KINGSWAY SOLAR
REACH PARISH COUNCIL’S SUBMISSION TO THE STATUTORY CONSULTATION PROCESS
Reach Parish Council has studied your preliminary environmental impact report (PEIR) and listened to your online presentation today. Our focus is, of course, on the proposed 440kV pylon route through our parish. We understand that the proposed route is iterative and stand by to assist in improving and refining your application to a level that would be acceptable to local residents.
As it stands, we object to your proposal to connect to the national grid by overhead head line (OHL) and, in particular, to the proposed route of the OHL through our parish. We consider that the proposed route creates an unreasonable and unnecessary landscape and visual impact to the east of our village.
Our objections
Reach’s Neighbourhood Plan of 2024 and the professional landscape appraisal that underpins it demonstrate that the great majority of Reach residents cherish open vistas from the village including those to the east of the village directly affected by the proposed pylon route. The Neighbourhood Plan seeks to protect these in policies RCH6 and RCH10 (https://eastcambs.gov.uk/sites/default/files/2024-10/REACH Neighbourhood Plan Made Version February 2024.pdf). A copy of the underlying landscape appraisal, where sections 4.4 Important Views and 4.7 Rural Lanes and Open Gaps are germane to our objection, is attached to this letter.
You acknowledge, in table 7.13 in Vol 2, Chapter 7 of the PEIR, that the northern part of the Grid Connection Corridor will face significant cumulative effects on some visual receptors including residents, PRoW and road users. However, we consider that the view points you have used in your LVIA are partial and insufficient to gauge the full scale of the adverse impact. Additional viewpoints along Burwell Road, public rights of way between Reach and Burwell and from the Devil’s Dyke would far better inform judgements on the cumulative effect of development.
Furthermore some existing viewpoints are orientated in one direction only and fail to take account of the view looking towards the majority of the proposed infrastructure. This should be reviewed. Other viewpoints such as Vp 21 illustrate the extent to which the existing 400Kv OHL utilises landform to mitigate its scale and effect, something which would not be possible with your proposed route.
We also believe that the proposed route has a significant adverse visual effect on the Devil’s Dyke scheduled monument, the northern end of which lies in our parish. The proposed route would greatly damage the sense of place at one of the most important Anglo-Saxon earthworks in the UK. At the northern end of the Dyke, the pylons would run parallel to the Dyke for about 2.5 km and would sometimes encroach within 150 metres of it. As such, the pylons would be a constant visual intrusion to visitors to the Dyke for which the main mode of access is by footpath along the top of the Dyke. We see no evidence in your PEIR that you have undertaken a Heritage Impact Assessment commensurate with the importance of the scheduled monument. Accordingly the mitigations you propose are insufficient. We know that our concerns are shared by our colleagues in the parish of Swaffham Prior.
Should your application proceed to public examination in its current form we shall submit a further professional landscape assessment in support of our above objections. However, we consider that there are alternative means of connection open to you that might allay the majority of local concerns.
Our alternative proposals
We believe that burial is technically feasible, financially viable and valid in planning policy terms as a mitigation of the cumulative effects of wirescape in the vicinity of the Burwell substations. We note that Sunnica, a solar scheme of similar scale and based a similar distance from national grid connection at Burwell was willing and able to bury its connection. Furthermore, very recently Cambridgeshire County Council buried an electrical supply from Burwell to the Community Heating Scheme at Swaffham Prior in the same area as your proposed pylon route. The decision was clearly to protect the Devils Dyke and surrounding countryside.
We note in para 4.3.45 of the PEIR that you identify the most notable constraint to an underground connection as being within a section of the corridor where two 33kV OHL lines and three high pressure gas pipelines are located. In the absence of any detail on the location of these constraints or their technical impact on burying your connection it is impossible for us to assess this assertion.
On the basis of the PEIR we judge that there may well be above ground connection options that though likely less satisfactory to local residents would be better than your current proposal.
We note in paragraphs 4.3.11, 4.3.12 and 4.3.18 of your PEIR that you had considered a connection using the existing Pelham to Burwell 400 kV OHL where you had identified capacity. We also note in paragraph 4.3.27 that you had also considered but rejected an OHL parallel route.
Next steps
At this stage we have four requests which will assist our further engagement with you. Please supply:
– evidence to demonstrate your compliance with the Holford Rules specifically rules 1,2,4,6 and 7 in respect of the proposed route
– evidence that you currently meet readiness criteria of the National Grid’s Gate 2 process, specifically that you have secured the land rights for the entirety of the pylon route
– a detailed summary of your engagement with National Grid including justification for the rejection of use of the existing Pelham to Burwell OHL and evidence for rejecting a route parallel to the existing Pelham to Burwell 400 kV OHL
– the location of the two 33kV OHL lines and three high pressure gas pipelines which you assess to constrain alternative connection and a summary of the technical issues that make these constraints insurmountable or technically unfeasible.
Please acknowledge receipt of this letter.
Yours sincerely,
N J Acklam
Nick Acklam
Reach Parish Council