This page is dedicated to the ongoing consultation regarding Eurolink/Lionlink and Walberswick Parish Council's part in that process

 

Latest Update - 1st April 2024

Lionlink - Walberswick Parish Council official response to the Environmental Impact Assessment Scoping Report

Walberswick Parish Council (WPC) has been invited as a Statutory Consultee to respond to the Environmental Impact Assessment Scoping Report (SR) for the proposed Lionlink (LL) project.   Walberswick, a pristine, historic village renowned as one of the top destinations for nature-based tourism on the Suffolk Coast, has been identified by NGV as one of its preferred landing sites and cabling routes for LL.

The WPC, with wide support from our village community, has focused its response on the sections of the SR specific to the landing site and the cabling route proposed for Walberswick.   This in no way suggests that WPC is supportive of any elements of the scheme nor the soundness of the SR, but rather that we are focusing our submission on the area we know best so as to assist in holding NGV fully to account.   

Most critically, we draw the attention of the PIanning Inspectorate to the fact that LL G2 site is in the very heart of Walberswick village. Despite being made aware of this during the pre-consultation stage, the Developer has chosen to submit a SR that misrepresents and downplays the location of G2 – known locally as Manor Field.  It is a gross oversight of LL not to state this positioning clearly.  As a result, LL has prepared a SR that is inadequate in terms of its approach to the potential impacts that need to be considered and resolved in relation to the Walberswick site. 

LL incorrectly states that the site is “south” of Walberswick Village.  In another section (6.3.45) it states that homes are located 5m “to the north” of the G2 landfall sites.  These are misrepresentations of reality.  Manor Field is within the village and, as such, directly abuts and is surrounded by homes not only on the north, but on the north, east and west -- including those within the village Conservation Area.  It is adjacent to a seasonal caravan park and camping ground at one corner.  G2 is also ringed on four sides by heavily used Public Rights of Way (PRoWs) that lead to the popular Walberswick swimming beach and that are part of nationally recognised walking trails that connect Dunwich, Walberswick and Southwold.  It is adjacent to, and will have to cross, highly protected SFA, SAC and RAMSAR sites.   There is no road access to the G2 site not because Manor Field is remote, but because it is a beauty spot that is an integral part of Walberswick village, accessed by PRoWs and by back garden gates of the houses on which it abuts. 

Because of this unique situation, we request that the inadequacies of the SR be challenged robustly in relation to the Walberswick G2 option.  LL states in 10.5.3 that “where it is not possible to avoid sensitive receptors, a number of measures will be embedded into the design to limit any effects.”  Specifically, LL says that “where possible, the proposed Onshore Scheme would be designed to avoid residential properties, community facilities and amenities as well as visitor attractions.”   We cannot understand why LL would have made such an inappropriate choice as G2 given that it directly contradicts its own stated design imperatives.  However, as LL has chosen to persist, then it must be compelled to Scope-In more impacts and, where impacts are Scoped In, should not be permitted to use “desk studies” for baseline data or to understand likely impacts.  Instead, LL must base its analysis on appropriate bespoke surveys, interviews and case studies.  The analysis should properly be done to cover a period of a year to take into account the differing seasonal impacts on the residential properties, amenities and attractions, particularly given that the basis of the Village’s economy is on year-round nature-based tourism.

Within this context, the remainder of our submission highlights by Chapter the specific areas of concern and where amendments are required. 

Chapter 3.  Assessment of Alternatives

The first step should be in relation to Chapter 3 of the SR that deals with the assessment of alternatives.  Given that LL has identified a preferred site in Walberswick that is within a residential area, with community amenities and visitor attractions, it needs to make much more transparent why they are dismissing more reasonable alternatives including an Integrated Offshore Grid, landfall at brownfield sites, or co-location with other interconnector and offshore projects.  There are sentences in the SR (such as 6.3.45) where LL admits that G2 is within 5m of residences.  Without much greater detail and transparency with respect to alternatives, it is impossible to determine whether there truly are no better alternatives to putting the landing site into the heart of a rural community surrounded by human and ecological receptors and within 5m of village homes.  

Chapter 4.  Legislation and Policy Overview

Table 4.1 references several local planning documents.  However, it leaves out the Conservation Area Appraisal and Management Plan for Walberswick and the Walberswick Parish Plan.   Walberswick Parish Council is also engaged in the process of a Neighbourhood Development Plan.  All these relevant documents must be used to better inform the EIA.   Walberswick documents can be provided to LL by the Parish Council.

Chapter 5.  EIA Method and Approach

Population size is a key element in impact analysis particularly on human receptors.   It is obvious from the SR that LL’s approach will not accurately reflect this impact in Walberswick if it relies solely on ONS census and other public source data. For the G2 site, it is essential that data and analysis is complete given that the site is within a residential area.  In addition to homes and ProWs which are within 5m, the tourist beach is only some 65m from the site.  Walberswick’s only main road, its village shopping, and many historically significant homes in the Conservation Area are within 100m of the landing site and because of its compact design, the majority of the village including playgrounds, village hall and all amenities are within 500m of G2. 

Walberswick has circa 350 homes.  About half are occupied by full time residents with others used by part-time residents most of whom stay in the village throughout the year but who are not likely to show up in ONS data.    Another portion of the residences are used as holiday lets many of which are large and therefore accommodate in excess of 10 guests.  There is also hotel accommodation at two pubs and camping and caravan grounds.   In addition to those who stay in the village, data available from the Parish Council in its pre-consultation submissions provides evidence that Walberswick has up to 200,000 day visitors annually coming by car and bicycle and on foot.   This means that the actual number of people staying in the village, and exposed to the impacts of LL construction, is many multiples higher than the census data and the preliminary population figures provided in the SR would suggest.  Given that LL is breaking its own design requirements by suggesting a landing site within a residential area and within close proximity to major recreation and tourism sites, it must be required to collect correct data on human receptors beyond ONS data sources in order to get an accurate and more granular baseline.  This is particularly essential for ensuring proper baseline data in areas that study impacts on human receptors including Chapters 6, 10, 14, 15 and 16.     The Parish Council can assist LL in providing some of the relevant data necessary to make a more accurate assessment and analysis.  

Chapter 6. Air Quality

We note that the SR scopes in most impacts, but the choice of language appears to downplay the potential risks.  This is notable in section 6.6.9 that states: the risks from the impact of construction dust on ecological and human receptors has been scoped into the EIA on the basis that there is potential for significant effects due to proximity of both ecological and human receptors to the proposed Onshore Scheme. However, the impacts will unlikely be significant with the implementation of suitable mitigation measures.   We believe that “lack of significance” does not reflect the reality in Walberswick given that G2 selection is contrary to LL’s statement in 6.5.3 that “The design of proposed Onshore Scheme will seek to avoid sensitive features such as larger residential areas and ecological designations.”  As the nearest residences are a mere 5m from the landing site, and the most protected of ecological sites similarly border the landfall construction site, then LL fails in implementing its design measures making its Control Measures listed in 6.5.4 likewise insufficient.  Therefore, in all its Air Quality assessments that are Scoped-In, it should be assumed that the impacts at G2 could be significant and therefore techniques for assessment must always take a precautionary approach and be at the highest possible standards and sensitivity.   For example, meteorological impacts must be assessed for the actual conditions present seasonally and in relation to the impact, for example, of the common occurrence of storms and very high winds that impact the G2 site whilst not necessarily present inland. 

Chapter 8.  Ecology and Biodiversity

Given the sensitivity of the G2 landing site and parts of the cabling route, we feel that the SR is deficient in its approach to ecology and biodiversity.   We set out below our chief concerns in relation to this section of the SR: 

Within Chapter 8, the issue of undertaking a Habitats Regulations Assessment (HRA) is assigned two small paragraphs (8.2.2 & 8.7.20); yet crossing the Walberswick-Minsmere SPA, SAC and Ramsar sites (International Sites to which HRAs relate) is unavoidable at the G2 landing site and terrestrial cabling route. Paragraph 8.7.20 acknowledges that Stage 2 of an HRA (Appropriate Assessment: AA) will be required.  The AA could well demonstrate a likely significant effect on the International Sites that would require a derogation from the Habitats Regulations (2017) (as amended).  Test 1 of the Derogation states the following:

Test 1: Consider alternative solutions

To allow a derogation you must decide that there’s no alternative solution that would be less damaging to the site.  You should work with the proposer and consider whether any alternative solutions are available. This might include considering whether the proposal could:

·       happen at a different location

·       use different routes across a site

·       change its scale, size, design, method or timing

As pointed out in our comments to Chapter 3, currently only two alternative solutions are put forward -- the Walberswick and the Southwold landfall sites and associated cabling routes. There are clearly other viable alternatives, such as an offshore grid, brownfield landfall, co-location of cables, etc and more information is required to be able to comparatively assess the ecological impacts of each viable alternative. To date, this evaluation has simply been presented in a cursory manner. As this will need to be properly and fully evaluated within the HRA, the absence in the SR of geographical scope and methods by which this will be done should be corrected and the methodology included.  

