary directional signage;

Signage and Traffic Management. Temporary signals; and

Hours of use (suitability of the routes in hours of darkness); and

8. Reinstatement works.

Existing Structures

4.6.9.157 A revised list of structures identified on the approaches to the proposed Access points within the boundary of North Somerset Council are set out in the table in Appendix B together with recommendations for further works.

4.6.10 South Gloucestershire Council construction access and routing

4.6.10.1 Although the scope of the works within SGC’s administrative boundary is small and definable (Aust –substation and 2 pylons) the details submitted to date have indicated that the following areas would need further attention:

Pylons Approaching Seabank

4.6.10.2 Whilst the pylons are within the SGC boundary, the access routes to them are within BCC’s administrative area; there is no objection to these access points.

Aust Sub Station

4.6.10.3 This site is constrained, as access is only via a single track lane that is also the only access point for residents on this lane or access to the adjacent agricultural land. Contrary to the other access points there has been inadequate information provided as to how the access to the site will be managed during the construction phase for the sub-station. This could lead to vehicles queuing on the approach to the Motorway Service Station adjacent to the A403/M48/B4461 roundabout which would be unsatisfactory and conflicts with recreational users of the footpaths and bridleways in the vicinity.

4.6.10.4 The proposed access road to the Aust substation also passes directly adjacent to the boundary of the Travellers’ site. Children may be at play outside the Traveller site, and the Travellers currently use the access track for parking and liaison will be necessary to ensure safe passage for all during what we understand may be a 20 month construction period. In addition mitigation measures including for example restricting access times need to be provided to protect the Travellers during construction. Continued consultation and engagement via South Gloucestershire’s liaison officer is recommended as proposals for access are developed.

4.6.10.5 Indirect impacts also need to be considered, including for example the proposed location of source materials used for construction of temporary access roads, pylons and sub-stations will need to be considered in relation to vehicle impact/routing. This could be a significant issue for South Gloucestershire given the proximity of various quarries within its boundary.




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4.6.10.6 SGC seek to ensure that an alternative access point is provided so that for the duration of the construction works at this location a one-way system could be implemented/and or other suitable access arrangements that would avoid the need for queuing in the vicinity of the Motorway Service Station access adjacent to the A403/M48/B4461 roundabout whilst maintaining safe access for recreational users of the footpaths and bridleways in the vicinity.

4.6.11 Bristol City Council construction access and routing 4.6.11.1 The report considers the Bristol area within Section G and corresponding drawings.

4.6.11.2 In relation to the description of the A403 St Andrew’s Road at 12.4.232, this is described as being dual carriageway. The road comprises two lanes in each direction but the carriageway is not dualled (e.g. directions segregated by physical means).

4.6.11.3 The documentation does not identify that the majority of Victoria Road (12.4.250) does not fall under the adoption of BCC Highways but lies within the ownership of the Port Authority. Whilst comments are provided below on the suitability of temporary access from this location it is recommended that contact is made with the Port Authority to acquire their views on the principle of new access from this location.

4.6.11.4 The baseline assessment of various routes in the Bristol area includes the A4, West Town Road, Victoria Road, King Road, St Andrew’s Road and Kings Weston Lane, although there is no commentary on a number of other affected routes including Avonmouth Way, Packgate Lane, Moorhouse Lane and Ableton Lane. With regard to the latter, it should be noted that whilst the proposed temporary bellmouths from Ableton Lane access cables situated within fields located in South Gloucestershire (drawing refs: 124 and 127), Ableton Lane itself in this location actually falls under the adoption of BCC who are happy to share adoption plans with the project team to illustrate this.

4.6.11.5 In relation to the additional effects of the construction period, BCC would expect National Grid to be responsible for auditing the current condition of PRoW and cycle routes in the Bristol area within the TA. This should also confirm the level of impact upon these routes (e.g. whether closures, diversions and / or stopping-up is being considered) in addition to the timescales for this disruption. A suitable timeline accompanied by a plan would be helpful in illustrating this.

4.6.11.6 A further issue for consideration in the BCC area relates to the redevelopment of the Seabank Power Station. Whilst this is considered in Table 12.26, BCC are not confident that this is being properly investigated from either side in terms of cumulative impacts and it is urged that more detailed liaison is carried out.

4.6.11.7 These comments below are made on the basis of the following drawings highlighted in bold which have been submitted to Bristol City Council (issued 16-09-2013)

MMD-322069-C-DR-GEN-XX-0310 Temporary Construction & Major Access

4.6.11.8 The above drawing confirms the proposed temporary access points and the associated construction routing plan associated with the project. This drawing however would benefit from some clarity in relation to the associated ownership / adoption of highway in this area. For example, the identified county / district




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boundaries to the north of the drawing differ from BCC’s understanding of the boundary with South Gloucestershire, which according to records is to the north east of Ableton Lane. This means that the all accesses shown on this plan are located within the BCC area.

MMD-322069-C-DR-CLD107-XX-0200 Victoria Road

4.6.11.9 According to BCC’s records, the above temporary access is proposed from a section of road not adopted BCC Highways but instead falling under the control of the Port Authority. Whilst comments are provided below in relation to the suitability of the access, it is strongly recommended that dialogue is undertaken with the relevant property team in order to secure agreement for the construction of this access.

4.6.11.10 In relation to the suitability of the access, it is noted that this stretch of road is subject to a 20mph speed limit. Whilst the drawing makes reference to this limit being enforced by the Port Authority, from visiting the site, it is clear that there is no convincing evidence that a 20mph design speed is appropriate in this instance.

4.6.11.11 Together with the lack of visible speed enforcement, the straight alignment and width of the route combined with the lack of any physical measures to retain speeds to below 20mph, it is difficult to see how a 70m y-distance can be considered acceptable, given the nature of the road and the speeds that were observed. The extent of visibility therefore requires to be rethought and it is suggested that the drawings are revised in the context of a 50mph design speed.

MMD-322069-C-DR-GRoute-XX-0200 Avonmouth Way

4.6.11.12 The above access is proposed off an existing industrial estate road which is subject to a considerable amount of on-street parking. The access proposals do not seem to have taken this into account and it is likely that some form of temporary Traffic Regulation Order (TRO) will be necessary to ensure that the access can be kept free of parked vehicles at all times.

4.6.11.13 In relation to parking demand, very little information is provided on this drawing (and others) in connection with the requirements for and the traffic and parking demand associated with the site compounds. Therefore, it is difficult to confirm whether or not BCC agrees that the site compounds are of an appropriate size and scale to accommodate the demand for parking to ensure that there are no adverse effects on the public highway.

4.6.11.14 The proposed visibility splays would appear to be appropriate although BCC require confirmation that ATC speed data has been collected to inform this.

4.6.11.15 Further clarification is also sought on the drawing in relation to the location of lighting columns which is not currently clear.

MMD-322069-C-DR-GRoute-XX-0201 Avonmouth Way

4.6.11.16 The above access is formed to provide a 215m visibility splay to the west. In view of the 60mph design speed and the sightlines provided for the access above it is therefore again queried from what level of detail / assessment the visibility splays have been formulated.




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4.6.11.17 A footpath is located at the end of Avonmouth Way which links through to Kings Weston Lane and it will be required that the use of this route is kept clear and free from obstruction at all times.

MMD-322069-C-DR-GRoute-XX-0202 Kings Weston Lane

4.6.11.18 The construction route proposes to cross Kings Weston Lane a short distance to the north of where Avonmouth Way finishes, continuing the route from the previous access. There are a number of levels, drainage and vegetation issues to overcome to achieve this access and this design will be required to be subject to further detailed scrutiny in terms of its construction.

4.6.11.19 Further to the above and in relation to visibility, the rationale for the sightlines shown are again unclear, particularly in relation to the provision of 50m and 120m sightlines along a road that is subject to the national speed limit (60mph). The nature of Kings Weston Lane in this location, which for the most part of the day is fairly isolated, encourages high speeds, particularly where it sweeps over the M49 bridge which itself generates a blind summit to the south of the proposed access. Further discussion is required in relation to this access.

