Object to LionLink survey planning application
National Grid has submitted a Planning Application to East Suffolk County Council (ESCC) to conduct geotechnical surveys along the proposed LionLink landfall and cable routes for the Walberswick and Southwold/Reydon options. For Walberswick, this would involve digging ‘trial pits’ and drilling ‘boreholes’ on the proposed G2 site and out towards the A12, but also on the beach and at the edge of the caravan site. The proposed work confirms the likely cable route and access points as well as the G2 landfall site, if Walberswick is the preferred option (see maps). It is proposed to carry out the work between 27 August and 31 October.
Comments to the application need to be made by 18 August and need to focus on whether “the works will have a significant effect on a protected habitats site”. Our responses should, therefore, concentrate on the potential impacts of the survey on wildlife, drawing on the preliminary results of the Walberswlck Wildlife surveys. We also think, however, that we should not be confined in our responses but also take the opportunity to draw ESCC's attention to the damaging impacts on the village itself, on its economy and residents through noise, vibration, transport, as well as the likely detrimental effect on tourism and visitor numbers. To date, National Grid has ignored the fact that the Walberswick option is sited in the heart of the village with the landfall site surrounded on three sides by residential houses and the access and cable routes also running alongside houses, choosing to characterise it only as “south of the village”. ESCC needs to be made aware that this is not correct.
What we need to do
We need to object by logging on to the East Suffolk Planning Portal and preferably using our own words fill out the Comments section, drawing on the main bullet points and information below.
Please do however add anything else you wish, including how you would be personally affected by the works. The important thing at this stage is to focus on the survey works planned rather than the wider issues of LionLink and the industrialisation of the Suffolk Coast.
How to leave your comment
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Search for the application here using this code DC/24/2714/con
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Please make it clear you are objecting to the works in Walberswick You may want to title your comments… Objection to Walberswick Proposal
Guidance for your comments
Impacts on Wildlife
I strongly disagree with the conclusion that there will be no significant impacts on the Minsmere-Walberswick European sites or SSSI (Sites of Special Scientific Interest) due to geotechnical investigations (GI) along the Walberswick corridor. Several key potential impacts have not been adequately assessed, particularly concerning species like Bearded Tits, Cetti’s warblers, Woodlark, and Nightjar, which inhabit the affected areas.
The negative impact of the use of UAVs (drones) on birds have been overlooked and needs further assessment
Whilst outside the scope of these reports, we have seen no accompanying reports to address the issue of protected species. Species have been identified which are variously protected under the Wildlife and Countryside Act and/or Habitats Regulations, such as Barbastelle bats. There should be an Ecological Impact Assessment addressing the potential risks to these protected species and, at the very least, a precautionary working methods statement to mitigate identified risks.
Siting of BHB is a serious risk to breaching beach sea defences. Seawater incursion is recognised as the primary threat to the protected site in its conservation objectives and has been identified as the key threat to the breeding bitterns using the site.
Detail
Throughout 2024, Walberswick has been conducting ecological surveys on birds, reptiles and bats around the whole of the proposed site and cable routes to the Dunwich Road. Additional surveys are also planned for moths. Below is a summary of what we have found so far:
Birds
There is an extremely rich bird life over the affected area, with 69 different species recorded over six full 22 KM surveys conducted. Key species that have not been mentioned include Bearded Tits or Cetti’s warblers (key SSSI citation species) using Unit 82. Yet, recent surveys show that this section is used regularly by this species, including particularly large numbers of bearded tit during the autumn period, when the GI is proposed. Woodlark and nightjar are known to occur on the section of the European site/SSSI close to BHD03-05, yet no specific mention is made of these species.
A diversity of hedgerow birds are to be found in the areas surrounding the proposed onshore trial pits around the G2 landfall site (eg TP04, TP09, TP10, and onshore borehole BH05). The work would also disturb the neighbouring reed beds and SPA and Ramsar Site, home to species such as bearded tits, reed and sedge warblers and marsh harriers. The proposed work running from the G2 site to the A12 would impact species such as woodlarks (north of BH04), and the breeding birds in the hedgerows including whitethroats, blackcaps and skylarks. Hobbies are breeding in the woodland just south of proposed BH04.And a pair of hobby nest very close to BHD003 & BHD004.
There is strong scientific evidence that UAVs (drones) disturb birds, particularly waterfowl. The UAV survey area includes an important passage/wintering site for waterfowl, including one of the most important sites for spotted redshank in the UK. The Appropriate Assessment does not mention either the disturbance evidence base nor spotted redshank, and concludes there will be no likely significant effects. This requires further assessment.
Other Wildlife (reptiles, bats):
Current surveys show that there is an exceptional population of reptiles, involving the four widespread UK species, along all field boundaries of the landfall site and corridor.
Nine species of bat have been regularly recorded in these areas, including the uncommon and more highly protected barbastelle bat.
Water voles are present very close to BH05, BHA & BHB.
Coastal Erosion:
The siting of a borehole BHB appears to be on the back of the beach/dunes area, exactly where the erosion risk is highest. This area has been breached twice by recent winter storms and is the ‘Achilles heal’ in relation to safeguarding the brackish and freshwater marsh system of the remaining protected site. Seawater incursion is recognised as the primary threat to the protected site in its conservation objectives and has been identified as the key threat to the breeding bitterns using the site. Yet, the HRA does not assess the physical damage from the borehole potentially exacerbating erosion at this critical location. Erosion is only mentioned as a generic pressure in Table 3-3. This needs to be assessed and further precise details of the location and potential physical sediment damage presented.