  • We note that the evidence requirements for the AA stage still needs to be agreed with Natural England under the Discretionary Advice Service (DAS) agreement to produce an Evidence Plan. Yet the SR gives no details of what this Evidence Plan may include, or when, where and how the Evidence Plan will be made available for consultation.  This omission makes the scoping of the HRA within Chapter 8 woefully inadequate and this needs to be included in the SR.  Specifically, it should set out how and where the Evidence Plan information will be disseminated.
  • An overarching issue in this Chapter is the lack of detail on survey methods to be employed. We understand that the survey scope and design will be refined as the project advances in consultation and agreement with Natural England (per 8.2.3, 8.3.58 & 8.7.5). However, we would expect that other statutory consultees, including the parish councils, be kept informed of any decisions as they arise. The SR is inadequate in this regard and specifically how and where this information will be disseminated should be added. 
  • The geographical scope of LL’s ecological assessment (Section 8.3) is inadequate to allow a full and satisfactory HRA/AA to be carried out.  We suggest that there be a re-evaluation of the Ecological impact Assessment (EcIA) and HRA scope and that this be strengthened in the SR.
  • The SR is inadequate in terms of the details on the methods and locations of surveys to allow full and proper assessment. In particular, more details need to be added to the SR for target bird species surveys (8.37, section 8.3.47), otter surveys and invertebrate surveys.  If this information is not currently available, then details of specifically how and where this information will be disseminated should be added to the SR.
  • The SR is incomplete in presenting the qualifying species for the SPA and Ramsar nor is this topic consistently presented throughout the SR.   Species such as little tern, avocet and nightjar have been omitted in parts (Table 8-2; paragraphs 8.3.44 & 8.3.45). This omission needs to be corrected. The suite of qualifying Annex 1 species (Table 8-2)  now includes woodlark as detailed in the following SPA factsheet: https://assets.publishing.service.gov.uk/media/5dc1504be5274a4aa00642a2/Minsmere-Walberswick_SPA_factsheet.pdf This update, however, is not reflected in the SR and needs to be updated throughout with survey scope and methods adapted accordingly.
  • No specific mention is made to several key rare and notable invertebrate species occurring within the Walberswick cabling route boundary (see Paras 8.3.88-8.3.92).  This includes wainscot moth species group, spotted-wing antlion Euroleon nostras, and starlet sea anemone Nematostella vectensis. These species need to be scoped in as they may be affected by impacts on the water quality and levels, by trenching and tunnelling impacts, and by exacerbated coastal erosion. 
  • We note that artificial lighting at night (ALAN) impacts have been scoped out as LL claims that only emergency lighting will be implemented (8.54). However, given the highly sensitive nature of the G2 site and the possibility that ALAN is not properly documented in the Construction Management Plan, these impacts should be scoped-in as a precaution.  
  • Chapter 8 does not identify contamination or coastal erosion as being within the scope of the terrestrial ecology and biodiversity assessment. Yet trenching of the landfall section between the landfall site G2 and offshore would inevitably lead to a high risk of contamination and erosion impacts. Even where horizontal directional drilling (HDD) is implemented, we understand there are associated risks that can lead to water level disruption and surface contamination due to cracking and leakage of mud-slurry lubricating material, and possible indirect coastal erosion impacts.  We are particularly concerned by the impact the proposal will have on the Annex 1 habitats and species through direct and indirect disturbance, coastal erosion and hydrological disruption potentially leading to changes to the coastal habitats, salinity and water levels, which are known to affect key protected features. We note that these issues are discussed in Chapter 18 and in a separate technical report (para 9.6.2).  However, given these potential impacts could occur within the Walberswick landfall zone, they need to be addressed and scoped in at Chapter 8

Chapter 10. Health and Well Being

Without repeating statements made in other sections of this response, we note that effort needs to be made to improve the baseline data and population information stated in this chapter. (see comments to Chapter 5).    In addition, because the G2 site does not conform to LL design parameters in its location within the village, then the greatest level of precaution should be taken in relation to health and well-being of those impacted.  Therefore, we believe that it is incorrect to scope out the disturbance or release of contamination in soil or groundwater that can result from construction activities given their potential to affect health. We believe that it is not sufficient to Scope out this impact by saying in Table 10-1 that “best practice control measures set out in a CEMP or Outline Code of Construction Plan (CoCP) will prevent uncontrolled releases of contamination. With these measures in place, the risk of exposure to soil and groundwater contamination will be prevented and adverse health effects will be avoided.”   As the location of G2 already appears to violate best practice, then we believe that it is incumbent on LL to recognise that there is the possibility of exposure given the extraordinary closeness of residences and recreation areas.  This possibility must be of overriding concern and therefore the impact must be Scoped-in

Chapter 12.  Hydrology, Hydrogeology and Drainage

We note that the SR does not contain any consideration of coastal flood risk and/or the effect of LL (onshore and offshore) on natural sea defences such as coastal margin habitats and saltmarsh.   These features are very much prevalent in Walberswick.  Moreover, as there is high probability and high potential magnitude of coastal flooding events here, this appears to be an oversight and needs to be scoped in as a likely significant effect for further assessment.   

Chapter 14.  Noise and Vibration

The siting of G2 in the heart of the village means that EIA related to impacts of Noise and Vibration need to be particularly robust.  In 14.5.3, LL again states that its design measures will be such as to select sites to minimise the number of human receptors and yet, by choosing G2, LL has failed to do so.   In 14.7.22, LL states that where residential receptors are identified within 1000m of any new noise sources, an assessment will be undertaken in line with BS 4142.  It should be noted that the entire village of Walberswick is within this distance from the landing site including all shopping, pubs, village hall, residences, village green, playgrounds and summer camp, playing fields, PRoWs and heavily used beaches.  

Section 14.3.3 suggests that a study area of 300m around the Onshore Scoping Boundary is necessary to assess construction noise impacts based on precedent from other projects

and the limitations of prediction methods beyond this distance as noted in the British

Standard BS5228.   As above, it should be noted that Walberswick’s main shop, pubs, residences including listed buildings, beaches and PRoW easily fall within this boundary. 

Finally, for potential construction vibration impacts, the SR states that an area of 100m is considered to be sufficient to assess potential construction vibration impacts.  Because of the inappropriateness of the G2 landing site and the early stages of the cable route, 100m takes in, among others, a large number of homes within the Conservation Area, the main village shops and holiday lets, all of which will be directly susceptible during construction and recovery and must be studied to assess impact and mitigation. 

Chapter 15.  Transport and Traffic

This chapter is particularly lacking in candour in relation to the constraints of the Walberswick G2 site and cabling route and therefore has erroneously scoped out some essential elements.  Specifically, LL states in 15.4.2 that adverse impacts could arise from inter alia: “increased traffic volumes and congestion due to construction traffic; abnormal load deliveries and temporary diversion of traffic due to road closures/diversions.”    In 15.5.4, it states that “where road closures are required, the period of the closure would be kept to a minimum and diversions would be via the most appropriate alternative route.  Access to properties would be maintained at all times.”

However, the SR fails to note and address that Walberswick is only accessible by vehicle via a single road.  Therefore, LL cannot keep the commitments it makes in 15.5.4.  Whilst Table 15.2 scopes in the effect of construction traffic on road users and the general public arising from construction, it has incorrectly scoped out the impact of closures/diversions for abnormal load access or other incidents that would close the road.  LL cannot scope out these impacts by claiming that they will occur in off peak times or that alternatives will be made available.  The fact is that there are no alternative routes to Walberswick and therefore any closure, at any time of the day, planned or unplanned, will deny access to emergency services and deliveries and would potentially deny residents access to their homes and/or visitors ability to leave.  Given this extremely precarious and dangerous situation, all impacts related to potential road closures must be Scoped-In for G2 and evidence provided for safe mitigation

Chapter 16.  Socioeconomics, recreation and tourism

The approaches proposed in this chapter are some of the weakest in the SR and are particularly inappropriate to the proper assessment of the Walberswick G2 proposal.  The weakness in the proposed assessments appears connected to LL’s failure to properly identify G2 not only within a village, but within a village whose economy is nearly entirely based on nature-based tourism around its beautiful natural beach, extensive walking trails, pristine landscapes and wildlife, quaint village life and beautiful views.   In fact, PRoWs at the G2 site are particularly prized as they provide the best viewing points for the largest continuous stand of reedbeds in England and Wales (part of the Minsmere-Walberswick Ramsar site). 