MMD-322069-C-DR-CLD119-XX-0200 Packgate Road

4.6.11.20 The above access is located from relatively new highway infrastructure and as such it is likely that the required sightlines associated with a 40mph design speed will be achievable, given that the accesses are located on the outside of a bend. It will however be necessary to either safeguard or divert the course of PROW BCC/4/10 which is situated between the proposed two temporary access points.

MMD-322069-C-DR-CLD121-XX-0200 Severn Road

4.6.11.21 Similarly to Kings Weston Lane there are a number of visibility and vegetation issues to overcome to achieve this access and this design will be required to be subject to further detailed scrutiny in terms of ensuring an adequate visibility splay in each direction. The rationale for these sightlines is again unclear, on this occasion suggesting 180m and 150m y-distances. It is assumed that this may be in some part due to the blind summit caused by the bridge over the motorway to the south of the access.

4.6.11.22 The impact upon and continued use of BCC PROWs 556/20, 555/30 and 555/40 will also require consideration.

MMD-322069-C-DR-S-Bank-XX-0200 Severn Road

4.6.11.23 The above access has numerous constraints owing to the geometry of the road in this location, the extent of vegetation and also in relation to levels. As previously, further detailed scrutiny will be required in order to ensure this access is achievable in relation to visibility and physical construction.

4.6.11.24 Of particular interest will be the disruption caused to the Sustrans cycle route for which the access proposes to use to access the power lines to the north of this access and how this will operate during the construction period.

MMD-322069-C-DR-CLD124 Ableton Lane




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4.6.11.25 As discussed earlier the above accesses are also being considered by South Gloucestershire Council, although the extent of adopted Bristol highway includes the lengths of Ableton Lane onto which the above proposed accesses will be taken from.

4.6.11.26 BCC are less concerned in relation to the visibility splays associated with drawing CLD127 as Ableton Lane in this location is unlikely to exhibit the speeds considered in view of its nature, which is more of a farm access track. What is more concerning will be the ability for the lane to withstand the passage of large vehicles along this route and the need to ensure adequate drainage.

4.6.11.27 Drawing no CLD124 also encounters issues regarding drainage although its positioning on the outside of a bend aids visibility in both directions. A sightline of 70m is therefore considered appropriate on this occasion, subject to justification on the basis of the relevant speed surveys.

4.6.11.28 The following drawings have also been considered in relation to understanding further context of the proposals in relation to the Bristol area.

13/NG/0126 – G/WP/PS/3-7 Works Plans (in. Victoria Road)

13/NG/0136-G/AR/PS/3-7 Access / Rights of Way Plans

4.6.11.29 The above drawings provide further information, although it is a little frustrating that they show further proposed access points that are not considered in the drawings above, but are connected with the decommissioning of the 132kW power lines.

4.6.11.30 In addition, the details shown on these drawings such as PRoW are not included in the access drawings, which has necessitated considerable cross-referencing between drawings of differing scales.

4.6.11.31 These issues are summarised below in relation to the BCC area:

Further additional access points from Portway, Portview Road, West Town Lane, Victoria Road, Third Way, Second Way, Moorhouse Lane – many of which are taken from BCC highway but continue through private land.

Unclear access proposals for the removal of the 132kW lines

4.6.11.32 The above will need to be clarified in due course, as well as the traffic that is generated by the removal of the 132kW cables if this is additional.

4.6.12 Impact assessment 4.6.12.1 Tables 12.18 to 12.25 include predicted construction vehicle flows across each

section. A detailed methodology is required to explain how these figures have been derived. The construction vehicle flows should present a worst case scenario and will provide the upper limits of any conditions that are implemented.

4.6.12.2 Woolavington Hill located within the District of Sedgemoor (paragraph 12.4.20) is classified as being of high sensitivity due to schools, places of worship and dwellings close to the route. The Joint Councils acknowledge the sensitive nature of this link. Specific analysis is required of the effect on pedestrian and cycle routes between sensitive receptors in this section, and mitigation should be proposed.




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4.6.12.3 In addition, and in relation to Woolavington Hill (Table 12.5), the 24hr HGV flow is stated as “1,11”, whereas 18hr HGV flow is 1,073. This is considered to be a possible typographical error.

4.6.12.4 Impact assessment on the PRoW network is considered to be underestimated. It is accepted by National Grid that there will be an impact on the PRoW network despite some of the path forming part of a promoted route and by National Grid’s own admission providing key links between settlements, no disruption to a path and impacts associated with this is regarding as having more than a moderately adverse impact. There is no cumulative effect considered for the rights of way in the vicinity of the Hinkley line entries, which is an area already subject to a significant reduction in the number of PRoW closed due to the DCO for HPC. Further interference or reduction in use of paths in this area will impact on local users and the alternative path which is in place for the West Somerset Coast Path (closed in the vicinity of Hinkley Point). Users will be affected by disruption, noise, dust and the impact on peace and tranquillity.

4.6.12.5 In respect of cumulative impact, National Grid should consider the potential impact of the Bristol Port Company scheme proposal which will see parts of the network closed in the later part of the 2010’s. National Grid should consider the cumulative impact of HGV movements associated on the proposed development with Hinkley Point C and the Bristol Port Company scheme especially in relation to the C182 and the local network crossing Wick Moor.

4.6.13 Mitigation 4.6.13.1 Further detail is required of measures to reduce the impact of construction traffic on

walking and cycling routes.

4.6.13.2 It is stated at paragraph 12.4.27, 12.4.75, 12.4.179, and 12.4.222 that PRoW affected by construction traffic will “undergo management”. Clarification is requested on the character and extent of this management.

4.6.13.3 National Grid need to provide a TMP and CMP for consultation prior to submission of the DCO. These then need to be agreed with the Joint Councils to ensure that the proposed development impacts are managed.

4.6.13.4 Driver training schemes should be implemented for all HGV drivers to enhance safety and this should form part of the CMP.

4.6.13.5 It is noted that until there is a full TA, the Joint Councils cannot assess either the full environmental effects of the project in highway terms, or the adequacy of the mitigation.

4.6.13.6 It is understand that the highway works are to be undertaken having regard to Articles within the DCO. One of these articles makes particular reference to the street authority and the undertaker entering into agreements. At this consultation stage the developer should be made aware that SCC (as street authority) fully expect to enter into individual legal agreements for the many elements of work on the highway. Where practical individual schemes or elements may be combined however it is anticipated that the legal agreements will take the general form of an agreement as if it were made using Section 278 of the Highways Act, albeit that SCC acknowledges that the phrasing of some clauses will need to differ to reflect the specific DCO requirements.




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4.6.13.7 In relation to PRoW National Grid has provided very limited details in relation to mitigation. It is stated in the chapter at paragraph 12.4.27, 12.4.75, 12.4.179, and 12.4.222 that PRoW affected by construction traffic will “undergo management”. Clarification is requested on the character and extent of this management.

4.6.13.8 The chapter does detail that PRoW will be affected and closures and diversions would need to be put in place (seeparagraph12.5.90), however the mitigation section of the chapter does not make any detailed reference to mitigation proposals for the impact on PRoW.

4.6.13.9 Although not discussed within the mitigation section, reference is made to a Footpath Implementation Plan in the overall chapter text, however no detail is provided in respect of this and no discussions have taken place to date with the Councils in respect of the proposed content. It is advised that the proposed title for the implementation plan should be amended to “Rights of Way Implementation Plan” to be more inclusive. Please see comments on the Socio-Economic chapter for further details in relation to proposed mitigation for PRoW.

4.6.13.10 Proposals to avoid disturbance and disruption as well as the safety of residents directly adjacent to the access points must also be provided, including for example for the Traveller community adjacent to the access track at Aust.




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4.7 Air Quality and Emissions 4.7.1.1 This section reviews Document 2.5, Chapter 13 (Air Quality and Emissions) of the

PEIR.

