21 July 2015
Response to National Grid route decision on 17/06/15
1. Introduction
Power Without Pylons recognises the need for more power generation. However, we firmly
believe that new 50m pylons – twice the height and more than twice the width of existing
pylons - would have an enormous negative impact on the landscape south of Moorside, and
there is an alternative.
It is our conviction that the Offshore route is the only rational solution to connecting
Moorside to the electricity grid.
Building a new line of huge pylons in this area would be a retrograde step and a disaster for
the Cumbrian landscape. The countryside in the UK is blighted by poles and wires in many
places. This cannot be corrected overnight, but the long-term objective should be to remove
as many pylons, poles and overhead wires as possible, and not to install more.
We do not believe that our objection is a NIMBY (“Not in My Back Yard”) reaction. A more
relevant acronym would be LAYBY – “Looking After Your Back Yard.” We are trying to look
after this landscape for all of the future generations of visitors. Many of the millions of people
who have to live in cities only find that tolerable if they can regularly escape to the wonderful
landscapes in the National Parks.
1.1. Existing pylons
National Grid believes that people will not object to replacement pylons that are twice as
high and more than twice as wide. It describes the existing line as an “opportunity corridor.”
We believe that the existing pylons are an eyesore and should never have been built in this
wonderful landscape.
The existing OHL was constructed around 1950 just before the National Park was created.
There is therefore no precedent for Lake District National Park Authority (LDNPA) to have
given permission for an OHL within the Park. LDNPA would not have allowed this
construction if it had existed at the time.
The existing pylons have been there for 65 years, and it is likely that the new ones would be
there for at least another 65 years. This is not acceptable.
NG_PWP_response_post_150617.doc
1.2. Ofgem VIP project
Ofgem has recently provided £500m funding to National Grid “Visual Impact Provision”
project to remove OHLs from National Parks. It would be senseless for National Grid to be
funded by Ofgem to remove OHLs in other National Parks, while putting up a new one in the
Lake District National Park.
This route would contravene Ofgem’s own rules:
“When installing this equipment companies must take into account the environmental
impacts of new investment, including the visual impact of infrastructure. Action to conserve
natural beauty might include finding alternative routes, undergrounding cables, alternative
pylon design, tree screening and camouflage.”
We do not accept that “alternative pylon design, tree screening or camouflage” would lessen
the impact of 50m-high 400kV pylons.
2. Negative effects of Onshore with Tunnel option
2.1. Landscapes
2.1.1 Adopting the Onshore South with Tunnel option would have a major negative impact
on the internationally and nationally important landscape and environment of the Lake
District National Park and adjacent areas. It would contravene legislation designed to
protect important areas of scenic beauty from damaging developments and flout national
policy guidelines.
2.1.2 The National Parks and Access to the Countryside Act 1949, amended by the
Environment Act 1995, states that the statutory purposes of National Parks are:
“To conserve and enhance the natural beauty, wildlife and cultural heritage of the
National Park; and
To promote opportunities for the understanding and enjoyment of the special qualities
of the National Park by the public.”
2.1.3 The 1995 Act also states that when exercising or performing any functions which affect
land in a National Park any relevant authority (of which National Grid is one) shall have
regard to National Park purposes. If it appears that there is a conflict between those
purposes, greater weight should be attached to the purpose of conserving and enhancing
the natural beauty, wildlife and cultural heritage of the National Park. By pursuing an
onshore route, National Grid is not meeting its obligation as a Statutory Undertaker with a
Duty under S62 of the Environment Act 1995 to have due regard to National Park purposes.
2.1.4 The National Planning Policy Framework states that great weight should be given to
conserving landscape and scenic beauty in National Parks. Planning permission should be
refused for major developments in these designated areas except in exceptional
circumstances and where it can be demonstrated that there are no alternative options.
Where applications are submitted they are required to include an assessment of any
detrimental effect on the environment, the landscape and the extent to which that could be
moderated.
2.1.5 The Holford Rules govern decisions on routeing overhead power lines today. They
were first set out in 1959 – several years after the existing 132kV cabling was permitted.