We have attempted below to point out the most critical shortcomings that need to be addressed:

  • 16.3.10 improperly fails to recognise socioeconomic recreation and tourist (SRT) assets that fall easily within 500m of the landfall site and cabling route.  These include tourism and recreation-based businesses, visitor attractions, playground, heritage assets, beaches and PRoWs.  These need to be included and factored in assessment of SRT impact.
  • Table 16-5 has left out several important community facilities for Walberswick including the Village Hall, the Walberswick Beach, PRoWs , and camping sites.  This oversight needs to be corrected and factored into assessment of SRT impact.
  • Table 16-8 scopes out the effect of construction on residential property (both direct and indirect). This is clearly incorrect given that G2 is surrounded by homes within 5m of the site.  Similarly, it is wrong to scope out the effect of construction on tourist accommodation and businesses because of the exceptionally close proximity (for example within the 100m and 500m buffers) of accommodation and natural attractions.  Therefore the SR should be amended to Scope-IN these impacts.
  • The impact on tourist accommodation of construction workforce has been scoped out on the argument that workers will come from nearby.  That is not at all likely given the low unemployment in the area, the competing energy projects including Sizewell C and the generally older demographic of the area.  Therefore, this impact should be scoped in for the LL proposal as a whole.
  • Given these and other shortcomings in the quality of the SR in relation to SRT, it is incorrect for LL to suggest in 16.7.1-3d that it can adequately assess impacts based on desk studies.  Given the inaccuracy of its information in the SR pointed out above and the very significant potential for the scheme to produce negative effects, the assessment needs to make use of surveys, interviews and other bespoke means to properly baseline, assess and mitigate

Conclusion

In summary, among other shortcomings, we believe that the selection of the G2 site makes it impossible for LL to meet the standards and commitments it has set out in the SR.  This argues for ensuring that LL proceeds with the utmost precaution by maximising throughout the EIA what is “Scoped In” and, in full acknowledgement of the inappropriateness of the Walberswick site, fully investigates, analyses, justifies, and demonstrates the ability to mitigate the impacts of its proposal.

 

---------------------------------

9th October 2023

 

Lionlink - Draft Parish Council response to the non-statutory Consultation

 

Below you will see the draft Walberswick Parish Council response to the non-statutory consultation on Lionlink which is currently underway. This draft paper will form part of the agenda for the next Parish Council meeting which will be held on 16th October in Walberswick Village Hall at 7PM. At that meeting it is anticipated that the draft will be finalised, then submitted. A .pdf of this same document can be found here: Walberswick Parish Council - Lionlink draft response

The most important thing you can do now is to write your own response to the consultation, and please feel free to use any of the points made by the Parish Council or not; it is entirely up to you. A separate article has been written, advising who to send your response to and how it should be formatted and this can be seen here: Where to send Lionlink responses (note: this will open in a new window)

Response of the Walberswick Parish Council - Non-Statutory Consultation for NGV MPI Lionlink

Walberswick now has two potential landing sites for Lionlink (formerly Eurolink).  As the elected Parish Council, we are writing on behalf of Walberswick residents, businesses, and visitors to object in the strongest terms to the proposal of using Walberswick as a landing site and a cabling route on the way to a proposed substation near Friston.  

Our consultation response deals with NGV’s proposals in three parts.  First, we comment on the quality of the non-statutory consultation to date.  Second, we make the case that NGV should recognise that Walberswick is wholly inappropriate as a landing site.  This is true for both the original site (G) and the second site (G2) added in the current non-statutory consultation. Third, we point out that we expect NGV to consider a much broader and more appropriate approach to landing sites and sub-station construction than its current set of proposals, all of which fall within and/or threaten green field, AONB, SSSI and protected reserve locations in a concentrated area of coastal Suffolk.  

Section I:   Quality of the Non-Statutory Consultation

As a Council, and based on the feedback from our constituents, we have found the approach taken by Lionlink in this non-statutory consultation to be inadequate at best and deliberately vague and disingenuous at worst.  For example, we were appalled by Lionlink’s consultation literature that stated that Lionlink had taken into account previous consultation responses by adding a second landfall site in Walberswick!  Rather than ‘listen to’ and take account of our concerns, Lionlink instead doubled down on the inappropriateness of the initial site selection by (i) keeping the first site (G) which should have been discarded and (ii) adding yet another site in Walberswick (G2) which brings the proposed landfall construction even deeper into the village.   The pre-consultation briefing materials and maps were extraordinarily unclear about Lionlink’s plans, and despite the efforts of the staff at the consultation events, clear answers and rational reasons for Lionlink’s proposed plans for coastal Suffolk were not forthcoming.  One such example is that the literature mentions the need for a haulage road, but neither the documentation nor the Lionlink representatives at the consultation event, could shed any light on where such a road would be located nor why and for how long it would be needed.   Such an approach simply underscores the impression of disregard that Lionlink and National Grid have for the impacted communities and the protected habitats and increases the distrust that a proper, transparent and justifiable investment decision will be reached. 

Section II:  Inappropriateness of Walberswick as a Landing Site

 We would have expected Lionlink to acknowledge that its own lack of understanding of Walberswick’s geography led it to inappropriately identify the initial site (G) that has no land access for construction equipment, would require the taking of land held in trust by Walberswick Common Lands Charity and would remove nearly half of all the Village’s parking during construction.  We find it remarkable that Lionlink has not removed site (G) from consideration, although its decision to choose a second site in Walberswick is, presumably, a tacit acceptance that site (G) has no real possibility of being taken forward.   To remind Lionlink why (G) is wholly inappropriate, the response of Walberswick Parish Council to the 2022 non-statutory consultation can be viewed here: http://walberswick.onesuffolk.net/assets/Parish-Council/Agendas/Agendas-2022/December-2022/DRAFT-consultation-response-eurolink.pdf

The remainder of our response is related to the proposal for G2 (known locally as Manor Field) that was introduced in this second non-statutory consultation.   In summary, the WPC wholly rejects Manor Field as a possible landing site.  This is on the basis that this proposal would bring the construction site into the very heart of the village, to a location surrounded by homes including those that are within the village’s conservation area, that is bordered by protected habitat, that is adjacent to  some of the most heavily used footpaths by residents and visitors alike including those that provide access to the Walberswick beach,  and that would cause maximum disruption to the village’s amenity and tourist driven economy. 

A .          Environmental Concerns 

Walberswick has a unique and delicate coastal environment.   Specifically, a landing on Walberswick and/or under the beach and subsequent drilling and cable laying to reach a sub-station inland and to the south would impact nearly all of following designated and protected sites:

  •  Suffolk Coast and Heaths AONB
  • Minsmere-Walberswick Heaths and Marshes SSSI
  • Suffolk Coast National Nature Reserve
  • Walberswick Salt Marshes
  •  Minsmere-Walberswick Heaths and Marshes Ramsar & SPA
  •  Minsmere to Walberswick Heath and Marshes SAC.

In short, it would be difficult for NGV to find a location that has more environmental protection designations.   To emphasise the catastrophic impact that Lionlink construction would have on flora and fauna in and around Walberswick, we use the example of the protected Marsh Harriers which were saved from extinction in the UK by a program launched in RSPB Minsmere. 

Marsh Harriers are included as part of the important assemblage of rare breeding birds on the Minsmere – Walberswick Ramsar site.    The harriers depend heavily on reedbed habitat (including Walberswick) located to the north of the Minsmere New Cut (a sluice boundary at the southern end of RSPB Minsmere) for breeding but are known to also forage widely for food over the Minsmere South Levels and also the EDF Energy estate, including Sizewell Marshes SSSI.  The difficulty of mitigating the impact that the construction of Sizewell C will have on Marsh Harriers was one of the many concerns of the Inspection Panel that recommended against the building of the nuclear plant.  An important consideration in the construction of Sizewell C was whether it could mitigate its impact on Marsh Harriers.  It was ultimately argued that the protected and undisturbed Minsmere-Walberswick Heaths and Marshes Ramsar & SPA would serve as the area of breeding protection for the Harriers.  Additional land was then identified around Westleton to try to replace the harriers’ foraging areas lost to Sizewell C.  These areas were noted in NGV’s Sealink documentation as needing to be avoided in determining best locations for cabling and sub-station construction.  Therefore, it would seem impossible for Lionlink to now propose disturbing the Marsh Harriers habitat north of the Sizewell C site, including both Walberswick and Dunwich where the Harriers breed and forage.   Marsh Harriers hunt regularly in the skies above the proposed landing site at Manor Field.