4.7.2 Topic Summary 4.7.2.1 The air quality assessment methodology applied is considered appropriate to the

nature of the scheme and is consistent with that presented at scoping. However not all comments on the scoping report have been addressed, for example the Joint Councils recommended that proposed mitigation measures should be based upon the latest Institute of Air Quality Management (IAQM) guidance rather than the Greater London Authority (GLA) approach13. The mitigation presented in the PEIR is based on the GLA approach and should be updated prior to submission of the DCO and incorporated into the CEMP in accordance with the requirements of EN-1.

4.7.2.2 Baseline air quality information is considered to require updating prior to formal submission of the DCO material, to include the full scope of pollutants assessed and up to date background air quality data.

4.7.2.3 The impact assessment has been based upon the latest best practice guidance and is applicable to this assessment. However, the impact of temporary construction compounds is not explicitly referenced and this is considered to be an omission. The inclusion of assessment material relating to SF6 is welcomed.

4.7.2.4 The air quality material has adequately assessed the potential impacts upon sensitive receptors during the construction and demolition phase. However, the material currently lacks an assessment of traffic during the construction and operational phase of the project, which will need to be submitted as part of the formal DCO submission. The lack of a construction traffic assessment means that under National Grid's proposed programme there will be no formal opportunity to comment on the impact of construction traffic prior to submission of the formal DCO. National Grid should consider the provision of this information during further structured engagement.


4.7.3.1 It is considered that the consultation material supplied requires further detail in respect of traffic emissions from the construction and operational phase. The assessment states that traffic data is outstanding and that AADT24, %HDV and vehicle speeds are still being gathered in order to finalise the traffic impacts section. It should be noted that the content and use of traffic data sets have not been agreed with the Highway Authorities. It is therefore not possible to comment on the adequacy of assessments of transport related emissions at present.

13 http://static.london.gov.uk/mayor/environment/air_quality/docs/construction-dust-bpg.pdf




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4.7.4 Methodology 4.7.4.1 The adopted EIA methodology at paragraph 13.3 is in accordance with the

principles set out in the National Grid Scoping Report. Should the traffic impacts become significant when all data is available the methodology describing how emissions from construction traffic have been assessed will need to be included.

4.7.5 Baseline 4.7.5.1 Baseline data collected to provide a summary of air quality relating to each of the

Councils administrative areas is not based on the most up to date information. This potentially reflects the lack of liaison between National Grid and the local Environmental Health Teams to ensure that the most recent data is collected and assessed.

4.7.5.2 Certain pollutants are not accounted for in the text. For example, NO2 is mentioned for all Council areas but PM10 is not accounted for in West Somerset, Sedgemoor, North Somerset or South Gloucestershire. This is considered to be an omission.

4.7.5.3 The UK-Air website is quoted as the source of background air quality information. The LAQM website now holds the UK background maps14. National Grid should set out the version of the background maps that has been used in this assessment. The year taken for the baseline background maps should also be stated. The formal DCO submission should be based on the latest version of mapping.

4.7.6 Impact assessment 4.7.6.1 A conservative approach has been adopted with respect to the impact assessment

for construction and demolition dust, which is deemed appropriate. However the material currently lacks specific reference to the impact of temporary construction compounds.

4.7.6.2 The lack of a construction traffic assessment means that there will be no formal opportunity to comment on the impact of construction traffic prior to submission of the formal DCO.

4.7.6.3 The inclusion of assessment material relating to SF6 is welcomed.

4.7.7 Mitigation 4.7.7.1 The Joint Councils’ Scoping Response requested that National Grid take into

account the latest IAQM mitigation methods for construction dust. This has not been addressed in the PEIR and references to the old Greater London Authority mitigation methods are still included. Although this will not have a significant impact on the conclusions of the assessment, it is expected that this would be updated to reflect latest best practice guidance prior to the DCO submission.

4.7.7.2 Fundamentally, due to lack of a traffic impact assessment it is not possible to comment on the scope of effects and mitigation measures that may be required in relation to the scheme.

14 http://laqm.defra.gov.uk/review-and-assessment/tools/background-maps.html




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4.7.7.3 Subject to the outcome of any traffic impact assessment and the inclusion of emissions other than dust within the proposed Construction Environmental Management Plan (DCO Schedule 2 Requirement 11) no further mitigation is identified at this stage.




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4.8 Noise and Vibration 4.8.1.1 This section reviews Document 2.5, Chapter 14 (Noise and Vibration) of the PEIR. It

also considers the Document 5.1 Pylon Options Report.

4.8.2 Topic summary 4.8.2.1 The level of detail of assessment and supporting information is considered broadly

adequate for a PEIR level assessment, although further clarification is required regarding noise generated by the T pylon during wet weather, which is touched upon in the Pylon Options Report.

4.8.2.2 The methodology is comprehensive in setting out the approach to the study and stating the limitations for a PEIR (e.g. limited baseline noise survey data). Issues raised in the Joint Councils’ Scoping Response as omissions from the assessment have now been mostly included. However, no study area extent is given for construction vibration. Vibration from the proposed construction works is not considered to be a likely significant cause of disturbance, but a rationale to define a suitable assessment cut-off distance would make it clearer as to where effects could be scoped out.

4.8.2.3 The assessment criteria described for construction noise in the methodology does not seem to align with the approach that is then described in the assessment text. This should be clarified as the method used to define the assessment thresholds appears to be ambiguous.

4.8.2.4 The impact assessment is systematic in applying the selected assessment criteria to evaluate construction and operational effects. There is a minor anomaly concerning the assessment of construction traffic vibration. Although this should be clarified for later assessment stages, it does not affect the result of the PEIR. The locations of noise effects are identified and the magnitudes quantified.

4.8.2.5 Whilst mitigation for substations is considered to be appropriate, construction mitigation measures do not currently address the impact of temporary construction compounds and haul road infrastructure and are not informed by a TA, therefore it is not possible at this stage to draw firm conclusions in relation to the appropriateness of mitigation measures relating to this aspect of the proposals.


4.8.3.1 Anecdotal evidence from consultation meetings suggests that the T pylon may generate more noise during wet conditions than a lattice pylon. Further information in addition to the Pylon Options Report should be supplied by National Grid to the Joint Councils prior to submission of DCO application in order to clarify this issue.

4.8.4 Methodology 4.8.4.1 Most issues raised in the Joint Councils’ Scoping Response have been addressed.

In particular, the potential for noise from breaking pylon foundation material as part of the removal of existing lines has now been included in the assessment.




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4.8.4.2 Minor issue: Construction vibration assessment criteria are presented in Table 14.2, but there does not appear to be any study area defined for vibration effects specifically. Paragraph 14.2.30 notes that construction noise will be considered at distances up to 150m, however, no study area extent is given for vibration. Whilst it is unlikely that vibration will give rise to significant effects, it was suggested in the Joint Councils’ Scoping Response that some cut-off distance might be proposed beyond which the risk of vibration disturbance is scoped out.

4.8.4.3 North Somerset Council had raised concerns in the Joint Councils’ Scoping Response regarding plant noise criteria. A plant noise criterion has been adopted whereby rating noise will not exceed background noise (according to BS 4142 assessment principles). This is 5dB below the threshold at which introduced plant noise would be of ‘marginal significance’ according to BS 4142 and would therefore address this concern.

4.8.4.4 Minor issue: Paragraph 14.4.21 refers to the construction noise assessment criteria given in BS 5228. This is generally described as the ‘5dB change’ method (BS 5228 Section E3.3). This does not align with the use of ‘ABC’ noise thresholds in Table 14.5 which are for use with the alternative ‘ABC method’ given in Section E3.2 of the Standard.

4.8.4.5 Recommendation: It should be clarified which assessment approach has been adopted as the method used to define the assessment thresholds appears to be ambiguous. It is assumed that the ABC method has been followed for the assessment, as the most conservative threshold ‘Category A’ has been described in Paragraph 14.2.37 (assessment). If so, the correct determination of the assessment category (according to BS 5228) is not as it is explained in the methodology.

4.8.5 Baseline 4.8.5.1 Limited baseline noise measurements have been made for the PEIR and therefore

the assessment compares predicted noise levels against the most conservative assessment thresholds (i.e. ‘Category A’). This reflects the generally low ambient noise levels and this approach is considered acceptable for a PEIR. In some cases the assessment may be onerous as a higher assessment threshold would be appropriate where ambient noise levels are greater than those assumed. As mentioned above, the National Grid methodology does not reflect that the ABC assessment criteria have been used, and seems to refer to the ‘5dBA change’ method instead.

