Orby Parish Council objections to PINS Scoping Opinion Grimsby to Walpole (EN020036)

Orby Parish Council comments/suggestions/objections with respect to PINS Scoping Opinion Grimsby to Walpole (EN020036)

We believe that the plan for pylons is destructive and outdated and will cause irreversible damage to the countryside, wildlife habitats, and local communities and we find the proposal will be detrimental to our beautiful countryside.

We fully support the need to generate renewable and low carbon electricity to meet local and national Net Zero ambitions.

However, there are more suitable, sustainable and modern alternatives for the network that have not been properly investigated and presented, such as undersea cable routes.

In more detail:

National Grid’s (NG’s) Scoping Report is ostensibly for ONE line of 50m 400kV pylons from Grimsby to Walpole, with new substations at Grimsby and Walpole, and two at Alford (so-called ‘southwest of Mablethorpe’ in all NG documents). The carrying capacity of a single 400kV pylon is less than 7GW. The new projects cited by NG to justify the project total 9.764GW. To accommodate this NG would need at least TWO lines of pylons.  Power would also be routed (south) via Grimsby (up to 7GW) into Alford. If this is approved, it is likely that projects already in the planning process (like ODOW) will be rerouted into the Alford substations (why would any project bury cables from Alford to Walpole when there is no need?). 

In addition, there are numerous large scale (1GW+) solar farms mooted along the proposed route which will also require connection (hence all the rather vague LCS’s incorporated in this document). The Alford substations will need capacity for 22GW plus (source NG). Please note that there is no local requirement for any of this new renewable generation, we are already in net spill.

To accommodate all this proposed generation, NG would require TWO 400kV lines from Grimsby to Alford and THREE 400kV lines from Alford to Walpole. Because Grids are designed largely in a ‘boxed format’ NG would then require a new 400kV line from Alford to Lincoln. According to NG, some 30GW is due to be brought into the B8 boundary. Recently, HMG announced even more ambitious licensing of additional renewable generation, some of which may be landed into the Eastern coast. Alford alone could easily end up a 40GW plus hub. Accommodating all the export routes south and the various associated onshore facilities would entail vast areas of land being dedicated to electrical facilities. We believe that this proposed ONE set of 400kV pylons and substations really represents the first enabling step for the conversion of vast swathes of rural Lincolnshire (and beyond), into a series of industrial-scale electrical complexes connected by multiple sets of 50m pylons.

To cover the true scale and potential impact of this project, we therefore respectfully request that the Scoping includes the following:

1.  The Scoping Area should be extended to cover the whole of the ‘Overhead Study Area’ as shown in Figure 3.2 of the Scoping Report. (Also, the ‘Overhead Study Area’ should be enlarged to cover the whole of the potential pylon/associated infrastructure corridors – this is not currently the case – see Fig, 3.2);

2. The PEIR, EIA and ES study area should extend 5kms from the boundary of the ‘Overhead Study Area’ and be extended, where appropriate, to the ‘Limit of Deviation’. The topography of the route means that this development will have a significant visual and cumulative impact as the landscape, being mainly flat, is highly sensitive to change. The significance of 50m pylons is not mitigated by distance in a flat landscape of large arable fields. If the ‘apparent height’ of a 50m pylon at 5km is 0.61cm as claimed by the applicant, then a 25m building would appear as 0.31cm. Most structures in the landscape along the route(s) are isolated farm buildings less than 15m high, therefore the visual and cumulative impact of even a single line of pylons and associated infrastructure would be significant. This development would change the landscape character throughout the route;

3. Because of the impact of the proposed development in a (mainly) sparsely populated rural area, all ‘additional measures’, ‘secondary measures’, ‘ancillary development’ and ‘associated ancillary development’ should be included in the Scoping and anything (apart from temporary measures necessary for construction), not included within the Scoping and EIA should not be accepted as part of the DCO. Otherwise, there is a risk that additional lines of pylons and substations (as illustrated in Figures 3.2 & 3.4) are included in the final DCO Application without any public consultation or environmental impact assessment;

4. The Visual Impact study area should be extended to the coast (in particular around the Gibraltar Point NNR); and the eastern edge of the Lincolnshire Wolds AONB;

5. Several Heritage assets of national importance (Grade 1), which are likely to be seriously impacted (i.e. significantly harmed) by the proposed development are not included in the current study area. All Heritage assets (Listed Buildings, scheduled monuments and listed Parks & Gardens) within 5kms of the ‘Overhead Study Area’ should be included in the PEIR/EIA/ES;

6. Photomontages and wirelines for the Visual Impact Assessment should be from viewpoints specifically agreed with local communities from every parish within the Visual Impact Study Area (e.g. Parish Councils; Parochial Church Councils/District Church Councils; walkers/ramblers associations; Parish Meetings; residents etc.; i.e. ‘the different groups of people likely to be affected by the project’ (Scoping Report 7.18.17);

7. Photomontages and wirelines should be provided in hard copy (printed at the optimal size for viewing), to all Parishes within the Visual Impact study area (minimum 10km radius from the Scoping Area); and on request to any member of the public. Photomontages cannot be properly used by a layperson on a computer screen. (Also, many areas within the route are Wi-Fi blackspots and there is no superfast broadband, so the files are too large to open).