Walberswick is not only home to Marsh Harriers, but to more than a hundred other species of birds drawn to this irreplaceable habitat.   The proposed G2 landing site is in the centre of our village where some 130 different species of birdlife have been recorded by bird-watchers in Walberswick’s bird hide.  On two recent “Birdsong Walks” in the summer of 2023, 63 bird species were spotted in and around the area of proposed construction of the landing site and cabling. 

The constantly changing coastline and beach at Walberswick is extremely unstable and susceptible to erosion and the shape and surface of the beach is in constant flux. During many regular high tides, and nearly always during high tides when the weather is poor, Walberswick’s shingle and sand beach is completely submerged up to the marram grass sand dunes and the marsh that lies behind them.   To reach the sea from Manor Field would require extensive drilling to cross under the Dunwich River, the marshes, reed beds, the sea defence sand dunes and out into the sea.   The relatively long trip to the sea, across and/or under this highly sensitive and protected habitat, along with the inevitable noise and vibration this would entail, seems to us wholly inappropriate and unjustifiable when many better options are available. 

 B.        Logistical and Safety Concerns

 There is currently no road access for construction vehicles and workers to reach Manor Field, meaning that Lionlink would have to construct a haulage road to the site through or around existing homes causing further destruction of habitat and undercutting the Conservation Area.  The inability of Lionlink to state how this site would be reached further indicates how ill-conceived its proposal is.   It is also worth noting that even before reaching any proposed haulage road, access to the village would have to be via the sole road into Walberswick (the B1387).  There is no other way in or out of Walberswick and residents are rightly alarmed by the impact that heavy equipment and worker vehicles during construction would have.  The B1387, (which becomes “The Street” when it enters the village settlement) has no pedestrian pavements, street lighting or crossing points and is shared by cars, bicycles, pedestrians and horses. The remainder of the streets surrounding Manor Field consist of unimproved, single lane tracks that are more heavily used by pedestrians and cyclists than by vehicles. Suffolk Highways acknowledged that the narrowness of The Street and its extremely heavy shared use by non-vehicular traffic justified making Walberswick one of the very few 20 mph areas in Suffolk.  Given this situation, we believe that the safety risks associated with putting a landfall construction site in Walberswick village are overwhelming.

C.        Impact on Homes and Businesses   

Walberswick’s economy is built around tourism drawn to the village by its beautiful natural beach, its areas of unique environmental interest, direct access to nature, our dark skies and historic character of the village.  Two pubs, three cafes, pub accommodation, 2 summer camping sites, dozens of self-catering businesses and several shops are all supported by the year-round tourist trade.   The noise, dust, vibration, light-pollution, increased traffic and destruction of habitat that would be associated with the Manor Field landing site would disrupt everything that underpins the Walberswick economy.    Subsequent drilling and trenching would lead to additional closures of footpaths heavily used by tourists and residents year-round.    In 2021, statistics were shared with Suffolk Highways demonstrating that in excess of 100,000 people walk through Walberswick and its footpaths every year.   Evidence from the purchase of car park tickets shows that in 2021, over 51,000 cars parked at the Walberswick car parks.  With an estimate of 4 passengers per vehicle, that would indicate that up to some 200,000 day visitors to Walberswick could be lost.  This does not count those who stay overnight, live in the village or walk to or take the rowing ferry from Southwold to Walberswick.    Whilst summer is the busiest time, Walberswick is a year-round destination for day and overnight visitors.   In short, if Lionlink was to land in the middle of Walberswick village at Manor Field, the impact would be catastrophic for every village business.  No business could realistically be expected to survive such a loss of tourist trade during Lionlink construction.

 D.        Loss of Amenity

The construction phase of Lionlink and ongoing maintenance required would have a hugely negative impact on those living here.  We note that it is highly unusual to put the cable landing and main construction site squarely in the midst of where people live, work and walk and none of the proposed landing sites except G2 propose to do this.  Manor Field is surrounded on three sides by homes including those in Walberswick’s Conservation Area.  It is also bordered by a caravan and camping ground.   It would be impossible for those living so close and fully exposed to the site to be well protected from the noise, vibration, dust, light pollution, traffic and debris associated with the project, as well as to the need to construct or bring in other infrastructure (such as electricity, water and sanitation) to support the construction site itself.

Section III:  Need to Consider Alternative Sites and Cumulative Impact

 The objection of the Parish Council to the Lionlink proposal extends beyond our Parish boundaries.  It is the view of our Council, as it is by many others locally and nationally, that NGV has not properly considered alternative sites away from the Suffolk coast.   We understand that locating grid infrastructure offshore is a common practice throughout continental Europe and there is no consideration of this in NGV’s proposals (although it does show an off-shore substation on the Dutch side).  Nor does NGV consider taking its cable ashore on the plentiful brownfield sites either further south or to those further north.   Since the power that Lionlink would be carrying from the Netherlands is not focused on Suffolk, we question why NGV is not considering bringing its cable on land to areas of the UK where it is intended to be consumed.  Lionlink should also be considering bundling its cable with other off-shore cables to come into brownfield sites.  Lionlink has not proven why it is determined to use greenfield sites in coastal Suffolk but not considering brownfield sites at Sizewell which are already industrialised. 

Finally, we note that NGV has not considered the cumulative impact that the multitude of energy project proposals including Sizewell C, the Friston substation for EA1 and EA2, Sealink, Nautilus and others would have on the environment and on the area’s inadequate transport infrastructure.  Taken together, these projects would have a devastating impact on the lives of the people who live here, on local businesses and community amenity.   Even in its own self-interest, NGV should recognise the huge risks of cost and time over-runs that its own project would face in trying to bring its cable and substation onshore in greenfield, protected sites on a very small section of Suffolk coast.  There are many far better alternatives.  

 

-------------------------

21st September 2023

 

Lionlink - reminder and guidance for 23rd September Consultation

23rd September is a very important day in the non-statutory consultation process for Lionlink which is now underway. It will take place in Walberswick Village Hall between 10AM and 4PM and if it follows the format of previous ones will be a "drop in" event where you can see and receive details on the proposals as they relate to Walberswick and, most importantly, ask questions of the actual project team

Please attend! "Footfall" at these events is a key measure of engagement for the organisers, so please go in person, for as long or short a time as you like, and encourage all your family, friends and neighbours to do the same.

Please also take the opportunity to inform yourselves as fully and as factually as possible on what is being proposed, so you are in the best position to eventually compose your own response.

There are of course many, many questions you may wish to ask, among which may be:

  •  What does "potential for a haul road" actually mean? Where will it be? How big will it be? Will it be left behind afterwards? What will be hauled on it?
  •  How does the Lionlink Interconnector get from the beach to the newly proposed G2 "land fall" site?
  •  Is G2 now the only proposal for Walberswick or is G still also a proposal?
  •  Where are the alternative plans for not landing on the Heritage Coast at all, but travelling under the sea to where the power is actually needed?
  •  Why is Walberswick the only proposal with a building site right in the middle of the village itself

(Clearly these are not the only questions that need answering and are only for guidance)

By close of play on Sunday 24th September the Parish Council will publish the email addresses of everyone we recommend sending your consultation response to, along with guidance on how to give yourself the best chance they will actually open/read it. The advice from the Parish Council remains however not to submit your consultation response until you have gathered as many facts as possible - there is no advantage in submitting early and you risk missing the opportunity to respond to facts that emerge between now and the end of October. The consultation is open for responses until 3rd November

 

-------------------------

 

8th September

 

Lionlink (formally Eurolink) consultation documents now available

 

National Grid have now published the consultation documents regarding a new proposed Landfall site in Walberswick and a new cable route in Southwold.