4.8.5.2 Baseline information concerning the proposed scheme alignment and locations of surrounding noise sensitive receptors has been based on relevant mapping. This is considered adequate for the purpose of the PEIR.

4.8.5.3 With regard to new development which could be potentially sensitive to noise from the scheme, Paragraph 14.6.2 notes that that there are no planning applications within a distance where there could be effects. Therefore the receptors established for the baseline are comprehensive in terms of the effects of the scheme in the future.




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4.8.6 Impact assessment 4.8.6.1 The assessment of construction impacts is based upon noise threshold levels and is

reported consistently against the selected criteria.

4.8.6.2 Construction noise effects are assessed as negligible. Construction traffic noise effects are assessed as low magnitude at the following locations:

B3141 Woolavington Hill (Sedgemoor District);

Caswell Hill, east of Portishead (North Somerset); and

Whitewick Lane, east of Wick (West Somerset).

4.8.6.3 It is noted that the air quality assessment states that traffic data is outstanding and that AADT24, %HDV and vehicle speeds are still being gathered in order to finalise the traffic impacts section. In the absence of a TA and CTMP the likely routing of construction traffic is also unclear. It is therefore unclear what the basis is for the traffic flow change data from which the assessment of a low magnitude construction traffic noise impact has been made (Table 14.7).

4.8.6.4 Minor issue: Paragraph 14.2.42 reports that vibration is proportional to noise generated and effects will be similar to those assessed for noise. This is true of airborne vibration specifically and not groundborne vibration. Paragraph A6.21 of DMRB15 (Volume 11, Section 3, Part 7) states:

A6.21 The relationship between the percentage of people bothered by largely airborne vibration and this noise exposure index is similar to that for noise nuisance except that the percentage of people bothered by vibration is lower at all exposure levels.

4.8.6.5 However, as noted in earlier in Paragraph 14.2.42, the generation of groundborne vibration is related to the quality of the road surface. It is not expected that there would be any groundborne vibration associated with haul roads or traffic associated with the scheme using public highways.

4.8.6.6 For operational noise, the impact criteria are related to established BS 4142 criteria and have been reported systematically for each receptor subject to impacts.

4.8.6.7 The PEIR assessment indicates that there may be a medium operational effect due to overhead line noise at two locations Court Farm and the public house in Stone-edge Batch (North Somerset). This is based upon worst-case assumptions.

4.8.6.8 Prior to mitigation, high effect levels are reported for receptors close to Sandford Substation for (Droveway Farm, Droveway Cottage and Mead Farm)(North Somerset).

4.8.7 Mitigation 4.8.7.1 In absence of a TA submission, the status of the traffic noise impact assessment

and therefore the extent of mitigation proposed is questioned.

15 The Highways Agency, TRANSPORT SCOTLAND, WELSH ASSEMBLY, drd (2011), Design Manual for Roads and Bridges Volume 11, Section 3, Part 7,HD 213/11 – Revision 1, TSO




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4.8.7.2 A CEMP, as proposed in DCO Schedule 2 Requirement 11, is considered to be an appropriate mechanism for the control of construction noise and vibration mitigation. At present a CEMP has not been provided, therefore the efficacy of the mitigation proposals cannot confirmed. A draft CEMP should be provided to the Joint Councils in advance of the submission for Development Consent for consultation, to enable the Joint Councils to achieve a higher level of agreement in the Statement of Common Ground.

4.8.7.3 The lack of clarity regarding the duration and use of temporary construction compounds and haul roads means that further mitigation may be required in relation to these aspects of the proposals.

4.8.7.4 Mitigation has been recommended for the substations in the form of acoustic enclosures. Following mitigation, the only residual effects are those assessed for overhead lines. No further mitigation is practicable to reduce overhead line noise. Therefore unmitigated impacts remain, which could be offset by contributions to other amenity improvements within the local area.

4.8.7.5 It is considered that the cumulative impact on amenity of various forms of disturbance (e.g. relating to construction noise and traffic) could give rise to significant effects that require additional mitigation.




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4.9 Socio-Economics and Land Use 4.9.1.1 This section responds to Document 2.5, Chapter 15 Socio-Economics and Land Use

chapter (including PRoW) of the PEIR. It also considers Appendix 5B and the draft DCO. The socio-economic assessment stream includes consideration of tourism impacts.

4.9.2 Topic summary 4.9.2.1 There is a considerable amount of further socio-economic assessment work

(particularly with regards to business surveys, tourist survey analysis and PRoW counts) to be carried out (p.174 - outstanding information) in order to assess impacts arising from the proposed route alignment, as outlined in NPS EN-1.

4.9.2.2 The methodology broadly follows the principles set out in National Grid’s Scoping Report. However, it is noted that a number of concerns highlighted in the Joint Councils’ Scoping Response have not been addressed in the PEIR. These include the following key concerns:

There is a lack of information about the way in which tourism impacts are to be assessed (noting that the Secretary of State’s scoping opinion, published on 4th September 2013, advised the applicant to “ensure that their qualitative assessment is based on strong evidence which itself should be quantitative wherever possible” (p.21);

It is not clear whether effects on land holdings of the underground section of the route will be addressed; and

The methodology for assessment of cumulative impacts (particularly on tourism) is still weak.

4.9.2.3 The methodological approach to the primary business survey is questioned, in particular whether it has been conducted in a manner that all potentially impacted firms have been contacted, that firms from the right mix of sectors have been included in the sample and that the questions asked to ascertain significant factors in location decisions, have been covered.

4.9.2.4 The impact assessment follows the methodology set out though the conclusions of the impact assessments are often unclear.

4.9.2.5 The proposed mitigation measures are presented as a definitive list. Given the further assessment work to be carried out on a number of aspects of the assessment (p/174 – outstanding information), it is considered that further mitigation measures may be identified following the additional assessment work, and as such it would be expected that the mitigation would be expanded upon in the ES and provided as part of structured engagement prior to a formal application for Development Consent.


4.9.3.1 In addition to the comments provided below specific to the content of the PEIR as published, there is a considerable amount of further assessment work (particularly




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with regards to PRoWs and tourism) to be carried out (p.174 - outstanding information) on a number of aspects of the environmental assessment. The Councils consider that further issues (and therefore necessary mitigation measures) may be identified following this further assessment work.

4.9.3.2 In relation to PRoW, little information has been provided in respect of what constitutes “path management”, what timescale relates to “closures of short duration” and the impact on PRoWs that are proposed to be used and crossed by construction access routes. In addition, little detail has been provided in respect of alternative routes for those paths, which are to be closed for the duration of the construction works. Much greater detail will therefore be required in the forthcoming ES. See also comments relating to PRoWs in the Landscape and Visual Effects and Traffic and Transport sections of this report.

4.9.4 Methodology 4.9.4.1 The adopted EIA methodology approach broadly follows the principles set out in the

Scoping Report. A key concern raised in the Joint Councils' Scoping Response (paragraph 11.1) stated that: ‘the Scoping Report contains only limited information regarding the approach to assessment of effects on land holdings for the undergrounding section of the route and further methodological detail is required.’ This has not been explicitly addressed in the methodology section of the PEIR. The Councils would expect this to be clarified in the ES.

4.9.4.2 Concerns remain about both the geographical coverage and the content of the primary business survey. This is critical to understand a number of central elements to the socio-economic assessment. It should give an indication of how existing businesses expect to be impacted by the proposed route alignment, how the relocation decisions of future potential businesses might be affected, and the likely tourism impacts. Whilst it is acknowledged that additional survey work is being undertaken for purposes of the ES, it is unclear why all 487 businesses identified as being within the 2km corridor have not been surveyed. The sector definition applied may exclude relevant firms; for example, creative industries, where a high quality natural environment can be an important consideration in the locational preference of businesses or industrial businesses of the type which might be current or future tenants of the Avonmouth and Severnside Enterprise Areas. The business surveys should ensure that these types of firms are included in the scope of the research. A request raised at a socio-economic topic meeting in June 2013 that draft survey questions be circulated for comment was not granted. As a result, concerns remain about whether the questions asked of respondents are sufficient to assess (or rule out) the types of impacts which are harder to pinpoint through desk review.