Rule 1 states that the major areas of highest amenity - which include National Parks; Areas
of Outstanding Natural Beauty; Heritage Coasts and World Heritage Sites - should be
avoided altogether if possible. It is possible to avoid these areas in this case. National Grid
is ignoring the Holford Rules.
2.1.6 Section 31 of the English National Parks and the Broads UK Government Vision and
Circular 2010 states that major development in or adjacent to the boundary of a Park can
have a significant impact on the qualities for which they were designated. This needs to be
considered in respect of all sections of the proposed corridor.
2.1.7 Whilst a significant proportion of the proposed overhead power lines lie within the Lake
District National Park, a further longer stretch of lines lie within 2km of the National Park
boundary where they are likely to have a significant adverse impact on the setting of and
views from the National Park.
2.1.8 Outside the National Park, the proposed route includes two Special Areas of
Conservation (Duddon Mosses and Drigg Coast at the Ravenglass Estuary) and a
designated Heritage Coast section (St Bees Head.) In addition it impacts on other sensitive
landscapes and seascapes.
2.1.9 PWP is concerned that National Grid has inaccurately assessed the landscape value
and sensitivity to electricity infrastructure of the coastal plain through which the proposed
route runs. The coastal plain on the Moorside to Silecroft section has open views between
high fells to the coast. These views are greatly valued as part of the Lake District’s
landscape character and 50m-high pylons would be a considerable detractor both when
looking inland to the mountains from the coast, and towards the coast from the fells – for
example from Corney Fell and Black Combe.
2.1.10 PWP has particular concerns about the area at the head of the Duddon Estuary,
which falls within a Site of Special Scientific Interest (SSSI), Special Protection Area and
Ramsar site. We consider neither route E2.1 nor E2.2 to be acceptable. We strongly object
to the northern route (E2.2) for the following reasons: it is longer and would therefore
disfigure more landscape; it runs closer to a centre of population; it would have a much
greater visual impact on head of the Duddon Estuary.
2.2. Health
2.2.1 The government document, “National Policy Statement for Electricity Networks
Infrastructure”, includes a section (2.10) on Electric and Magnetic Fields (EMFs) which
states: “EMFs can have both direct and indirect effects on human health. The direct effects
occur in terms of impacts on the central nervous system resulting in its normal functioning
being affected.”
2.2.2 The document also gives guidelines for siting 400kV lines where houses and schools
are nearby. Current proposals may contravene these guidelines where the planned route
would pass close to schools.
2.2.3 Kirkby-in-Furness is of particular concern. If a new 400kV OHL were to follow the line
of the existing 132kV OHL, as planned, it would be very close to the school and the site of a
proposed housing estate behind the school. The corridor here is a very narrow, with little
scope for rerouting. Not only would the much larger pylons needed for a 400kV line be an
eyesore, but the higher voltage lines would also bring greater potential health risks from
electric and magnetic fields.
2.2.4 There has also been discussion in the past relating to leukaemia clusters close to
power lines. This has not been proved, yet equally it has not been disproved.
2.3. Cultural heritage
2.3.1 The Lake District plays an important national and international role in the development
of the landscape conservation movement. Such is the significance of the Lake District
National Park’s cultural landscape that the UK government backed an application for the
National Park to be designated by UNESCO as a World Heritage Site. A proposal to site
pylons through and close to the National Park is wholly incompatible with World Heritage
status and may jeopardise the bid.
2.3.2 Ravenglass Roman Fort and bath house is part of the ‘Frontiers of the Roman Empire’
trans-national World Heritage Site. The impact of an electricity infrastructure on the
landscape will have implications not only for the proposed Lake District World Heritage Site
but also for the ‘Frontiers of the Roman Empire’ World Heritage Site and their settings.
PWP is concerned that the effects of the planned route on valuable physical assets have not
been fully assessed.
2.4. Ecology
2.4.1 Cumbria County Council has produced an assessment of the ecological implications of
National Grid’s preferred option. Whilst it has assessed the effects of pylons above ground, it
has not considered the ecological implications of mitigation such as undergrounding. If the
onshore option is to be pursued, a comprehensive ecological assessment will be required.