 

All the documents can be seen by following this link: https://www.nationalgrid.com/national-grid-ventures/future-developments/lionlink/consultation-materials

 

Details are still scarce, but the new proposed landfall site is half way up the village, between Millfield Road and Stocks Lane - this can be seen on this map: https://www.nationalgrid.com/document/150436/download

 

It is very important that as many people as possible attend the consultation day that will be held in Walberswick on 23rd September and make their views known; details can be seen here: https://www.nationalgrid.com/document/150446/download

 

Lionlink will also be an agenda item at the next Parish Council meeting on 11th September, which all members of the public are welcome to attend either in person or via Zoom; details of this meeting can be seen here: http://walberswick.onesuffolk.net/assets/Parish-Council/Agendas/Agendas-2023/September-2023/Agenda-11th-September-2023-FINAL.pdf

 

The Parish Council will (of course) be making a formal response on behalf of the village as part of the consultation, which closes on Friday 3rd November, but everyone is also very strongly encouraged to also make their own submissions - we would advise to only do this after the consultation event on 23rd September as you will then have all possible facts available when expressing your views

 

All Parish Council updates on this topic will be posted to this website, along with the Parish Council's own dedicated page, which can be seen here: http://walberswick.onesuffolk.net/walberswick-parish-council/eurolink/

 

----------------------------------------------

 

25th August

 

Lionlink (formally called Eurolink) – consultation day in Walberswick on Saturday 23rd September 2023: 10AM - 4PM

 

Many will recall that in November/December last year there was a “non-statutory consultation” regarding the proposed Eurolink cable project, including proposed landing sites in both Walberswick and Southwold

 

The Eurolink Multi-Purpose Interconnector project has now been renamed Lionlink but is still the same project. We have recently become aware that following the previous consultation some changes have been made to the proposals made for both Southwold (a new cable route) and Walberswick (a new landing site). As a result of this there will be a new round of “supplementary consultation” which will start on the 8th September. This time (following strenuous complaints made by the Parish Council among many others) there will be a consultation day in Walberswick itself, which will happen on Saturday 23rd September 2023 in Walberswick Village Hall. The document outlining the above can be viewed here: Non-statutory consultation - August 2023

 

The LionLink project team will begin publicising the event on 25th of August by mailing a leaflet to all households and businesses in the consultation zone

 

This consultation gives residents a chance to share their views on both the new and original proposals. More details on these options will be made available to the public when the consultation begins on the 8th September 2023.

 

This supplementary consultation will follow a similar format to one in 2022 - inside the village hall will be a series of banners which have all the details on the LionLink project proposals, including more detail on the alternative landfall site and underground cable corridor. At the front door of the venue the project team will also be handing out a briefing pack and an FAQ pack with further detail on the project. During the event attendees can move around the room and read through the proposals on the boards. The project team will also be on hand in the middle of the room to answer questions.

 

As soon as the Parish Council have any more details we will publish them here and this will be a significant agenda item at the next Parish Council meeting on September 11th, which members of the public are welcome to attend

 

Please put 23rd September, 10AM - 4PM in your diary and attend if you possibly can, as this is a significant way for us to demonstrate the feelings of the village to this project

 

----------------------------------------------

 

15th December

 

Eurolink consultation - final WPC submision and where to send your own responses

 

WPC submitted its formal consultation response to NGV Eurolink on 14 December, which can be seen below.  People should feel free to use their own words and/or to draw from the WPC input in their own responses.  The most important thing is that we need EVERYONE to do their part and write in to the consultation.  Unless NGV hear from us, they will not know the depth of objection - the deadline is 18 December.

Where to send it:

NGV - this is by far the most important place to send it; email address: info@eurolink.nationalgrid.com

Our elected officials - After writing to NGV, please also write or forward your consultation response to our elected officials (the same submission is fine).  This should include MP Therese Coffey, Suffolk County Cllr. Richard Smith and the Deputy Leader of the East Suffolk Council, Cllr Craig Rivett who has been delegated responsibility for Eurolink.  Note that ESC has not taken a decision on Eurolink so it is important to encourage ESC to defend our communities.

 

Therese Coffey (our MP): therese.coffey.mp@parliament.uk

 

Richard Smith (our county Councillor): richard.smith@suffolk.gov.uk

 

David Beavan (our district Councillor): david.beavan@eastsuffolk.gov.uk

 

Craig Rivett (Deputy leader of ESDC): craig.rivett@eastsuffolk.gov.uk

 

Most important for all the above is to only put one name in the "To" box of the email, otherwise it may not get read, so please do each as a separate email

 

Please feel free to also copy the Parish Clerk into any of your responses: walberswick clerk@gmail.com

 

----------------------------------------------

 

Approved by Walberswick Parish Council 12 December 2022

 Response of the Walberswick Parish Council

Non-Statutory Consultation for NGV MPI Eurolink

 

Walberswick beach is one of the proposed landing sites for the MPI Eurolink.  As the elected Parish Council, we are writing on behalf of Walberswick residents, businesses, and visitors to object in the strongest terms to the proposal of using Walberswick as a landing site.  

 

Our consultation response deals with NGV’s proposals in two parts.  First, we make the case in Section 1 that NGV should recognise that Walberswick is wholly inappropriate as a landing site and that it should, therefore, exclude it from further consideration.  Second, in Section 2, we point out that we would expect NGV to consider a much broader and more appropriate approach to landing sites and sub-station construction then its current set of proposals that all fall within and/or threaten green field, AONB, SSSI and protected reserve locations in a concentrated area of coastal Suffolk.  

 

1 Inappropriateness of Walberswick as a Landing Site

Through our participation in webinars and visits to the consultation exhibits, it quickly became clear that NGV knows very little about Walberswick.  Its desk study missed a plethora of information that would have discounted Walberswick as a potential landing site.   The information set out below should serve to inform NGV. 

A) Environmental Concerns

Walberswick has a unique and delicate coastal environment.   Specifically, a landing on Walberswick beach and subsequent tunnelling and cable laying to reach a sub-station inland and to the south would violate nearly all of the following designated and protected sites:

  • Suffolk Coast and Heaths AONB
  • Minsmere-Walberswick Heaths and Marshes SSSI
  • Suffolk Coast National Nature Reserve
  • Walberswick Salt Marshes
  • Minsmere-Walberswick Heaths and Marshes Ramsar & SPA
  • Minsmere to Walberswick Heath and Marshes SAC.

In short, with the exception of RSPB Minsmere, it would be difficult for NGV to find a location on the Suffolk coast that has more environmental protection designations.   To emphasise the catastrophic impact that Eurolink would have on flora and fauna in and around Walberswick, we use the example of the protected Marsh Harriers which were saved from extinction in the UK by a program launched in RSPB Minsmere.  Marsh Harriers are included as part of the important assemblage of rare breeding birds on the Minsmere – Walberswick Ramsar site.    The harriers depend heavily on reedbed habitat (including Walberswick) located to the north of the Minsmere New Cut (a sluice boundary at the southern end of RSPB Minsmere) for breeding but are known to also forage widely for food over the Minsmere South Levels and also the EDF Energy estate, including Sizewell Marshes SSSI.  The difficulty of mitigating the impact that the construction of Sizewell C will have on Marsh Harriers was one of the chief concerns of the Inspection Panel that recommended against the building of the nuclear plant.  (BEIS, however approved the DCO anyway overriding the recommendation of the Inspection Panel.)  An important consideration in the construction of Sizewell C was whether it could mitigate its impact on Marsh Harriers.  It was ultimately argued that the protected and undisturbed Minsmere-Walberswick Heaths and Marshes Ramsar & SPA would serve as the area of breeding protection for the harriers.  Additional land was then identified around Westleton to try to replace the harriers’ foraging areas lost to Sizewell C.  These areas were noted in NGV’s Sealink documentation as needing to be avoided in determining best locations for cabling and sub-station construction.  Therefore, it would seem impossible for Eurolink to now propose disturbing the Marsh Harriers habitat north of the Sizewell C site, including both Walberswick and Dunwich where the Harriers breed, which would entirely undo the Sizewell C Marsh Harrier mitigation plans.

 

B) Logistical Concerns

There is currently no road access for construction vehicles of any kind to reach the proposed Walberswick landing site.  Reaching the shore is either by a small wooden footbridge and footpath through marshy terrain and over dunes to the beach or via a very narrow bridge (less than one lane) at the end of a gravel track that can carry only a single passenger car at a time.  The load limit on this bridge and its narrowness mean that it cannot physically carry lorries.   From there, only a footbridge through marshy land and then a walk over the top of the dunes does one reach the beach.   The narrow bridge is owned by the Environment Agency and protects a sluice flap under it that separates sea water from the brackish marshes behind.   The Environment Agency has already informed the Walberswick Common Lands Charity (the landowner) and the Walberswick Parish Council that the bridge may be unstable even for future passenger car use.  The EA is looking at alternative means for accessing and maintaining the sluice flap.  Therefore, NGV would have no means of accessing the proposed landing site.