4.9.4.3 The business survey information included in the PEIR does not include questions relating to location decisions. It is considered that this information is necessary to provide useful contextual information for qualitatively assessing the magnitude of impact of reduced visual amenity on business location preferences when the scheme is operational.

4.9.4.4 The PEIR does not present full survey results. It is hoped that these would be include in full in the ES to allow a broad reading of results and avoid the appearance of ‘cherry picking’ key findings.




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4.9.4.5 It is noted that the methodology does not make clear whether committed development that would be completed by the construction and operational phase of the proposed development is included within the future baseline as part of the assessment methodology.

4.9.4.6 There is a lack of clarity in the significance criteria set out in the methodology. The magnitude categories set out in Table 15.4 does not make clear the distinctions between categories. It is noted that Table 13.6 of the Scoping Report entitled ‘Definitions of Significance’ has not been included in the PEIR. National Grid should confirm the significance ratings in the ES.

4.9.5 Baseline 4.9.5.1 The ES submitted with the DCO would benefit from a short explanation of why the

relevant indicators have been selected before setting out the baseline conditions for the assessment. In reviewing the baseline information the following observations are made:

Baseline and survey data pertaining to businesses should be presented in such a way that it is clear where the businesses are located (for example, on a plan);

Paragraph15.3.3: - there is an error in the text where it states ‘with primary industries … accounting for 1/3 of regional Gross Value Added income. This should read ‘1.3%’ rather than ‘1/3’;

Paragraph15.3.13: - the proportion of residents with no qualifications in England reported in the text differs from that presented in Table 15.8;

Paragraphs 15.3.16 - 15.3.18: - Super Output Area (SOA) data is discussed in the text but not presented in a table;

Table 15.9: - the data contained within this table is not discussed in the text;

Table 15.16: - it is unclear why data is provided for the surrounding 5km when the Wider Study Area, as defined in paragraph 15.2.10, is defined as: ‘a corridor of approximately 2 kilometres (km) around the proposed route’;

Paragraph 15.3.64:- the findings presented here are difficult to understand given the lack of information relating to which PRoWs were surveyed, upon which day of the week they were surveyed, and the substantial amount of survey work still to be carried out;

Paragraph 15.3.66:- there is no reasoning/explanation for the selection of PRoW locations for User Surveys;

Table 15.27: - this table appears to include an error as final row. The final row is labelled ‘King’s Sedgemoor Drain near Peasey Farm’ (a duplication of the first row), this appears to include the ‘total’ figures for the table;

Appendix 12: There remain a few inaccuracies in relation to path numbers. Accurate details should be sought from the Councils;

PRoW condition surveys are to be submitted as part of the ES. Inter-relationships of potential effects on amenity (e.g. changes to views, noise, etc) and additional commentary should be included within the ES once all PRoWs have been surveyed; and




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Changes to the key and map are required for Figure 15.4.1. The following information should be included:

●●●● Proposed England Coast Path National Trail (east of River Parrett); and

●●●● Proposed England Coast Path National Trail and River Parrett Trail.

Changes to key and map are required for Figure 15.4.9. The following information should be included:

●●●● Proposed England Coast Path National Trail and West Somerset Coast Path

4.9.5.2 Overall, the baseline section would benefit from greater consistency in the presentation of data. In particular, discrepancies between the presentation of data in tables and how it is reported on within the text should be avoided. The observations as highlighted above undermine the findings emerging from the baseline analysis.

4.9.6 Impact assessment 4.9.6.1 The approach to the impact assessment does appear to follow the methodology set

out (noting the deficiencies in the method set out above), however the conclusions of the impact assessments are often unclear. We would expect the conclusions and how they have been classified to be clarified in more detail within the ES.

4.9.6.2 With regards to the assessment of the significance of the potential effects, the Councils would make the following observations:

Paragraph 15.4.1 states: ‘The eventual choice of pylon configuration will not make a significant difference to assessment of potential effects from the Proposed Development to socio-economic features and existing and future land uses.’ Whilst the Councils acknowledge the potential benefit of the T pylon design to reduce visual impact due to its reduced height and therefore greater screening potential, the T pylon design cannot be considered to mitigate all impacts associated with the proposed route alignment;

Paragraphs 15.4.18 – 15.4.23: given the methodological concerns previously raised regarding the content and coverage of the Business Survey, it is considered that the findings from this survey need to be based on an adequate sample upon which to report any representative, robust and meaningful findings of effects on local businesses, on the ability of the area to attract investment in future, or on the tourism sector;

Paragraph 15.4.22: this paragraph notes the most common negative response related to ‘traffic and potential disruption on roads’. The impacts of construction traffic are covered in little detail in the assessment and we would expect this to be covered in more detail in the ES, particularly in terms of longer term reputational effects on tourism in the region, and particularly related to the cumulative effect of this disruption with construction traffic associated with Hinkley C and other significant local projects. It is understood that visitor survey respondents were given a brief description of the scheme before being asked how they thought it might impact on their future perceptions and holiday plans, but it is less clear what information was provided and whether respondents




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would have understood, for example, potential traffic congestion implications during the construction period, particularly when considered cumulatively with other developments. It may be appropriate to carry out visitor surveys specifically on the impact of traffic on their perceptions and future holiday plans to establish the scale of likely impact when the traffic assessment is complete and accurate estimates can be provided to survey respondents. Note that as part of the Environmental Assessment for the Hinkley Point C application some bespoke research was commissioned, which included a tourist survey to assist in assessing the likely impact of the development on tourism.16 1,410 tourist visitors participated in a survey, the results of which were used to model the likely impact of that development on tourism in Somerset. National Grid should review this research for transferability of findings and as a minimum cumulatively assess these impacts. In addition, the method for understanding the impact of the proposed route alignment on tourists should be addressed in more detail; and

Paragraph 15.4.25: the text notes that one directly affected business may relocate and it is concluded: ‘this could avoid the employment loss’. However, it is not made clear whether the business plans to relocate within the study area. This should be clarified in order to support the conclusion made. Whilst the business in question will be compensated to the extent that their loss will be considered mitigated, the extent to which there may be wider employment or supply chain considerations of this relocation these should be made explicit.

4.9.6.3 Paragraph 15.4.35: the text states that the proposed development ‘could have direct effects on eight Planning Allocations’. However, nine planning allocations are subsequently listed in table 15.32. In the baseline section the Royal Ordnance Factory at Puriton is identified as a key planning allocation (alongside the Avonmouth and Severnside Enterprise Area) as: 'of interest for the socio economic and land use assessment' (paragraph 15.3.53). However, the effect on this planning allocation is not assessed in Table 15.32. Full assessment of any potential impacts on the Huntspill Energy Park site should be included in the ES accompanying the application for Development Consent.

4.9.6.4 Table 15.32: with regard to the Avonmouth and Severnside Enterprise Area, the PEIR text concludes ‘the Proposed Development should not prevent these areas from coming forward for development; however the type of land developed within the direct route corridor may be limited to a compatible land use, such as roads, car parking and landscaping’. It ranks the area as both low sensitivity and low significance. Whilst this is an area of industrial land use and therefore likely to be less sensitive to the visual impact of overhead lines, it is a site of strategic economic importance to the West of England; considered to be one of the region’s key employment drivers. The impact of any constraints on development represented by the Proposed Development has the potential to be significant. For example, pylon placement could have a material impact on the viability of various development packages under consideration. This should be considered more carefully and may justify a higher significance rating.

16 The South West Research Company for Somerset County Council & EDF Energy, ‘Hinkley Point C Somerset Visitor Research 2011’, August 2011.