2.5. Tourism
2.5.1 National Grid acknowledges that there is the potential for overhead pylon development
to have an effect on tourism in the area. Tourism is a vital part of the local economy: farmers
and landowners have been encouraged to diversify by providing holiday accommodation
and many local businesses that provide products and services to visitors rely fully or partly
on tourism.
2.5.2 Since the economy is therefore highly sensitive to landscape damage, it is necessary
to have a clear understanding of the potential effects of an onshore route and the likely costs
to the economy.
3. The case for mitigation
3.1. National Grid consultation 2014, stage 2
3.1.1. All the impacts referred to in Section 2. above were previously raised by many
respondents in consultation stages 1 and 2.
3.1.2. Most public responses were in favour of the Offshore route. Stakeholder
responses were more mixed, but many said or implied that if an onshore route were
taken adequate mitigation would be needed in several places. They were not
referring to the mitigation already on offer, i.e. the Morecambe Bay tunnel.
3.1.3. By adequate mitigation, we refer mainly to undergrounding. Tree screens do not
work with 50m pylons.
3.1.4. Important locations requiring mitigation include:
Lake District National Park: Ravenglass /River Irt /River Mite /River Esk /Roman remains
Lake District National Park: coastal stretch
Whicham valley in or just outside the Lake District National Park
Duddon Estuary
Lindal
3.2. Inconsistency
There appears to be an inconsistency in National Grid’s attitude to mitigation. The Hinkley
Point C grid connection plan shows an underground section, designed to mitigate the impact
on the Mendip Hills AONB.
Given that National Parks have a higher level of protection than AONBs, the implication is
that this sort of mitigation would be offered as a matter of course in the Lake District National
Park.
3.3. Justification
National Grid has stated that “justification will be needed for more mitigation.” The justifiable
case for effective mitigation has already been clearly made by many respondents to the
consultation, to whom justification was obvious.
Rather than requiring consultees to justify mitigation, we believe the onus should be on
National Grid to justify the disfigurement of the landscape. Nothing we have heard so far
justifies the destruction of the Lake District landscape, particularly when there is an
alternative.
4. Offshore south sub-sea HVDC route
PWP recognises the enormous problems associated with doing any effective mitigation on
the National Grid-preferred Onshore route. There are potentially major problems associated
with undergrounding and crossing river estuaries, including archaeology and ground
conditions.
It will be noted that the locations listed in Section 3.1.4 as requiring proper mitigation reflect
most of the preferred overland route. For this reason PWP continues to insist that the
Offshore sub-sea HVDC route is by far the best option.
Nothing we have heard so far in any meetings or read in documentation convinces us that
this route is impossible or impractical. National Grid has not said that it is impossible to
construct. If it were not a feasible option, National Grid would not have proposed it.
4.1. Sub-sea element
Despite what has appeared in the media, it has been stated in National Grid workshops that
it is not impossible to bury the cables in the sea-bed. A number of potential sub-sea
difficulties have been cited – including the risk of unexploded shells - but National Grid does
not appear to view these as the main problem. The White Young Green report states that
the offshore route “diverts away from the coast to avoid the Eskmeals firing range.”
Furthermore, we believe that most Eskmeals test firing is not done with live shells.
4.2. HVDC/nuclear power station connection – technical difficulties
We have requested, from National Grid and NUGEN, a technical description of the
difficulties involved in connecting HVDC to a nuclear power station. We are still waiting.
4.2.1. “Nuclear Safety”
We believe this term may be being used to justify rejection of the offshore option when this
may not in fact be a safety issue at all. If this relates to the capability to import electricity in
a disaster-type scenario, there must be alternative ways of handling this.
4.2.2. Technology approvals
NUGEN is concerned about schedule delays due to having to gain approval for nonstandard technical options. This is not an adequate justification for rejecting the HVDC
option. There would appear to be plenty of time to gain any necessary approvals. National
Grid and NUGEN should be applying for these approvals now, and continuing to design this
option, so that if the Infrastructure Planning Commission (IPC) rejects their preferred route,
the schedule can still be maintained.