 

It is worth noting that even before reaching this small bridge, access from the sole road into Walberswick (the B1387) is by a narrow single lane dirt track that is bounded by an Environment Agency sea wall protecting the marshes to the south and hedges that separate several private homes from the track on the north.   Large construction equipment would be unable to realistically navigate this track even if there was a bridge capable of handling the load. 

 

The constantly changing coastline and beach at Walberswick would be another challenge for using this as a landing site.  The coast is extremely unstable and susceptible to erosion and the shape and surface of the beach is in constant flux. During many regular high tides, and nearly always during high tides when the weather is poor, Walberswick’s shingle and sand beach is completely submerged up to the marron grass sand dunes and the marsh that lies behind them.   Even the car parking area, proposed for construction support, is highly susceptible to flooding when the sea over tops the dunes especially during winter and spring tides.   We would not think that such conditions were useful in managing construction timelines and costs.  There are no electric connections to this area. 

 

C) Impact on Businesses

Walberswick’s economy is built around tourism drawn to the village by its beautiful natural beach, its areas of unique environmental interest and the tranquil and historic character of the village.  Two pubs, three cafes, pub accommodation, 2 camping sites, dozens of self-catering businesses and several small shops are all supported by the year-round tourist trade.   Walberswick beach is small and a large portion of it would be cordoned off as a construction zone.  It would be impossible to walk along the beach from Walberswick towards Dunwich (part of the designated Suffolk Coastal Path) because the beach would be cut in two by the cable landing site.   Subsequent tunnelling would lead to additional closures of footpaths heavily used by tourists and residents year-round.   The bifurcation of the beach, the presence of construction equipment, tunnelling, noise and light pollution would destroy all the major elements that bring visitors to Walberswick.   In 2021, statistics were shared with Suffolk Highways demonstrating that in excess of 100,000 people walk through Walberswick and its footpaths every year.   Evidence from the purchase of car park tickets shows that in 2021, over 51,000 cars parked at the Walberswick beach car parks.  With an estimate of 4 passengers per vehicle, that would indicate that up to some 200,000 day visitors to the Walberswick beach could be lost.  This does not count those who use the beach but stay overnight, live in the village or walk to or take the rowing ferry from Southwold to Walberswick.    Whilst summer is the busiest time, Walberswick is a year-round destination for day and overnight visitors.   In short, if Eurolink was to land on the Walberswick beach, the impact would be catastrophic for every village business.  No business could realistically be expected to survive such a loss of tourist trade during Eurolink construction.

 

Finally, the Parish Council directs NGV to the separate submission made by the Walberswick Common Lands Charity (WCLC) which details the negative impact that the selection of this site would have on the Charity’s ability to fulfil its charitable purposes within our community, not least supporting individuals in need and hardship.  The Parish Council also notes that the land is held in trust by WCLC and that the trustees do not have the power to sell it.

 

D) Loss of Amenity

The construction phase of Eurolink and ongoing maintenance required would have a hugely negative impact on those living here.  The loss of access to the beach and to land along the cabling route during construction, and the long-term environmental damage left behind, will represent an extremely serious loss of amenity.  In addition, road access to Walberswick is limited to the B1387.   This B-road is shared not only by vehicles (including a large number of farm vehicles) but by a very large number of cyclists and pedestrians.  Walberswick has no roadside footpaths.  Walberswick has the rare designation in Suffolk as a 20 mph zone in recognition of the danger to pedestrians, bicyclists and vehicles of having to share this single roadway that has only single lane access in many places.   It would not be possible to safely accommodate the additional construction and worker vehicles associated with Eurolink. 

 

 2. Need to Consider Alternative Sites and Cumulative Impact

Section (1) above highlights the key reasons why Walberswick is an inappropriate site for cable landing and related cable laying.  However, the objection of the Parish Council does not end there.  It is the view of the Council that NGV has not properly considered alternative sites away from the Suffolk coast nor has it considered the cumulative impact that the multitude of energy project proposals including Sizewell C, the Friston substation for EA1 and EA2, Sealink, Eurolink, Nautilus and pending extension of power pylons would have on this one very small area of greenfield coast line and rural communities. We understand that locating sub-stations offshore is a common practice throughout continental Europe and there is no consideration of this in NGV’s proposals (at least on the British side).  Nor does NGV consider taking its Eurolink cable to the plentiful brownfield sites either further south or to those further north.   Since the power that Eurolink would be carrying from the Netherlands is not focused on Suffolk, why is NGV not considering bringing its cable on land to areas of the UK where it is most needed?  Nor has Eurolink shown why it is not considering sites around Sizewell which are already industrialised. 

 

Finally, Eurolink has shown no effort to consider the cumulative impact that its proposals would have on the communities in its path.  NGV has not acknowledged that its project would face tremendous logistical constraints in terms of workers, worker accommodation, road access, rail access, and water supply for the construction of its substation and cable laying.  Already, Sizewell C has admitted that its “local” work force will need to come from a distance of 90 minutes by car each day, that it will need to build dormitories for up to 5000 workers, that it will need to put thousands of additional HGVs on Suffolk’s roads every day for a decade or more.  Sizewell C will have no water source and will have to bring in some 40 water tankers each day from the start of construction and then will have to build a desalination plant to provide it with potable water.   The sub-station at Friston would add to this same picture making it inconceivable that more construction for Eurolink’s substation, cable routes and landing sites could be added to this mix in the same part of the Suffolk coast.  Therefore, in addition to all the environmental destruction, the impact on the local community, and the devastation it would cause to local businesses and community amenity, NGV should also recognise the huge cost and time delays that its own project would suffer from trying to bring its cable and substation onshore here.

 

----------------------------------------------

 

29th November

 

Meetings with MP Therese Coffey and East Suffolk Council:

 

On 25 November, at the request of a group of Parish and Town Councils, including WPC, MP Therese Coffey held a public meeting on Eurolink and Sealink in the Campsea Ashe Village Hall.   The numbers able to attend was limited by the size of the hall.  The MP had been offered the use of Snape Maltings but she declined it for the smaller venue.   From Walberswick, we had one Councillor, one WCLC Trustee and a member of the public in attendance. 

Dr Coffey explained that she was not supportive of the offshore cables and substations coming on shore in our area in an uncoordinated and potentially destructive manner.   She and some other local MPs were working together in a group called “OffSET” to try to get Government to support a better approach for increasing wind generation offshore which would involve a North Sea cable that could attract many different developers and the use of brown field sites, such as Bradwell in Essex, for any new onshore infrastructure.  She expressed disappointment with the approach and performance of National Grid and was dismayed that BEIS, National Grid and her own Environment Agency had refused to show up for her meeting.  She then went on to claim that her ability to influence energy policy was limited and that she could not represent the interests of her constituency in her role as cabinet minister.  While glad to know that she objected to the proposed projects and to the uncoordinated approach being taken by each of the energy projects, the meeting was surprised and dismayed that she felt her role in Government was not to represent her constituents.  The view of the meeting was that as SoS for the Environment and having sat in high level cabinet positions in the last three Governments, we expected Suffolk Coastal to have more voice in what was being done to the environment and to our communities by the lack of a joined-up Government energy strategy.  

The meeting expressed very strong concerns about the impact that the concept of Suffolk as “The Energy Coast” would have on the Suffolk Coastal constituency as well as the nation that could result in putting up to 1/3rd of the entire country’s future energy supply in 5 square miles of rural Suffolk.  Speakers expressed disbelief that Suffolk’s beaches, AONB and crumbling coast was being considered as a landing site for European interconnectors when there were numerous suitable brownfield locations.   In response to questions about further consultation with her constituency, the MP stated categorically that she would not hold another public meeting and that constituents could write to her with concerns.  For those interested, Libby Purves has an article about the meeting in the Times on 28 November; follow the link to see it: https://www.thetimes.co.uk/article/village-hall-reveals-our-national-power-failure-tq7j0jvf9?shareToken=90716a71086be7ed6338a87084d3205a (Note: this opens in a new window). 