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4.9.6.5 With regards to cumulative effects paragraph 15.5.3 acknowledges the ‘potential for the cumulative projects to amplify amenity effects related to traffic and noise’. This is a major concern for the Councils especially regarding the reputational risk and the impacts of traffic and noise on tourism and in terms of the area’s ability to attract future business investment. There does not appear to be a mechanism in the method as set out for identifying the likelihood or extent of these impacts.

4.9.6.6 Residual effects for the operational phase should include the potential wider impact on tourism offer and reputation within the region.

4.9.6.7 Cumulative effects on the labour market should also be considered. For example, although local construction employment is generally well matched with the skill set of those currently unemployed with the local area, the extent to which this surplus labour may already have been absorbed by major developments such as Hinkley Point C (and, therefore, the extent to which there may be in-migrant labour) should be explicitly considered.

4.9.6.8 No specific cumulative effects have been stated for PRoW. Consideration needs to be given to the effect of further impacts on the rights of way network in the vicinity of the Hinkley Line Entries as noted in the Secretary of State’s Scoping Opinion. Site preparation works for Hinkley Point C has resulted in the long term closure of approximately 9km of PRoW in the parish of Stogursey. Therefore this area is already subject to a significant reduction in the number of PRoW available to residents and visitors to the area. Further interference or reduction in the number of paths available for use in this area will impact on users. Part of the West Somerset Coast Path (WSCP) has been closed and temporarily diverted. The temporary alternative path will form part of the England Coast Path National Trail which is due to open in 2014. It appears from Figure 12 that a section of the alternative route may be used as a haul road which could impact on users of the new National Trail. The WSCP is not actively promoted at present but user numbers are expected to increase when the new designation of National Trail takes place in 2014. Users are likely to be affected by disruption, noise, dust and there will be an impact on peace and tranquillity.

4.9.6.9 Overall, it is considered that the assessment of impacts section requires a more articulated link to the baseline findings, in particular: a more representative and improved qualitative analysis for the Business Survey with more detail on the impacts of traffic and noise particularly on tourism and a wider sectoral scope; to ensure all affected planning allocations are listed and assessed. At present considering the scope and content of the surveys there is a risk of the scale and significance of socio-economic impacts being underestimated.

4.9.6.10 The impact assessment on the network would seem to underestimate the likely significant effects. National Grid acknowledges that there will be an impact on the PRoW network but despite some of the paths forming parts of promoted routes providing key links between settlements, no path is regarded as having more than a moderately adverse impact. No regard has been had to any locally promoted (e.g. district and parish) walks and circular routes.

4.9.6.11 Path counts have been undertaken in a number of locations but as stated these provide only a snapshot of activity. Regardless of the results of user counts, local communities are very protective of their rights of way network and any changes, even on a temporary basis, can result in upset and complaints to the highway




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authority which is responsible for protecting the rights of the public to the use and enjoyment of the paths.

4.9.6.12 National Grid provides at paragraph 15.4.43 that: “direct effects are expected to range from PRoW management (i.e. signage, banksmen, and closures of short durations) and temporary diversions (closures from 6 months up to the full duration of the construction). It is not currently anticipated that there will be any permanent closures or diversions of public rights of way”. No specific discussion has yet taken place with the Highway Authority (HA) in relation to these impacts and how they will be managed. It is vital that the HA is party to and agrees with any temporary works including paths affected by scaffolding, closures and alternative routes to be provided during the full duration of construction.

4.9.6.13 Rights of Way Wardens are usually the first point of contact in the event of any disruption to use of a Public Right of Way (PRoW) and they will need to be involved and be fully briefed on the proposals which will last for a considerable number of years. The SCC database and interactive mapping system needs to contain all the information on affected PRoW for users who use this facility to plan walks etc. No mitigation has been discussed in terms of improvements to other PRoW or upgrading of the status of paths which were put forward as a result of public consultation for the Rights of Way Improvement Plan.

4.9.6.14 As with the baseline section, greater accuracy would be expected in the presentation of the impact assessment in the ES chapter. The observations as highlighted above undermine the robustness of the initial findings of the impacts assessment as set out in the PEIR.

4.9.6.15 The overall conclusion (at paragraph 15.9.2) that the proposed development is likely to have low moderate construction employment impacts is thought to be broadly correct, but the linear dispersal of these opportunities should be noted and employment breakdown in terms of the proportion which are likely to come from the local area should be specified.

4.9.6.16 The conclusion at paragraph 15.9.4 that no significant additional impacts are expected during operation compared with construction impacts is weak (particularly in terms of assessment of tourism impacts and impacts on Avonmouth and Severnside Enterprise Zone proposals and proposals for Huntspill Energy Park). Potential sources of impact, such as longer-term cumulative reputational risks in terms of tourism and the area’s wider attractiveness for business relocations, attracting self-employed people, and business retention and relocation are not explicitly considered and there is no obvious commitment to assess these impacts in the elements of technical work which are yet to be completed.

4.9.7 Mitigation 4.9.7.1 The proposed mitigation measures in the PEIR are presented as a definitive list.

Given the significant further assessment work to be carried out (p.174 - outstanding information) on a number of aspects of the assessment, the Joint Councils consider that further mitigation measures are likely to be needed to address impacts identified following this further assessment work, and would expect these to be provided to the joint councils for review in advance of the DCO application. The Joint Councils do not accept the current draft as a definitive list.




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4.9.7.2 In relation to PRoW, whilst the consultation material identifies the majority of PRoW likely to be affected by the proposed development, no detailed proposals regarding impacts and how disruption will be managed/mitigated has been included. In addition, no enhancement mitigation has been put forward by National Grid despite the Secretary of State’s Scoping Opinion outlining that: “The ES should clearly identify all potentially affected PRoW and set out the impacts on them, including within the wider area. It is important to minimise hindrance to them where possible and enhancements should be considered as part of the mitigation proposed”.

4.9.7.3 In light of the potential for the scheme proposals to cause disruption to the free movement of users of PRoW in the short and longer term and to impact on users overall enjoyment of PRoW due to adverse effects on views, noise, etc during construction the mitigation proposals put forward by National Grid require further development and consultation. National Grid seeks only to minimise the extent to which PRoW usage is disrupted and where PRoW must be temporarily closed, provide diversion routes, clear signage and advance warning of the closure. This is despite the comments provided in the Scoping Opinion that PRoW enhancements should be considered as part of the mitigation proposed.

4.9.7.4 Improvements to PRoW affected by the proposed development as follows:

Improvements to path furniture e.g. gates etc, and surfaces to those PRoW affected by the development; and

Upgrading of routes (legal and physical) put forward as a result of the public consultation on the SCC Rights of Way Improvement Plan, to mitigate the increase in levels of HGVs and abnormal loads on surrounding roads.

4.9.7.5 No approach has been made by National Grid for information regarding any proposals resulting from public consultation for the RoWIP. SCC has a database of proposals requested by Parish Councils, user groups and individuals for network enhancements/missing links, etc. These improvements are sought where appropriate.

4.9.7.6 Cumulative effects on paths in the vicinity of HPC, especially those which coincide with haul roads require further consideration given the major disruption to the footpath network resulting from the HPC proposals. Temporary signage is considered to be insufficient and National Grid’s mitigation proposals should include improvements to surfaces and path infrastructure in the vicinity of HPC.

4.9.7.7 Mitigation should be considered for any likely potential negative impacts on strategic employment sites. The Royal Ordinance Factory site at Puriton (the proposed Huntspill Energy Park) or the Avonmouth and Severnside Enterprise Areas are considered to be the most likely such sites.

4.9.7.8 Mitigation should be considered for any likely potential negative impacts on the county’s tourism offer (of which the PRoWs are an important element, but not the totality).

4.9.7.9 Potential local benefits arising from employment potential do not appear to be committed by the applicant in the draft DCO or any reference to supporting this aim through a planning obligation. This should be included.