We have requested from the Office of Nuclear Regulation details of any new approvals that
might be required.
4.2.3. Security of supply
We believe this term refers to the ability to export the generated electricity. This would
appear to be a commercial issue, not a safety one. HVDC technology is described as
slightly less reliable, but in this situation the northern AC OHL route would secure an
adequate supply. It has been stated that the entire output of the power station can be
carried on just one of the two northern AC circuits. There would therefore appear to be
sufficient redundancy in a design which included an HVDC element.
4.2.4. White Young Green (WYG) consultancy technical report
This report states:
1. “A simultaneous outage of two converter units or cable sections in the HVDC system
would still permit security requirements to be maintained and generation from the plant
could continue, rather than suddenly being reduced.”
2. “However, there are other potential issues with a DC link operating within the AC system.
For example, power oscillations and frequency control could cause disturbance
particularly if there is an unplanned outage of one of the converter units and where the
other units have reached their maximum output. Issues such as these can be resolved by
careful design and implementation of latest technology.”
This would appear to indicate that there are some potential problems, but that they can be
resolved.
4.3. Cost
4.3.1. The extra cost of an offshore HVDC route over and above the National Gridpreferred route is approximately 40%, or £400m (National Grid figure). However, this
National Grid connection should be considered as part of the whole Moorside power
station project. The extra cost of the Offshore route would be a very small proportion
of the total cost (perhaps 3%).
4.3.2. The extra cost of an offshore HVDC route over and above the National Gridpreferred route is approximately 40%, or £400m (National Grid figure). However, this
National Grid connection should be considered as part of the whole Moorside power
station project. The extra cost of the Offshore route would be a very small proportion
of the total cost (perhaps 3%).
4.3.3. £1bn of capital expenditure equates to £1 on annual electricity bills (National Grid
figure). The extra cost to the consumer of the offshore HVDC option compared with
National Grid-preferred onshore route is therefore 40p per annum. Locally, this tiny
increase in electricity bills would be greatly outweighed by, for example, lost tourist
revenue and traffic delays during the construction phase.
4.3.4. We understand that that the costs involved in providing an Offshore South route
may conflict with National Grid’s “statutory duty to maintain an economic and
efficient transmission system.” However, this duty needs to be balanced with
National Grid’s statutory duty to have regard for the purposes for which the National
Park was designated and also its duty to biodiversity under the NERC Act 2006.
5. Onshore route mitigation
5.1. PWP believes that the Offshore HVDC route is by far the best option.
However, for the sake of completeness, we have listed below alternative technologies and
routes that we are aware of.
If adequate mitigation were to be done in all of the necessary locations on the onshore route,
the onshore route option would almost certainly become much more expensive and difficult
than the offshore one.
5.2 Alternative technologies
5.2.1 Gas-Insulated Line (GIL)
The cable runs inside a gas-filled tube. The tubes can be installed in several different ways:
for example buried in a trench, or cut-and-cover tunnel. One of the main advantages is that
they can be installed much closer to each other than a standard underground cable.
GIL advantages:




















Has far less visual impact on the landscape
Takes far less space (corridor width)
Removes Electrical Fields and reduces Magnetic Fields dramatically
Considerably reduces transmission losses (paid for by tax payer on their electricity bill)
Is safe to be close to
Is safe in a failure state
Causes minimal damage to the environment
Has no impact on tourism, property values, or socio‐economic issues
Can be virtually invisible when completed
Reduces CO2 emissions
Can be accessed 24 hours a day for maintenance
Can readily accept additional capacity
Is not affected by adverse weather
Is less vulnerable to acts of terrorism
Is easily monitored remotely 24/7
Allows installation inspections to be carried out remotely 24/7
Reduces time and cost of maintenance
Reduces downtime
Provides an available duct to run other services such as media/broadband cables
Causes less disruption to local residents and visitors in the construction phase.