Tourism and Economy:
People counters have been placed on key footpaths around the G2 landing site to show their extensive use. In less than a month, we counted at least 14,000 people using these paths.
The proposed plant, machinery, and vehicle access via the caravan park access site would involve moving vehicles down one main street of the village. The impact on caravan owners and users needs to be assessed.
BELOW 2 alternative versions of how an objection could be worded which may help you form your response…
1
I strongly disagree with the conclusion that there will be no significant impacts on the Minsmere-Walberswick European sites or SSSI (Sites of Special Scientific Interest) due to geotechnical investigations (GI) along the Walberswick corridor. Several key potential impacts have not been adequately assessed, particularly concerning species like Bearded Tits, Cetti’s warblers, Woodlark, and Nightjar, which inhabit the affected areas.
The negative impact of UAVs (drones) on birds, especially waterfowl, has been overlooked and requires further evaluation. Additionally, there is a lack of reports addressing protected species, such as Barbastelle bats, which are safeguarded under the Wildlife and Countryside Act and Habitats Regulations. An Ecological Impact Assessment should address these risks, alongside a precautionary working methods statement to mitigate potential harm to these species.
Throughout 2024, extensive ecological surveys conducted by local residents, including ecological experts, revealed a rich birdlife with 69 species recorded, including those mentioned above. The surveys also found a diverse range of hedgerow birds in areas near proposed onshore trial pits and boreholes, which would be disturbed by the planned work. Specific areas, like the reed beds and SPA/Ramsar sites, home to species such as Bearded Tits, Reed and Sedge Warblers, and Marsh Harriers, are particularly vulnerable. The breeding grounds of Woodlarks, Skylarks, and other hedgerow birds could also be impacted, along with the nesting sites of Hobbies.
There is strong scientific evidence that UAVs disturb birds, particularly waterfowl, yet the Appropriate Assessment fails to mention this or the important passage/wintering site for species like the Spotted Redshank, requiring further review.
Regarding other wildlife, surveys reveal an exceptional population of reptiles across field boundaries and nine bat species, including the rare Barbastelle bat. Water voles were also observed near specific borehole sites.
Coastal erosion is identified as a critical issue, particularly concerning the siting of borehole BHB on a vulnerable section of the beach/dunes. This area has already been breached by winter storms, posing a significant risk to the freshwater marsh system and breeding bitterns. The Habitat Regulations Assessment (HRA) does not thoroughly evaluate the potential physical damage and sediment disruption that could exacerbate erosion at this key location, requiring a more detailed assessment.
2
I am writing to express my strong objection to the Planning Application submitted by National Grid, which seeks approval for geotechnical surveys in Walberswick. The proposed works raise significant concerns about the potential negative impacts on the local environment, the well-being of the village, and its economy.
Threats to Village Life and Economic Disruption
Walberswick is a unique and vibrant community, heavily reliant on tourism. The proposed geotechnical activities, which include digging trial pits and drilling boreholes, would have a profound effect on the quality of life for residents and the local economy:
Noise, Vibration, and Traffic Disruption
The use of heavy machinery and the resulting noise and vibrations will undoubtedly disturb the peace of the village. Additionally, the proposed transport routes for equipment and materials, particularly through the narrow main street and via the caravan park access, will create significant disruption and safety concerns for both residents and visitors.
Impact on Tourism
The timing of the proposed works during a peak period for tourism is particularly troubling. Walberswick’s economy depends largely on visitors, and the disturbances caused by these activities could lead to a substantial decline in tourism, directly harming local businesses that rely on this critical revenue stream. People counters on key footpaths around the site already show high usage, indicating the potential extent of this economic impact.
Misrepresentation of the Site’s Proximity to the Village
National Grid’s description of the Walberswick site as being “south of the village” is misleading. In reality, the proposed landfall site (G2) is situated in the heart of the village, surrounded by residential houses on three sides, with access and cable routes running alongside these homes. This mischaracterisation understates the potential impact on the village and its residents, who will be directly affected by the proposed activities.
Environmental and Ecological Concerns
The environmental impact of the proposed surveys cannot be overstated. Walberswick is home to a rich diversity of wildlife, much of which is protected under European and national conservation laws:
Impact on Protected Bird Species
The proposed survey area is home to several key bird species, including Bearded Tits, Cetti’s Warblers, Woodlarks, and Nightjars. These species, which are integral to the biodiversity of the area, have not been properly accounted for in the Environmental Impact Assessment. Disturbances caused by the planned works during the critical autumn period could have significant detrimental effects on their populations.
Use of UAVs (Drones)
The application overlooks the well-documented risks associated with the use of drones, particularly their potential to disturb waterfowl. The area slated for UAV surveys includes a crucial passage and wintering site for species like the spotted redshank, one of the most important sites for this species in the UK. This risk requires further assessment and mitigation.
Protected Species and Coastal Erosion
Surveys have identified the presence of protected species, including nine bat species (such as the barbastelle bat) and an exceptional population of reptiles. Additionally, the siting of borehole BHB in an area prone to coastal erosion is deeply concerning. This location has been breached by recent storms, and any further disturbance could exacerbate the risk of seawater incursion, threatening the protected marsh systems that are vital for breeding bitterns.
Conclusion
Given the significant risks to both the environment and the community, I urge East Suffolk County Council to reject this planning application. The proposed geotechnical surveys in Walberswick would cause irreparable harm to the village’s ecology, economy, and the daily lives of its residents. It is crucial that these concerns are thoroughly addressed before any further action is taken.
Thank you for your attention to this matter. I trust that ESCC will consider these objections carefully and prioritise the protection of Walberswick’s unique environment and community.