Customer Services: Our Ref:

Transcription

1 3/18 Eagle Wing Temple Quay Huse 2 The Square Bristl, BS1 6PN Custmer Services: NWWFCnnectin@pins.gsi.gv.uk Ms C Duffy Envirnmental Planning SP Energy Netwrks 3 Prentn Way Prentn CH43 3ET Yur Ref: Our Ref: EN Date: 4 March 2015 Dear Ms Duffy NORTH WALES WIND FARMS CONNECTION PROJECT DRAFT HABITATS REGULATIONS ASSESSMENT NO SIGNIFICANT EFFECTS REPORT AND DRAFT ENVIRONMENTAL STATEMENT CHAPTERS Thank yu fr giving the Planning Inspectrate the pprtunity t cmment n the draft Habitats Regulatins Assessment N Significant Effects Reprt (HRA NSER) and fr frwarding draft cpies f Chapters 1 5 f the draft Envirnmental Statement (ES) fr the Nrth Wales Wind Farms Cnnectin Prject. The Planning Inspectrate des nt as a matter f curse cnduct detailed reviews f ESs ahead f the examinatin stage, but when pssible we d prvide sme advice as t the apprach applicants are prpsing. 2. We have nw reviewed the dcuments and have set ut sme cmments belw which we hpe will be helpful. These cmments are in additin t the pints raised at ur meeting n Friday 23 February. Please nte that these cmments are based n a high level review at this stage and are given n a withut prejudice basis. Cmments are limited t the prcess and d nt address cnclusins reached within the dcuments. As these cmments cnstitute sectin 51 advice under the Planning Act 2008 (as amended) they will be placed n the Planning Inspectrate's register f advice n the Natinal Infrastructure Planning website. Draft Habitats Regulatins Assessment N Significant Effects Reprt 3. The Inspectrate recmmends that in accrdance with advice cntained in Planning Inspectrate Advice Nte 10 the NSER shuld include evidence that Natural Resurces Wales (NRW) supprt the cnclusins reached. The NSER

2 shuld cnfirm that the prject is nt cnnected with r necessary t the management f the Eurpean sites cnsidered. The terminlgy used within the reprt shuld be cnsistent with the HRA prcess, eg reference shuld be made t in-cmbinatin effects rather than cumulative impacts (an EIA term). It is als imprtant t ensure that the assessment cncludes as t the likely significance f each impact cnsidered in rder t supprt the finding f n likely significant effect. 4. The Inspectrate highlights the imprtance f prviding cnsistency and clarity in the descriptin f develpment in the NSER. There are sme areas where this culd be imprved, eg references t existing highway culd be clarified by specifically identifying rad numbers. It wuld als aid the reader if prpsed and existing infrastructure was always identified as such. 5. There are sme sectins f the NSER fr which it is recmmended that greater detail is prvided t ensure that the prcess by which Eurpean sites were selected and assessed is clear, and that the cnclusins are fully substantiated. This particularly applies t Sectin 5 f the NSER in relatin t the assessment f likely significant effects. Crss-reference shuld be made as apprpriate t the relevant baseline infrmatin within the Envirnmental Statement (ES). 6. Specific cmments relevant t the NSER are as fllws: Paragraphs : It wuld be helpful if these paragraphs crssreferenced relevant plans identifying the elements f the prpsed develpment and thse f the wider scheme. Paragraphs : The descriptin f the wider scheme in the NSER is nt cnsistent with the descriptin f the wider scheme cntained in the draft ES Chapter 2, which includes the fur wind farms fr which the prject will prvide a cnnectin, and diversins f existing lwer vltage verhead line crssings. The descriptins in the NSER f bth the prpsed develpment and the wider scheme shuld reflect the descriptins set ut in the ES s it is clear what has been assessed. Paragraph 3.3.1: The justificatin fr selecting the 15km study area shuld be prvided, and it is recmmended that it is stated whether the study area and identified sites were agreed with NRW. Table 3.1, page 13 and Table 3.2, pages 14 15: All the features f the sites shuld be identified here, nt nly thse that are a primary reasn fr designatin. Table 3.2 shuld identify whether the sites included are SPA r Ramsar sites. Paragraphs 4.4.1, 4.4.7, 4.4.9, , : Refer t dimensins that d nt appear t be maximum dimensins permissible under the DCO. The dimensins n which the assessment is based shuld reflect the maximum parameters specified in the DCO and represent the wrst case scenari. Paragraph : It wuld be helpful t include infrmatin n the duratin f the cnstructin activities.