5.2.2 Horizontal Directional Drilling (HDD)
The technology is derived from the oil industry and involves drilling down at an angle to pass
under the river bed and then up the other side. The cable can then be dragged through the
borehole. National Grid has stated that the distance limit in this situation is about 500m due
to the required size of cable. (Longer distances can be achieved with HDD with smaller
cable sizes.)
5.2.3 Undergrounding
Compared with OHL construction and GIL, the standard undergrounding technique has a
number of disadvantages. These include the opposite of most of the GIL advantages listed
above. In addition it is expensive and requires a huge width of corridor for a double 400kV
circuit (in construction the working width is approx 40m – 65m.)
5.3 Areas requiring mitigation
5.3.1 Lake District National Park Ravenglass/River Irt /River Mite /River Esk
/Roman remains
This area includes the historic village of Ravenglass, three separate estuaries,
Muncaster Castle, and Roman remains including bath house. Adequate mitigation
could mean HDD across the estuaries plus undergrounding. Another alternative
method of crossing the estuaries could be by using the railway bridges. GIL could be
of use in this area in order to restrict the necessary corridor width, and to mitigate the
impact on archaeology. Note: This option was considered by National Grid (see
“Route Corridors and Search Areas Considered and Not Taken Forward.”)
5.3.2 Lake District National Park coastal stretch
Adequate mitigation can only mean undergrounding. This could be standard
undergrounding, or perhaps GIL, in a trench or even in a tunnel (buried or surface)
alongside the railway.
5.3.3 Whicham Valley
The proposed OHL in the beautiful Whicham valley, with its ancient woodland sites,
lies partly in and partly outside the Lake District National Park. Again, adequate
mitigation can only mean undergrounding.
5.3.4 Duddon Estuary area – possible solutions
5.3.4.1
HDD in the lower estuary (Millom - Askam area)
This would appear to be the best solution for the Duddon Estuary area, if it is
technically feasible. If the maximum borehole length in this situation is 500m, this
could be solved by building islands in the estuary to allow more than one stretch of
HDD. The nature of the estuary here – shallow with deeper channels in the middle –
would make this possible.
Pros:
Avoids a long section of pylons around the estuary.
Cons:
Ecological impact in estuary.
PWP believes that any negative impacts of this option would be fewer than the visual,
ecological and other impacts of pylons, together with their individual construction
tracks, all around the estuary.
Cost:
The cost of this solution would need to be assessed but it could be less
than installing the long stretch of pylons that it would replace.
5.3.4.2
Tunnel in the lower estuary (Millom - Askam area)
This would be similar to the proposed Morecambe Bay tunnel, using AC cables.
Pros:
Avoids a long section of pylons around the estuary; technically feasible.
Cons:
None identified
Cost:
As a rough estimate, this could cost around £150m (offset by the cost of
pylons around the estuary – perhaps around £50m.)
5.3.4.3 Undergrounding all the way around the estuary
This could be standard undergrounding. Alternatively GIL could be used, in a trench
or a tunnel (buried or surface), perhaps alongside the railway.
Pros:
Cons:
regard.
Cost:
Avoids a long section of pylons around the estuary.
Standard undergrounding needs a wide corridor. GIL is much better in that
5.3.4.4
Trenched cables in the lower estuary (Millom - Askam area)
This would be an expensive solution
There is an existing (lower voltage) cable already in this location that supplies
electricity to Millom. There are believed to be problems with river bed scouring and
shifting channels, that make this option less than ideal.
Pros:
Avoids a long section of pylons around the estuary.
Cons:
River bed scouring, shifting channels; ecological impacts.
Cost: This is likely to be inexpensive
5.3.4.5
Trench further out to sea, in a loop just outside the estuary - variation
on the previous option
To avoid the problems with river bed scouring and shifting channels mentioned
above, a trenched method could be used, going offshore from the Millom area, or
maybe Silecroft, as far out as is necessary to avoid those problems, and coming back
onshore - maybe in the Barrow area. This method would use AC cable.
Pros:
Cons:
Cost:
5.3.4.6
Avoids a long section of pylons around the estuary.