Appendix A

SCC review of access details




Page A1

HPC National Grid Conection Project Consultation Doc Review - for inclusion in S 42 response.docV2

WWW.SOMERSET.GOV.UK

Tech

nic

al R

ep

ort

FAO: Alyn Jones (SCC) Lynn Basford (JMP)

Hinkley Point C Connection

Project

August 2013 SCC Review of Access Details

Sa-6-0026-002-1

HPC National Grid Conection Project Consultation Doc Review - for inclusion in S 42 response.doc Page 2 of 28

Economic & Community Infrastructure Operations

Traffic & Transport Development Group – PP C502 Somerset County Council

The Crescent Taunton

Somerset TA1 4DY

Tel: 0845 345 9155 Fax: 01823 358064

Technical Report

U:\DMZ\Advice\HDCactivefiles Page 3 of 28 22/10/2013

CONTENTS

1 INTRODUCTION ....................................................................................................................................... 4

1.1 INFORMATION PROVIDED FOR CONSIDERATION ........................................................................ 4

2 TECHNICAL REVIEW ............................................................................................................................. 5

2.1 PROPOSED ACCESS LOCATIONS ...................................................................................................... 5

2.2 ACCESS SPECIFIC OBSERVATIONS ................................................................................................ 12

3 GENERAL OBSERVATIONS ................................................................................................................ 25

4 ENVIRONMENTAL MANAGEMENT STATEMENT ....................................................................... 28


1 INTRODUCTION

1.1 INFORMATION PROVIDED FOR CONSIDERATION

The following information has been provided for consideration: -

1.1.1 Document DVD August 2013, Hinkley Point C Connection Project, Public

Consultation Doc.

1.1.2 Hard Copies August 2013, Hinkley Point C Connection Project, Public

Consultation:-

• Document 2.6 PEIR Part 1.

• Document 2.6 PEIR Part 4.

• Document 3.2 Land Affected Plans; Sections A to I,

• Document 3.5 Access an Rights Of Way Plans; Sections A to I.

1.1.3 Document CD 30th August 2013, National Grid, Hinkley Point C Connection

Project Technical Submission From Richard Gott to Helen Vittery.

1.1.4 Email; Richard Gott to Helen Vittery 25th Sept 2013 containing attachments:-

� MMD-322069-C-SK-400UG-XX-0203-400-UG-XX-0200)

� Document transmittal sheet Ref: DT 060913-RG-41


2 TECHNICAL REVIEW

2.1 PROPOSED ACCESS LOCATIONS

2.1.1 It is noted that Somerset County Council as the Highway Authority have

previously been involved in dialogue and discussion with National Grid and their

agents regarding proposed access locations. The detail contained within this

consultation document would appear to be at odds with SCC’s understanding of

the current agreed position and in order to provide the clarity necessary to

enable the project to progress efficiently, the Highway Authority have reviewed

all access locations included within the submitted consultation package. It is

acknowledged that some of the proposed access locations may have been

superseded post compilation of the consultation package and to ensure that

absolutely every proposed location is given consideration the Mott Mac Donald

technical submission received by SCC Aug 30th 2013 has also been subject to

review within this technical report.

2.1.2 Site inspections of the proposed access locations were carried out between 25th

September – 2nd October 2013. The Inspecting Engineers observations have

been included within section 2.2.3 of this report.

2.1.3 A desktop Planweb study of each of the proposed access locations has been

completed. The Inspecting Engineers observations have been included within

section 2.2.3 of this report.

2.1.4 The report considers feasibility in context of layout and road safety for individual

access locations only. Some general observations have been included

regarding the route in the proximity of some of the locations however no

consideration has been given to feasibility of overall strategic route.

2.1.5 The below schedule 2.1.8 details all access locations that have been proposed

within the documentation packages listed within section 1.2. The report

identifies 3 distinct workstreams:

• Doc 3.5 Access Rights Of Way Plans: Sections A to I (Consultation Doc

August 2013)

• Doc 2.6 PEIR, Part 4 Section 12, Preliminary Construction Routes, Access

Locations And ATC Count Site (Consultation Doc August 2013)


• Mott Mac Donald submission 30/08/13 (not included within consultation

Doc)

2.1.6 Access locations detailed within the terrier document referenced within the

commissioning brief (see 1.1.2) entitled Doc 3.2 Land Affected Plans appear to

be consistent with those detailed within the Doc 3.5 Access Rights Of Way

Plans. For ease of reference this report utilises the Doc 3.5 Access Rights Of

Way Plans ‘AC’ notation, no notation for individual access locations has been

included on the Doc 3.2 Land Affected Plans.

2.1.7 Access location references are inconsistent between the 3.no workstreams,

cross-references have therefore been provided within schedule 2.1.8 below


2.1.8 Schedule of cross referenced workstreams


2.2 ACCESS SPECIFIC OBSERVATIONS

2.2.1 The following comments have been made specifically for each access. There are a number of common factors that may apply to more than 1 access and these are repeated in section 3 of this report.

2.2.2 Many of the accesses are to be constructed on private land not within the

control of the highway authority. Where visibility splays are to be provided they

must be kept clear at all times.


2.2.3 Individual Access Locations – Technical Review Comments


3 GENERAL OBSERVATIONS

3.1.1 There are many field accesses where livestock is likely to be kept.

Consideration will need to be made for allowing livestock to continue to use the

field but prevent animals from straying on to the highway.

3.1.2 Where ditches are culverted to allow access into a field, private surface water

from adjacent land must be prevented from flowing out onto the highway.

Advice on the size of culverts in ditches should be sought from the Local Inland

Drainage Board or District Council Drainage Engineer.

3.1.3 There are no construction details for the accesses. Details will be required for

the surface finishes. Care must be taken to ensure that loose material such as

stone and mud is not tracked out onto the highway as this will present a hazard

to through traffic.

3.1.4 Engineering drawings and supporting information will be required for each of the

individual proposed locations, to include:-

• A topographical survey of the access location.

• Extent of existing and proposed highway boundary and National Grid

ownership identified (or red line where notice has been served).

• Demonstration that appropriate visibility splays have been secured

• Swept path diagrams to demonstrate that all vehicles can enter and exit the

site safely.

• Details of any alterations to the accesses that may be proposed (including

but not limited to; widths, levels, construction, drainage, structures/culverts,

fencing, passing places, lay-down areas, parking and turning provision,

anticipated no and type of vehicles, etc.)

• Duration of works at a specific location and the anticipated level of use at

that location should be identified.

• Any mitigation schemes that are required to the existing highway network to

facilitate the use of the proposed access (including strengthening works to

the existing carriageway construction as necessary, passing places, etc.)


3.1.5 Swept path drawings should be provided for all accesses at a scale of 1:200.

3.1.6 Swept path drawings should show all movements in and out for the largest FTA

vehicle expected to use the access.

3.1.7 Visibility splays should extend to the nearside edge of the carriageway and not

to the centre.

3.1.8 ‘x' distances of 2.4m should be provided and detailed on all accesses.

3.1.9 All watercourses will need to be investigated, where necessary consent for

alterations/crossings will need to be secured from the EA, IDB or SCC.

3.1.10 The project delivery programme remains unknown; confirmation will be required

in order that adequate consideration can be given to this project in context with

both HPC & non-associated committed development. Access locations may

conflict with committed development and require adjusting accordingly.

3.1.11 No reference to route maintenance, either re-active or pro-active appears to

have been included within the consolation document. Upon receipt of the

transport assessment, further discussion will be required regarding route

maintenance proposals, given the rural/unclassified nature of many of the

access locations and the anticipated frequency of HGV traffic it is possible that

pro-active enabling maintenance works may be required.

3.1.12 Further to 10 above, it is recommended that a baseline route condition survey is

undertaken at the earliest opportunity, to include assessment of any existing

structures along the route, findings of the survey will assist in determining route

maintenance proposals and will inform detailed design process.

3.1.13 Utility apparatus will require detailing on individual access design proposals.

Where works conflict with existing apparatus locations, the utilities will require

diverting, protecting to the satisfaction of both the statutory undertaker and the

highway authority.

3.1.14 The A39 is a dedicated abnormal loads route within Somerset, the designer

should consult with Avon & Somerset Police regarding movement of any AL's.

3.1.15 Adequate consideration will need to be given to environmental & ecological

sensitivity when assessing proposed access locations.


3.1.16 Further details will be required regarding duration of works at a specific location

and the anticipated level of use.