3 Paragraph 5.1.1: A definitin f what is cnsidered t cnstitute a significant effect shuld be prvided in this sectin. Paragraph 5.2.4: It wuld be helpful t include the survey dates fr all the surveys listed. Paragraphs : A mre detailed explanatin and justificatin fr the cnclusins reached shuld be prvided in relatin t the Eurpean sites identified in Tables 3.1 and 3.2. Crss-reference shuld be made t relevant baseline infrmatin cntained within the ES and supprting dcuments. This may include, fr instance, the lcatin f relevant watercurses, infrmatin relating t migratry bird species including use f the site r fly ver activity and findings frm the winter bird survey. Paragraphs : The cnservatin bjectives fr the Dyfi Estuary SPA have nt been prvided. The NSER shuld include the cnservatin bjectives fr all Eurpean sites taken frward fr assessment. Stage 1 Matrix A, page 32: The evidence ntes prvided in supprt f the cnclusins fr Elwy Valley Wds SAC shuld be expanded t prvide greater demnstratin f why significant effects are unlikely such as, fr instance, clarifying that there are n pathways which culd give rise t indirect effects n the SAC. Paragraphs : Suggest crss-reference is made t relevant survey infrmatin in the ES and appendices as apprpriate, such as fr instance the winter bird survey. 7. The Inspectrate has als identified a number f minr typs and missins within the main bdy f the reprt, eg paragraph , first bullet pint: we assume -wide has been mitted after 60m. 8. The Inspectrate makes the fllwing cmments in relatin t the figures and matrices prvided as appendices t the main reprt: Paragraph 1.2.9: Figure 1.1 is referenced but nt included in the NSER. It is presumed that the lcatin plan at the end f the dcument is Figure 1.2 but this is nt clear. It is recmmended that it is labelled as such, and that the SAC referenced in the key is clearly labelled. Paragraphs and refer t Figure 1.2, which is a lcatin plan. It wuld appear that these shuld mre apprpriately refer t Figure 4.1, Preferred Rute Crridr and Prpsed Rute Alignment. Fr ease f reference we suggest that the lcatins f the matrices in the Reprt are identified n the Cntents page. If any ther Eurpean sites are subsequently screened in fr assessment crrespnding matrices shuld be prvided, and any matrices prvided shuld include all the features fr which the Eurpean site is designated.

4 Stage 1 Matrix A table, page 35: Effect 1 shuld reflect the name f the effect. Suggest replacing x in the shaded bxes with n/a, as advised in AN10, Appendix 1. Fr ease f reference, we request that all matrices are numbered uniquely rather than all titled Matrix A. The matrices shuld include a key, as shwn in Advice Nte 10, Appendix 1. Draft Envirnmental Statement Chapters Chapter 2: Descriptin f the prpsed develpment Paragraph 2.2.7: The last bullet pint refers t diversins f existing lwer vltage verhead line crssings cmprising part f the wider scheme, and reference is made t this in paragraph Hwever, the first bullet pint f paragraph includes recnfiguratin r undergrunding f existing verhead lines as wrks integral t the prpsed develpment. The Inspectrate cnsiders that incnsistencies within the ES and applicatin dcuments as a whle shuld be avided where pssible. Paragraph 2.4.1: The Inspectrate suggests that this is rewrded t make it clear that it is nly the ple psitins, and nt als the rute alignment, that are indicative n Figure 2.2. Figure 2.3: Is indistinct and the dimensins are unreadable in the hard r electrnic cpy. Paragraph : Reference is made t final cnnectins at the terminal ples t St Asaph and the cllectr substatin via a sealing end and a slack span respectively. It wuld be clearer if a mre distinct name was given such as the Clcaeng cllectr substatin. It is als unclear the extent t which these features are part f the prpsed develpment r the wider scheme. References t dimensins are ften described in terms f the minimum, in general r apprximately, such as fr instance in paragraphs , , and Whilst it is understd that the final specificatins aren t knwn at this stage, the assessments in the ES must be based n the wrst case scenari, and it shuld be made clear in the ES that this has been the apprach. It is stated in Sectin 2.7 that sme excavated material will need t be remved frm the site and sme backfill material will be imprted t the site. The ES shuld include cnsideratin f remval f waste materials and traffic mvements relating t remval and imprtatin f material. Chapter 3: Alternatives and Design Evlutin Paragraph 3.3.7, 2 nd bullet pint: It is stated that there is a preference fr the Link crridrs but the term is nt explained here r subsequently.

5 Chapter 4: EIA Methdlgy Table Cumulative Assessment: Althugh identified in paragraph as frming part f the wider scheme, the prpsed lwer vltage diversins are nt included in the table and presumably shuld be; Tw f the fur wind farms described as included in the wider scheme are shwn in the table as excluded frm the cumulative assessment. It is stated that Derwydd Bach Wind Farm is cnsidered t be t far frm the prpsed verhead line t give rise t any significant cumulative visual effects, which suggests that there is ptential fr cumulative effects in relatin t ther factrs, s it is unclear why it is identified as excluded; It wuld be helpful t include the prximity t the prpsed develpment f the develpments identified in the table. Paragraph : suggest that this is rewrded s that it is clear that the laying f the undergrund cable is nt part f the prpsed develpment. 9. Please nte that as with the NSER there are sme typs and referencing errrs in the draft ES chapters that will need t be crrected prir t submissin. Hwever, the Planning Inspectrate acknwledges that these are wrking drafts and that there will be further refinement and editing prir t submissin. 10.I hpe yu find these cmments useful. Please d nt hesitate t cntact me shuld yu have any queries. Yurs sincerely Alisn Dwn ALISON L DOWN EIA and Land Rights Adviser Advice may be given abut applying fr an rder granting develpment cnsent r making representatins abut an applicatin (r a prpsed applicatin). This cmmunicatin des nt hwever cnstitute legal advice upn which yu can rely and yu shuld btain yur wn legal advice and prfessinal advice as required. A recrd f the advice which is prvided will be recrded n the Planning Inspectrate website tgether with the name f the persn r rganisatin wh asked fr the advice. The privacy f any ther persnal infrmatin will be prtected in accrdance with ur Infrmatin Charter which yu shuld view befre sending infrmatin t the Planning Inspectrate.