 

On 28 November, East Suffolk Council representatives held a series of meetings with Parish and Town Council representatives to get feedback on Eurolink and Sealink.   Along with others, WPC expressed our unequivocal objection to the use of Walberswick and other inappropriate parts of our coast as landing sites and to the massive industrialisation of the coast associated with the construction of Sizewell C, the Friston sub-station and possibly 3 more substations connecting Eurolink, Sealink and Nautilus as well as additional pylons coming from Sizewell.  We expressed the view that East Suffolk Council must object to the development which it had not done for Sizewell C nor the Friston sub-station and that the plethora of new cables coming on shore was a direct result of siting these enormous energy projects here without adequate supporting infrastructure.  We expressed the view that it was the responsibility of ESC to highlight the unsustainability and massive environmental and societal damage associated with the failure of energy project coordination.

 

The Parish Council again strongly encourages every concerned resident, visitor and friend of Walberswick to attend one of the consultation meetings (the next one is at the Stella Peskett Hall in Reydon from 10-4 on Wednesday 30 November) and then to write in to express your views.

 

---------------------------------------

17th November

How/where to share your views with Eurolink and our elected representatives:

 

Written input will be critical for demonstrating opposition to the choice of Walberswick as the landfall for the Eurolink cable and other views you may have about the overall project.   It is essential that letters and emails are individualised; input that is copied directly or petition style letters will have much less impact.  Over the next few weeks, we will post on this website some of the key issues that you may wish to highlight.   Your input can be submitted until 18 December.

 

1.  You can write in any time from now, but you may find it more helpful to write after attending one of the presentations.  The nearest is at Stella Peskett Hall, Mights Rd, Southwold, IP18 6BE on 30th November, 10AM-4PM.  If you cannot attend, information is also available on the Eurolink website (nationalgrid.com/eurolink - note this will open in a new window). Your response should be sent to:

 

OR

  • Post response to: NGV EuroLink Consultation, Holborn Gate, Floor 8, 26 Southampton Buildings, London WC2A 1AN

 

Either way, please include your name, address and email contact information with your submission. 

 

2.  It would also be helpful if you wrote to East Suffolk Council and Suffolk County Council to ask them to oppose landfall of the cable at Walberswick.  Please note that both Cllr Smith and Cllr Beavan have expressed their opposition (see Eurolink update posting 15 Nov).  Therefore, you may wish to thank them for their support and ask them to encourage their respective councils to object. You can send your emails to: 

 

Cllr Richard Smith, Suffolk County Council:  richard.smith@suffolk.gov.uk

Cllr David Beavan, East Suffolk District Council: David.Beavan@eastsuffolk.gov.uk

 

Again, please include your name, address and email contact information with your submission. 

 

3.   You may wish to write to our MP, Therese Coffey, who is also Secretary of State for the Environment and Rural Affairs, at her parliamentary address:  therese.coffey.mp@parliament.uk. You should not only ask her to object to landfall at Walberswick, but to help the Suffolk Coast overall by insisting that the national level government look at the cumulative impact that these separate and uncoordinated energy infrastructure projects are having on our protected and delicate coast.    Each project — Sizewell C, Scottish Power EA1 and EA2 substation at Friston, Nautilus, Sealink, Eurolink and several more still in development — is compounding the environmental, transport, social and economic impacts on our communities.  Moreover, putting so many projects here in an uncoordinated fashion is making it harder to deliver national energy projects because there are insufficient appropriate locations and the infrastructure and services to support construction are missing.  The fact that all these projects are proposing to violate protected environmental sites including AONB, SSSI, SRA and RSPB reserves, and that Eurolink has to consider such inappropriate locations, far from the source of energy demand, such as Southwold, Walberswick, Dunwich and Thorpeness/Aldeburgh, is ample evidence of this.

 

The MP’s office requests that you indicate whether you are a constituent and include your name, address and email contact.  Please do not send anything to the MP as a cc:

 

It would help the Parish Council if you would send a copy of your submission/letters on Eurolink to WPC at walberswickclerk@gmail.com.  Although there is no requirement to do so, this would be useful in helping WPC monitor the issues raised and gauge the scale of input from residents.

---------------------------------------

15th November 2022:

The WPC considered a report on Eurolink at its meeting on 14th November that was well attended by all Councillors, many parishioners both in person and via Zoom and our Suffolk County Council Representative, Richard Smith, and our ESC Representative, David Beavan.

 

The Council resolved to unequivocally object to the “short-listing” of Walberswick beach as a potential landing site for Eurolink on the basis of the inappropriateness of the site.  This relates to the area being a year-round recreational beach, an AONB and SSSI, and its inaccessibility by road for construction vehicles.  Economically, it could be expected to have a devastating impact on local businesses that would already be suffering from the impact on the tourism sector that the construction of Sizewell C will have in Suffolk coastal.  Presumably, the Walberswick Common Lands Charity would suffer from the taking of its land and the loss of its main source of revenue from the car parks during construction. 

 

Building on this Resolution, the Council also approved the following Action Plan to push the Eurolink project to drop further consideration of Walberswick beach:

  • The Council will write to our elected representatives at the District, County and National levels to express our objections and ask for their support.   The Council thanked both Cllr Smith and Cllr Beavan last night for their statements expressing their objection to the Eurolink proposal and their commitment to work with Walberswick and other impacted communities to oppose the current selection of inappropriate sites.   WPC will also write to our MP (and Environment Minister) Therese Coffey to ask for her involvement and to stand up for her constituents in her national role by opposing these proposals for landing sites and overwhelming the Suffolk coast’s AONB with massive-scale energy infrastructure. 

 

  • The Council will submit a written response to the non-statutory consultations.  Approval of the consultation response will take place at the WPC meeting on 12 December in order to meet the deadline of 18 December. 

 

  • The Council, supported by statements made by Cllr Smith and Beavan, reiterated that it was essential that all concerned residents, visitors to and friends of Walberswick get engaged in the current consultation process ongoing until 18 December.  This should be done through attendance at consultation events, through written submissions to National Grid, and through writing to elected officials directly.   Hundreds of residents and visitors would need to get involved to make our views heard.    The Council will use the Village website, the Village News and social media to raise awareness, explain issues and encourage wide-scale engagement.  The Council welcomed efforts by Parishioners who were already actively encouraging residents to attend the consultation events and write in through posters and social media. 

 

  • Councillor Bassinette, who has responsibility for Sizewell C and other energy projects, was delegated to draft related documents and lead on the effort in consultation with the Chair, the WCLC and with other Parish and town councils similarly impacted by National Grid’s plans.   In this regard, it was noted that arrangements were already in place for discussions this week amongst the affected Councils. If timing of deadlines precluded bringing consultation and other written submissions to the full Council for approval before submission, Cllr Bassinette was delegated to make those submissions directly on behalf of the Council, and then to present them to the Council at the first opportunity.

 

---------------------------------------

9th November 2022:

In the last week four WPC Councillors have had the opportunity to attend webinars put on by National Grid to begin explaining proposals for using Suffolk Coastal as the location for landing underwater electric cables called Multi-Purpose Interconnectors (MPI) and constructing sub-stations to connect to the Netherlands, Belgium and Kent.   The proposals for Eurolink and Sealink have not been previously shared with local Parish Councils.  The initial proposal for Nautilus was consulted with some of the most likely impacted communities (which does not include Walberswick) approximately a year ago. 

 

This article summarises what was learnt/interpreted from these initial webinars.  For Walberswick, the most immediate concern relates to Eurolink but all of the projects have the potential to bring negative impacts particularly when the cumulative impact is considered. 

 

Overall situation for the Suffolk Coast

 

In short, the Government's decision to allow the sub-station for the off-shore Scottish Power EA1 and EA2 to be located in Friston rather than in a brown-field site, and the building of 2 EPR nuclear reactors at Sizewell C, sets up the Suffolk Coast to become an industrialised area not only for power generation, but for more and more MPI, substations and transmission lines.  This is because National Grid, a UK State-owned company responsible for transmission of electricity, is mandated to build transmission lines to where power is generated.  In other words, it is the owners of power generation (usually for-profit companies like EDF and Scottish Power) who determine where they build their plants and then National Grid must build and install power transmission capabilities to off-take the electricity generated.  The national Government (BEIS, under Kwasi Kwarteng during the time that Boris Johnson was PM), supported by East Suffolk District Council, have approved the building of these power generators in green field, AONB and SSSI sites along the Suffolk coast. Because of this, despite normally building sub-stations in brown field sites if possible, National Grid is similarly looking to put all of its infrastructure in green field sites in Suffolk coastal.  Obviously, the relationship between electricity generation and transmission projects would have been known to BEIS.  However, by taking up each project individually as an NSIP, and excluding discussion of how the generated electricity would reach the grid, BEIS could approve projects without considering the cumulative effects.   According to National Grid, if Friston and/or Sizewell C were not to go forward, then these cabling systems similarly would not be required in this area. 

