National Planning Policy:

How National Grid’s substation proposals fly in the face of it...

Stour Valley Underground (SVU) has previously made the case that the National Grid proposed Twinstead location for substation is plainly contrary to clause 112 of the National Planning Policy Framework (NPPF) which states:-

Local planning authorities should take into account the economic and other

benefits of the best and most versatile agricultural land. Where significant

development of agricultural land is demonstrated to be necessary, local

planning authorities should seek to use areas of poorer quality land in

preference to that of a higher quality.

In the opinion of SVU this clause places upon Braintree District Council (BDC) an obligation to find an alternative to the NG proposed “C2” site beside the A131 near Twinstead which as is evidenced on the following BDC supplied map is on Grade 2 agricultural land and is thus “best and most versatile”.

The Government’s Agricultural Land Classification Map: this section copied from sheet 149.

Waldergrave and Butler woods are shown in orange near the centre of the map. The land between these woods is National Grid’s proposed substation location which is clearly identified as Grade 2, as is the land surrounding the woods.

BDC has indeed done this as such an alternative on poorer quality land clearly exists adjacent to Braintree Substation.

This is made very clear by BDC’s formal substation consultation response as copied to us by local planning authority Planning Policy Officer, Emma Goodings on 15/4/2013.

Our worry is that the response includes a caveat that accepts that a substation could be built by NG at site C2 near Twinstead on the A131.

BDC’s response states:-

Study Area C – Butlers Wood/Waldegrave Wood off the A131, Twinstead/Bulmer Parishes.

If a substation is shown to be the only option for the reconnection of the 132kV network in the District then the Council’s preferred option for this, is at site C off the A131.

The Council believes that a substation location to the rear of the gap between Waldegrave Wood and Butler’s Wood is thebest location for a new substation...

With respect to theabove and "if a substation is shown to be the only option”, NG have confirmed that Area C is NOT the only viable option, BDC’s preferred Braintree option being able tofulfill their operational requirements.

We hold that the position indicated by this aspect of BDC’s response is incompatible with section 112 of the NPPF. SVU believe that BDC’s response should be fully compliant with the NPPF and should therefore hold that Study Area C is wholly insupportable because of its conflicting with this important provision within the NPPF.

What are we asking for?

We believe that BDC’s response should state clearly that neither of Study Areas B nor C are acceptable because of this conflict with clause 112 of the NPPF and that in keeping with its obligation to implement the NPPF, BDC have identified an appropriate alternative location, adjacent to the existing Braintree Substation, seeing that as the only deliverable option that is NPPF compliant.

Why is this important now?

National Grid state that they intend to have the B2T connection in place by the end of 2021. We conclude that this means that NG will restart the consultation process within the next 2 years. The consultation will resume with a round of refresher meetings and then go straight into the formal consultation with the project as currently proposed. Time scales for all addressing this planning application when this happens will be extremely demanding.

Local communities, and their representatives and LA officers have gained valuable concessions and variances from NG’s original proposals. They and we certainly would not wish to jeopardize these. And yet by including a non NPPF compliant proposal for a Substation on Grade 2 agricultural land, there is a chance the whole plan could be rejected by PINs. This is not SVU’s objective.

Accordingly, we are seeking a revision to the local planning authority’s response to the substation consultation well before the proposals go to the Planning Inspectorate (PINs) such that it is fully compliant with the NPPF with respect to clause 112. Indeed we would hope that the response would specifically cite clause 112 in vehemently rejecting NG’s C2 proposal and supporting BDC’s well argued case for its preferred location for the new substation equipment alongside the existing substation at Braintree.

Why now?

Because SVU believe that this revision and its communication to NG is needed to press them to revisit and revise their substation location preference before resuming the informal consultation. We seek to have NG go into the formal consultation and thence to PINs with a NPPF compliant proposal. This we believe would deliver a plan that all relevant LAs, councillors and local community / amenity groups can support.