8. All photomontages and wirelines should conform to the Nature Scotland (2017 and updates) Visual Representation of Wind Farms Guidelines. Panoramic photomontages should be accompanied by a single photomontage from the same viewpoint taken at 50mm focal length. 

9. There is an overlap between substations LCS 6 & 8 (i.e. LCSB) in the Scoping Report (Figure 3.4), and the siting zone for the convertor station and direct current switching station in National Grid’s EGL 3&4 Project Background Document. NG should make it clear which project the proposed developments belong to. Since, if the Grimsby to Walpole Project is consented, EGL 3 & 4 will be added to the overhead lines (Table 4.3), rather than taking the buried route to Weston Marsh (as currently proposed), then it would surely be most cost-effective to combine the two projects at this stage and extend the Scoping Area and EIA appropriately.

10. Full flood risk assessment for inundation of seawater relating to storm surges; collapse of levées; breach of riverbanks; flash flooding etc. should be conducted for the whole (revised) Scoping Area. 

11. Finally, there is a serious issue of broadband availability along the whole route, therefore we request that in addition to providing the photomontages (see 7 above), the applicant makes all consultation documents freely available in hard copy at locations open to the public during working hours, and at weekends (many libraries in the affected area, Alford for example, only open 4 days a week). The documents should also be made available on free memory sticks provided by NG at public information days, and on request. Otherwise, many of those most affected by the proposed development will be unable to access the information required to comment on it.

Potential impacts on the landscape:

• It will carve off the nearby popular coastal resorts of Mablethorpe, Sutton-on-Sea, Sandilands and Anderby Creek from the Lincolnshire Wolds National Landscape (an area of outstanding natural beauty) and may mean our Parish’s Tourists, of which local businesses depend, will in future choose to visit The Wolds, or The Coast, rather than holidaying in the Parish to visit both. There needs to be a detailed impact assessment on the Lincolnshire Wolds area of outstanding natural beauty (AONB)
• As in our response at the ‘non-statutory consultation’ phase to National Grid, we do not feel National Grid have adequately accurately assessed other options of an offshore integrated grid or undergrounding as alternatives.
• The uncertainty around the siting of proposed pylons and substations should be cleared up so that residents understand exactly the potential impacts.
• We support cleaner and more secure forms of energy but not at any cost to the environment and residents. Pylons are an archaic infrastructure system blighting the landscape for decades.

Potential impacts on natural environments:

• The EMF of the pylons will interfere with bee hives on land beneath (which are needed for pollination of crops) and bats navigation, which reside in Rigsby Wood and Ailby Plantation.
• Risks harming our Parish’ Barn Owl population and migrating Canadian Geese that fly over the Parish could be adversely affected too.

• We are close to a migratory superhighway for millions of birds, the cables would risk their harm too.
• The land in the Parish is predominantly agricultural and any soil compaction during construction would affect the productivity going forwards.
• The lifespan of the infrastructure needs careful consideration in regard of being subject to strong gusts of winds off the North Sea/regular Sea Fret exposure.
• Impact on protected species such as great crested newts, reptiles, birds, water voles, badgers and bats.

Potential impacts on residents:

• The effect of land and property owners’ mental health is of great concern, adding to the stress both mentally and physically farmers are already under. 100% of homeowners in the Parish voted against this proposal at our Parish Meeting in February 2024.
• Adverse impact on value/profitability of the Parish’s (and surrounding) land and property.

Devaluation of property putting residents at risk of negative equity.

• Noise pollution from Sea Fret hitting the cables on a regular basis and this being more likely overnight when people are trying to sleep.
• Disruption for residents in their commute to school/work (and tourists in their holiday travel) during the construction period.
• What steps will be taken to prevent Mirco-shocks for residents & tourists who walk, cycle, horse-ride or fish in the area?
• Light pollution adversely impacting residents as properties of a particular rural nature with far reaching views.
• Where exactly will the two proposed substations be located? Require a detailed explanation of construction activities especially if any will take place at night and the landscape measures to be taken around the sub stations and pylons. There will be an adverse impact on residents in terms of light, views and noise.

Potential impacts on businesses:

• Our predominant industries are Farming & Tourism. Disruption to holiday makers during construction and reduced appeal of the region once constructed will mean reduced visitor numbers = less profitability/viability = less employment for local population.
• Loss of prime agricultural land / land less productive due to soil compaction/disturbance, giving concern for future food security. What steps will be taken to ensure that harvests can continue during construction?
• Need to understand the effect of maintenance via helicopter, vehicle and drone activities.

Potential impacts on existing infrastructure:

• During construction there will be many large heavy vehicles on narrow country lanes, what steps will be taken to mitigate the disruption to rural transport links, damage to the already crumbling county roads?
• Potential for narrow lanes to subside under the weight of heavy plant possibly contaminating watercourses and causing flood risk.
• Traffic impacts should be assessed for both construction and operational activities.

Potential safety risks:

• What measures will be put in place during construction and beyond to mitigate the risks to workforce and residents, given that many areas are rural and emergency response times  slow?
• Flying exercises by military in the area and the Lincolnshire Gliding Club at nearby Strubby North Airfield that sometimes has craft pass over to our Parish.
• Has a fire risk assessment of the pylons and wires been conducted especially since they run across agricultural land which is highly flammable both pre- and post-harvest of grain crops.