 

There are currently three set of MPIs and related above ground substations being proposed to connect Friston to both the UK and European grids (and continental Europe to us). 

  1. Eurolink:  This is the most immediate concern for us as it is proposed that the cable from the Netherlands would come on shore in one of four locations:  Southwold, Walberswick, Dunwich or between Thorpness and Aldeburgh and then travel underground (mostly) to a large substation that Eurolink would build somewhere around Saxmunden-Friston-Leiston and then underground again until connecting to the massive Friston sub-station being built by Scottish Power.  The choice of locations for coming on-shore was done only as a 'desk study' and no one from Eurolink visited the potential sites.  Eurolink’s consultants said that in determining the final location, they would consider things like environmental damage, SSSI and AONB, accessibility, population centres, etc.
  • If Eurolink were to come ashore at Walberswick, the building site would be 2 hectares (20,000sq metres), so pretty much the whole of the beach, the dunes and the Cliff Field car park.  Work would take an estimated 4 years, after which only a “kiosk” (like a telephone box) would be left above ground. It is, therefore, primarily about the destruction caused during construction and damage to the eco-system left behind, rather than the operation of the cable itself, that is most problematic (assuming no other issues or repairs would be required).   Eurolink would like to start in 2025 with a target of 2029 for completion.  The working life of the cables is 40 years, but may last 60-70 years.  No answers were given on the effects of coastal erosion over that period as Eurolink has not modelled it.  Eurolink is unwilling to share the desktop analysis that led to the selection of these sites and said that they would not do so until their DCO application is fully formed.
  • It would seem to anyone who knows our area, that Walberswick beach would be wholly unsuitable given its inaccessibility for transport or materials, its designation as an AONB and SSSI and the fact that it is a full-year, heavily used beach.   Southwold and Dunwich (depending on where the MPI would land) would seem to have similar issues.  Only if it landed at the Sizewell nuclear site would these obvious shortfalls presumably be avoided.   
  • Despite having consultations in every other location where the cable would make landfall, Eurolink has reiterated that they have no intention of having a public meeting in Walberswick.  In response to repeated requests by WPC, Eurolink have said that Southwold should be close enough for Walberswick residents. 

 

2.           Sealink:  This is another National Grid venture (being handled through a separate sub-company) which would link coastal Suffolk (and Friston) to Kent.  This is to allow transfer of power around and between the southeast of England.   Just like Eurolink, it involves an MPI (originating in Kent) landing on one of the Suffolk beaches, leading to another enormous sub-station (26 metres high and 5 hectares of land). Their announced 'preferred' landing for Sealink is on the beach somewhere between Thorpeness and Aldeburgh (reportedly near Aldeburgh’s Seashell sculpture).   The sub-station would possibly be in/around Saxmunden, Leiston, Friston area. 

 

3.           Nautilus:  This is yet another MPI.  This one travelling from Belgium and much the same story; coming on shore on coastal Suffolk, connecting to a 3rd substation.

 

4.            New transmission towers?   Although this was not part of the National Grid presentation, in answer to a question, a National Grid engineer indicated that the existing pylons at Sizewell cannot carry Sizewell C electricity.  They therefore expected that there would be another DCO for another set of above ground transmission lines to connect to Bramford, if Sizewell C goes forward.    

 

Direct Impact of Eurolink on Walberswick

 

As noted above, if Walberswick were to be the preferred site, the damage would likely be considerable.  Many details are unknown because studies have not been conducted.  It can be assumed, however, that it would include the loss of access to the Walberswick beach and Cliff Field (which would become a construction site) and the lasting damage that construction would have on the delicate and special coastal fauna and flora on the beach, the dunes, and surrounding marshes.  There would also be the construction damage related to digging a trench for the running of the underground cable from Walberswick beach 10 miles or so to wherever the sub-station would be located.  This says nothing of the impact on the houses nearby, the loss of the village as a beachside tourist destination during construction (and potentially afterwards because of loss of habitat), the impact on businesses and the lives of all residents.   How National Grid would organise the taking of land, including that of the Walberswick Common Lands Charity, is unknown. 

 

If another site other than Walberswick is selected, it will not negate the impact that these MPI projects will have to the south of us.   Friston and/or surrounding villages could end up with 5 buildings, each 5 hectares in size and 26 metres tall.   This construction would be ongoing for years and at the same time as the building of Sizewell C and the Friston sub-station. 

 

What was made clear is that the decisions (with perhaps the exception of Nautilus) are at the earliest stage.  No decisions on location of landings, sub-stations, nor route of cables, have been made.   The wide range of places on our coast set out by National Grid as possibilities is an indication of how much engineering work is still needed.  National Grid also admitted that they had done no thinking about the transport impacts, how/where they would find a workforce, where this workforce would live, what would be the cumulative impact of Sizewell C and Friston being built at the same time as National Grid’s three additional sub-stations and cabling systems.   This means that we should have time now to bring some local knowledge and views to the process.  But if Sizewell C and Friston are allowed to go forward then overall the die is cast in terms of National Grid’s additional infrastructure. (At this time, there are Judicial Reviews pending on Friston and Sizewell C and some £30 billion of financing needs to be identified for Sizewell C.)

 

Next Steps

 

Walberswick Parish Council will be discussing this issue formally as part of its meeting on 14th November, in the Heritage Hut at 7PM and anyone who wants to come along to listen to the discussion or to express a view in the "open Forum" part of the meeting is very welcome to do so, and the meeting (as always) can also be joined remotely (via Zoom) - if anyone would like to join remotely, please email andrew.wpcouncillor@gmail.com BEFORE 6PM on the day of the meeting

 

The most important next step will then be to attend one of the five in-person consultation events where you can view the proposals in more detail and put your questions directly to the project team. The dates, times and locations of the events are as follows:

 

Exhibition Event #1: Leiston

Date: Wednesday 23rd November

Time: 10:00 - 16:00

Location: Waterloo Centre, Waterloo Avenue, Leiston, IP16 4HE

---------------------------------

Exhibition Event #2: Saxmundham

Date: Thursday 24th November

Time: 14:00 - 20:00

Location: Saxmundham Market Hall, High St, Saxmundham IP17 1AF

---------------------------------

Exhibition Event #3: Aldeburgh

Date: Friday 25th November

Time: 10:00 - 16:00

Location: St Peter and St Paul’s Church Hall, Victoria Road, Aldeburgh, IP15 5DU

---------------------------------

Exhibition Event #4: Reydon

Date: Wednesday 30th November

Time: 10:00-16:00

Location: Stella Peskett Hall, Mights Rd, Southwold IP18 6BE

---------------------------------

Exhibition Event #5: Dunwich

Date: Thursday 1st December

Time: 14:00-20:00

Location: Dunwich Museum, James Street, Saxmundham IP17 3DT

 

---------------------------------------

28th October 2022:

It has been a shock to all of us to have received a mass mailing from National Grid through our letter boxes that suggests they are considering using Walberswick's beach as one of four possible landing sites for a Multi-Purpose Interconnecter (MPI) between the Netherlands and the UK.  Follow the link to see more information from National Grid (Note: Opens in a new window)

 

There have been indications for some time from National Grid that they were considering this landing in the vicinity of Thorpeness/Aldeburgh; however, none of us had heard of any proposals to use Southwold, Walberswick or Dunwich beaches as is now being suggested.

 

National Grid has had absolutely no prior consultation with, or notification to, Walberswick Parish Council or Walberswick Common Lands Charity (WCLC), who own Cliff Field, on which National Grid's proposal would be built; obviously this is a wholly unacceptable situation. Both the Parish Council and WCLC have immediately contacted National Grid to insist that they hold a Public Meeting in Walberswick during the "non-statutory" consultation period announced in their mailing of 24 October - 18 December. Follow the link to see a copy of the WCLC letter to National Grid

 

Currently the nearest public consultation event to Walberswick will be held at Stella Peskett Hall in Southwold, on Wednesday 30 November from 10am – 4pm. We would encourage members of the Parish to attend this consultation event anyway and in the meantime we will continue to push for a consultation event to be held in Walberswick itself. It is at such a meeting that National Grid will have to explain their proposal and concerned residents and visitors can attend to raise questions and issues. This will very much be a first step and additional action will need to be determined following this initial period.

 

Andrew Lewis & James Darkins                                                

Chairs, Walberswick Parish Council and Walberswick Common Lands Charity