3.1.17 Legacy use for these accesses must be identified, where necessary

appropriate provision to facilitate legacy use will need to be included within the

individual access legal agreements.

3.1.18 Where access locations are to be returned to existing layout upon completion of

construction, appropriate provision will need to be included within the individual

legal agreements.

3.1.19 The TDG review team have been informed that the highway works are to be

undertaken having regard to Article 19 of the DCO. Article 19 (1) makes

reference to the street authority & the undertaker entering into agreements. At

this consultation stage the developer should be made aware that SCC (as street

authority) fully expect to enter into individual legal agreements for the many

elements of work on the highway. Where practical individual schemes or

elements may be combined however it is anticipated that the legal agreements

will take the general form of an agreement as if it were made using Section 278

of the Highways Act, albeit that SCC acknowledges that the phrasing of some

clauses will need to differ to reflect the specific DCO requirements.


4 ENVIRONMENTAL MANAGEMENT STATEMENT

Any comments on the subject of environmental issues contained within this

report are observations only. This report does not in any way constitute a formal

environmental assessment of the proposals submitted.

This document is also available in Braille, large print, on tape and on disc and we can translate it into different languages. We can provide a member of staff to discuss the details. We value diversity. We are committed to promoting equality of opportunity and fair access to services based on need.

Appendix B

Road structures identified in North Somerset on the proposed construction traffic routes

This page is intentionally blank.

Somerset County Council, North Somerset Council, Sedgemoor District Council, West Somerset Council Hinkley Point C Connection Project Stage 4 Consultation - Technical Review


Page C1

Structure

Ref.

Structure Name Owner Structure Type Load Carrying

Capacity

Comments Recommendations

46040 Osmond Railway

Bridge Rail Property Ltd.

Single span steel

girders with

transverse spanning

brick jack arches.

40t/45 HB

Load carrying capacity confirmed

by Daryl Parker in May 2002. Last

General Inspection conducted in

2009. Carry out a Principal

Inspection to confirm current

condition.

Carry out a Principal Inspection in

liaison with Rail Property Ltd &

NSC to confirm the current

condition. Approach Rail Property

Ltd. To confirm current load

carrying capacity

46044 Droveway Bridge North Somerset

Council

Single span stone

masonry arch 40t/45 HB

Assessed in 1997. Last Principal

Inspection conducted in 2007.

Carry out a Principal Inspection to

confirm the current condition and

to identify any maintenance works

required to ensure the structural

integrity of the structure.

46054 Lampley Bow

Culvert

North Somerset

Council

1.0m Dia. Armco

culvert. No Record

An inspection of this structure was

conducted in June 2013 by NSC

structures team. The level of the

water made it impossible to

inspect the interior of the culvert.

Although we have no record of its

strength, this type of structure is

inherently strong.

Carry out a Diving

Inspection/survey to confirm the

condition of the structure and to

establish sufficient information to

enable an assessment to be

undertaken. Carry out a structural

assessment of the pipe.

46038 Kingston Railway

Bridge Rail Property Ltd.

Single span stone

masonry arch 40t/11 HB

The last General Inspection of this

structure was carried out in 2009.

Carry out a Principal Inspection in

liaison with Rail Property Ltd. &

NSC to confirm the current



Page C2

Structure

Ref.


Capacity


condition. Approach Rail Property

Ltd. to confirm current load

carrying capacity

46017 Mawkins Bridge North Somerset

Council

Conflicting data.

Structure type to be

confirmed during

the recommended

Principal Inspection.

No Record The last Principal Inspection of this


Carry out an Inspection for

Assessment to confirm the current

condition and establish all the

information required for a load

assessment to be carried out.

Commission a structural

assessment to confirm load

carrying capacity. As there are no

record drawings available, intrusive

site investigation and materials

testing will be required.

46019 Kenn Pier Bridge North Somerset

Council

Single span stone

masonry arch. The

structure has been

widened using

reinforced concrete

construction to

support the

parapets.

40t The last Principal Inspection of this



confirm the current condition. If the

structure is required to facilitate the

passage of vehicles outside the

range included in the 40t

assessment, then further

assessment for specific vehicles

will be required.



Page C3

Structure

Ref.


Capacity


47170 Nailsea Moor

Drove No.1 Private

Single span stone

masonry arch No Record




Assessment/survey to confirm the

current condition and to collect

sufficient information to enable an




carrying capacity.

47018 Causeway Bridge North Somerset

Council

Single span RC

beam/slab. 17t

The last Principal Inspection was

carried out in 2008. The structure

appears to have been

strengthened in 2002 by the

addition of a RC overslab. There

are however no records of

strengthening in terms of AIP,

design/check certificates etc. The

1998 assessed capacity of 17t has

therefore been reported.


Assessment to confirm the current

condition. Commission a structural


carrying capacity.

47159 Causeway Pipe Private Listed as pipe

<0.9m dia. No Record

There is no historic information

available relating to this structure.








Page C4

Structure

Ref.


Capacity




carrying capacity.

47054 Caswell Hill North Somerset

Council

1.8m dia. Armco

corrugated steel

pipe culvert.

No Record The last Principal Inspection was

carried out in 2000.

Carry out a Principal


current condition and to facilitate a

structural assessment.

Commission an assessment of the

structure.

46020 Kenn Pier Culvert Environment

Agency

2 span RC concrete

deck, simply

supported on RC

abutments and

continuous over a

central RC pier.

Each span is 1.5m

clear between

supports

No Record The last General Inspection of this


Contact the Environment Agency

to establish the current condition

and load carrying capacity of the

structure.

46065 Puxton Court

Farm Culvert East

North Somerset

Council

Twin Culvert < 0.9m

dia. No Record



During this inspection it was

established that the headwall has

rotated and the pipe fractured








Page C5

Structure

Ref.


Capacity


close to the culvert entrance at

both ends of the structure.



carrying capacity.

46041 Oldbridge River

Bridge

North Somerset

Council

3.8m single span

stone masonry arch

bridge.

40t

An inspection of this bridge was

carried out in 2013, and reported

that the structure requires some

remedial work to ensure its

integrity. Historic information

suggests that the bridge was

strengthened to 40t in 2004 by

Cintec. There appears to be no

confirmation that the works were

carried out. Following a parapet

impact in 2011 an RC saddle was

constructed over the arch along

with the addition of mass concrete

backing behind the abutments.








will be required.

36203

Puxton Court

Farm Culvert

Twin Culver.

North Somerset

Council

Twin Culvert < 0.9m

dia. No Record

Last General Inspection was

carried out in 2000, but we have

no recorded information from the

inspection.










Page C6

Structure

Ref.


Capacity


carrying capacity.

36018 Puxton New

Bridge

North Somerset

Council 1.8m span RC slab No Record

Last Inspection was carried out in

2008, from which it appears that

the bridge is in a fair condition.






structure. Intrusive investigation

will be required to facilitate the

assessment.

36004 River Banwell

Bridge

North Somerset

Council

5.2m span Armco

Culvert No Record

The last inspection, carried out in

2008 reported that the structure is

in a good condition.






structure.

46290 Beacons Works

Pipe Assumed private Unknown No Record

No historic records relating to this

structure. It has been established

that the proposed haul road will be

constructed directly over this

structure, and as such it will be

necessary to replace the structure

with new as part of the works.










Page C7

Structure

Ref.


Capacity


carrying capacity.

47112 Watery Lane Pipe

New Private

0.9m diameter pipe

culvert No Record

No inspection history for this

structure








carrying capacity.

47017

Portbury

Common Railway

Bridge

North Somerset

Council

8.7m span

brick/stone masonry

arch bridge. The

bridge spans a

disused railway.

40t

There is no record of a Principal

Inspection having been carried out

for this bridge.








will be required.

47111 Portbury Culvert

No. 2

North Somerset

Council

1.2m dia. pipe

culvert No Record

No reliable inspection data is

available









Page C8

Structure

Ref.


Capacity



carrying capacity.

47073 Portbury Culvert

No. 1

North Somerset

Council

Twin Culvert 0.6m

dia. No Record No inspection data is available








carrying capacity.

hinkley point c connection project

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