None identified
This is likely to be inexpensive
Extending the Morecambe Bay tunnel to cross the Duddon Estuary
This would make the tunnel much longer, but might avoid the fixed upfront costs if, for
example, the same tunnelling machines could be used.
Pros:
Cons:
Cost:
Avoids a long section of pylons around the estuary.
None identified
This could be expensive
5.3.4.7
Duddon crossing in the lower estuary (Millom - Askam area)
This idea would make use of a proposed new road bridge or barrage to carry
transmission cables across the estuary.
Pros:
Avoids a long section of pylons around the estuary.
Cons:
The time schedule for the grid connection may not permit waiting for the
bridge to gain funding and permission. Ecological impact due to necessary piers in
the estuary bed. PWP believes that the negative impacts of this option would be
fewer than those of pylons (with their individual construction tracks) all around the
estuary.
Cost:
For the grid connection this would be a low-cost solution.
5.3.4.8
Dedicated cable bridge in the lower estuary (Millom - Askam area)
A bridge built just to carry transmission cables across the estuary.
Pros:
Avoids a long section of pylons around the estuary.
Cons:
Not visually attractive, though better than pylons all around the estuary, and
better than a pylon crossing; ecological impact due to necessary piers in the estuary
bed. PWP believes that the negative impacts of this option would be fewer than those
of pylons (with their individual construction tracks) all around the estuary.
Cost:
Possibly less than the long stretch of pylons that it would replace
5.3.4.9
Pylon Duddon crossing in the lower estuary (Millom - Askam area)
Pylons to carry transmission cables across the estuary. Some pylons would be
necessary in the estuary itself.
Pros:
Avoids a long section of pylons around the estuary.
Cons:
Visual impact. Ecological impact due to necessary piers in the estuary bed.
PWP believes that the negative impacts of this option would be fewer than those of
pylons (with their individual construction tracks) all around the estuary.
Cost:
Possibly less than the long stretch of pylons around the estuary that it
would replace.
Note: This option was considered by National Grid (see “Route Corridors and Search
Areas Considered and Not Taken Forward.”)
5.3.4.10 HDD at the head of the estuary, near the railway bridge
This technique will be used for a new water main in this area, currently being
constructed.
Pros:
Technically feasible.
Cons:
Avoids only one small section of pylons across the river at the head of the
estuary.
Cost:
An inexpensive solution
5.3.5 Lindal
The Lindal area, including the Lindal tee grid junction, is an existing eyesore, with
lines of pylons going in four directions. This situation can only be made far worse by
400kV pylons. There is an existing pylon very close to Lindal school. Again,
adequate mitigation can only mean undergrounding.
6. Conclusion
There remains widespread support for the Offshore option.
Many individuals and organisations that expressed support for the Onshore with Tunnel option
did so with the caveat that adequate mitigation would be required in many areas. On closer
analysis, areas requiring mitigation make up the greater part of the proposed land-based route.
A number of mitigation measures are possible, yet the entire topic of mitigation is fraught with
difficulties. Major difficulties include irreconcilably conflicting issues surrounding biodiversity,
ecology and landscape preservation, and cost. To provide the mitigation likely to be required to
meet National Grid’s various statutory obligations with regard to environmental protection would
in all probability outweigh the cost of the Offshore option.
Many, if not all, of the negative impacts stated in Section 2. above were recognised by National
Grid in relation to the Onshore route without tunnel which would take pylons around Morecambe
Bay. As a result, this option has now been ruled out. These same negative impacts apply to
the overland parts of the Onshore with Tunnel route – and perhaps in greater measure due to
the particular sensitivities of many areas. It is illogical and difficult to understand that National
Grid now appears to disregard these factors.
We intend to challenge National Grid’s plans at the Infrastructure Planning Commission enquiry.
We assume that National Grid will be progressing the design for an offshore HVDC route in
parallel with its preferred route, to allow for the possibility of the onshore route being rejected by
the Planning Inspectorate.
It is totally unacceptable to construct a new line of giant pylons in and around the Lake District
National Park.
PWP’s conviction is that the Offshore route is the only rational solution to connecting
Moorside to the electricity grid.