Response to December 2024 Consultation
We are disappointed that National Grid did not contact our campaign group in this latest round of consultation for the Sea Link project.
National Grid has repeatedly stated that public consultation is key to developing its plans, but by overlooking the local community who will be directly impacted by Sea Link, these statements seem rather hollow. Nonetheless, we share our views below on your revised plans below. Lack of consultation/information made publicly available.
As this is the final round of consultation before National Grid submits its DCO application to the Planning Inspectorate, we believe that National Grid has a responsibility to be much more transparent to the public and should have provided more information about the impact on both communities and the environment of the proposed Sea Link project in Kent at the pre-application stage.
In particular:
• A full project costing has not been made available
• Visual mock-ups from surrounding roads, homes and amenities have not been provided
• Traffic impacts have been underestimated
• A Cumulative Impact Assessment has not been provided
• A carbon footprint report has not been provided (and this is key when destroying marshland, which is itself a carbon sink). Unsuitability of the new mitigation area.
The newly proposed mitigation area is completely unsuitable and is very unlikely to provide 10% net gain in biodiversity.
This is for a number of reasons:
• Distance: it is not functionally linked to Pegwell Bay which is what makes Minster Marshes so vital to the wildlife which depend on the marshes and the bay. At 3 miles from the bay, it is outside the flight range of the endangered Golden Plover which heavily rely on Minster Marshes at high tide. Adapting existing farming practices will not compensate for this.
• Light pollution: the area already has high levels of light pollution from Thanet Waste, Stevens & Carlotti, Discovery Park and Kent Renewable Energy plant. This will be further exacerbated by 112 newly consented houses across the road at Discovery Park which will cause further light pollution and bring domestic cats – the bane of wild birds.
• Disturbance from human activity: the site is directly adjacent to the A256 Sandwich Bypass, a very busy dual carriageway, with its associated pollution and noise. On the opposite boundary of the site, the Stour’s bank is completely filled with moored houseboats, creating additional disturbance.
• Access to the site appears to be via a new access road through an area of scrub and trees, destroying more existing habitat which will not be mitigated by the planned mitigation area.
Continued use of the former Hoverport
We are pleased that National Grid is no longer considering using the former Hoverport as a compound but dismayed that the revised plans include using it as an access route to Pegwell Bay. This too is functionally linked land to Pegwell Bay and provides a rare habitat for a wide range of endangered species of flora and fauna including the critically endangered Lizard orchid. In addition, the site provides a valuable space for the people of Thanet to engage with their natural environment.
As a peninsula, and one of the most deprived areas in the South East, access to wild space is crucial to residents’ well-being. It will also mean the closure of the newly created King Charles III coastal path for a protracted period of time.
Comment on overall plans
While the remaining elements of National Grid’s proposals have not changed since the last consultation, we reiterate our view that the plans to site Sea Link at Pegwell Bay and Minster Marshes are catastrophic for the environment, for the local economy and our local population. The government has committed to halting species decline by 2030 and increase abundance by 10% by 2042, reducing the risk of species extinction. 1 National Grid’s plans for Sea Link will directly lead to species decline by destroying unique and irreplaceable habitats for wildlife at Pegwell Bay & Minster Marshes.
These include significant populations of 29 red listed bird species, 40 amber listed birds, and 74 other species, including orchids, European Eels and beavers.
Our list of species we have counted on Minster Marshes is attached as an appendix to this submission. No mitigation measures can ever replace or restore the fragile habitats these species rely on. Once they are gone, they are gone forever. In addition, the increased pylon heights and additional pylons will lead to catastrophic bird deaths as this area is part of Europe’s migration ‘superhighway’ for a wide number of migrating birds. We have already seen 179 mute swans killed in a single incident on National Grid’s existing pylon network in the area.
As National Grid is aware, Pegwell Bay is a nationally and internationally protected wetland in recognition of the unique habitat it provides for vast number of species. The legal protections of RAMSAR, NNR, SSSI and SAC are being ignored in these proposals. National Grid ignored these protections in the NEMO link project and failed to implement any of the promised mitigation measures. Pegwell Bay has never recovered from the damage caused by the NEMO construction. Thanet as a region depends heavily on tourism, with 19% of local employment reliant on our tourist industry.
Building a 28m high, 9 hectare converter station will have a hugely detrimental impact on our local economy and landscape, partly due to the construction traffic, road and footpath closures and lengthy construction period. Once constructed, the planned edifice will be vastly out of scale and character with the limited industrial low level buildings in the area.
Natural England’s State of Natural Capital Report for England 2024/3 , published in October 2024, emphasises the capital value of nature and makes clear that marine, coastal margins and wetlands are at particularly high risk and protection of these assets must be of the highest priority. National Grid’s Sea Link plans fly in the face of these recommendations
Position of the converter station
Siting the converter station on marshland will not only contribute to global warming by destroying marshland, which is an essential component of natural carbon capture, but also requires substantially more construction materials (again contributing to global warming) than were the converter to be constructed on stable ground.
National Grid’s own guidance on where to construct substations states ‘land that is prone to floods cannot be considered, or land that is boggy in nature. Equally, land subject to subsidence … cannot be considered.’
As Minster Marshes floods regularly, is boggy and is predicted to suffer from subsidence according to research by the British Geological Survey, we remain baffled that National Grid is pressing ahead with its plans, in the full knowledge that this site is entirely geographically unsuitable.
Further, the additional costs related to constructing on such unstable ground have not been accounted for. We believe that National Grid has not thoroughly evaluated other sites. It is clear that Richborough sub station was identified as the connection point before the Routeing and Siting Study was subsequently carried out.
Credible alternatives on brownfield sites such as Isle of Grain, Kingsnorth, and other areas that could connect easily to Sellindge were discounted too early. The relocation of the NAUTILUS project to the Isle of Grain demonstrates that it is a suitable location for building new infrastructure to support the expansion of the grid and will have a much reduced impact on the environment.
The Sellindge link to Europe is already established so we cannot understand why the Sizewell to Sellindge link was discounted on cost of the undersea cabling alone, when the current plan will now require a huge cost increase from raising the level of the marsh by two meters over at least 9 hectares.
Furthermore, NESO’s plans post 2030 include building another massive undersea cable from Scotland to Richborough which they are apparently happy to finance without problem. It appears that National Grid’s teams are siloed across the many different projects that form part of the ‘Great Grid Upgrade’ and that there are substantial efficiencies and reduced environmental impact that could be delivered through co-location and taking a more joined up and strategic approach. The drive to Net Zero does not need to be and indeed must not be at the expense of the environment and threatened species. There is a better and more sustainable approach, and it should begin with meaningful dialogue with all stakeholders – not a headlong rush to DCO.