Detailed guidance notes for LionLink Consultation - Due 10th March 2026

The purpose of this document is to act as detailed guidance notes for people responding to the NGV consultation. 

THE LANDFALL SITE

I completely reject the choice of Walberswick generally and Manor Field in particular for the landfall site.  It is obvious that Manor Field is a totally inappropriate location for the proposed landfall site given its proximity to a large number of residential properties on 3 sides and to protected habitats on the 4th.  NGV has not produced any evidence to indicate that there won’t be adverse impact on either human or ecological receptors.

I am especially angry about the proposed working hours, including 12 hour days and 7 days a week for possibly 2 years and then within this, 40 days of HDD drilling going on for 24 hours per day. These proposals are completely unacceptable even with any suggested ‘mitigation’.

NGV has failed to undertake any studies to ascertain how lighting, noise and vibration at the landfall site will impact on human receptors, over half of which are over 60.  They claim that the risks to ecological receptors have been mitigated by drilling (using HDD) under the protected habitats, but they have not properly assessed the impacts that the construction work will have on those habitats. compound is to those habitats.  Neither have they fully assessed the risks of ‘frac-out’ from the HDD into the saltmarshes, reedbeds and river adjacent to the landfall site. I do not accept the assurances that NGV give about ‘mitigation’ on human and ecological receptors adjacent to the landfall site.

Why have NGV not adopted seasonal constraints on construction work to protect breeding birds and other wildlife in the SSSI and other protected habitats both onshore and offshore? I do not accept any proposals for construction work at the landfall site that do not include full seasonal constraints for species onshore and offshore.

The PEIR does not contain any real detail about the size, location or layout of the construction compound in Manor Field or the facilities or equipment to be located in it. On these grounds it is impossible to judge the impact of the proposals as stated and I do not accept that the consultation process is valid.

TRAFFIC/TRANSPORT

Although NGV acknowledges that there will be significant construction impacts on local roads (including the B1387, Lodge Road) and Public Rights of Way around Manor Field and the Marshes, the PEIR contains no supporting facts or figures on traffic types, movements, volumes or congestion modelling so we can understand what these impacts will be. This is not a valid consultation in any way!

The B1387 is the only route into and out of Walberswick. It is narrow and windy and is totally unsuitable for Heavy goods Vehicles and Construction traffic, even if NGV state that is only for limited stretches of the road. This should rule out Walberswick as a landfall site altogether.

I do not believe NGV can construct the haul roads and connections to the B1387 without either closing or partly closing the B1387 for periods of time. This will have a disastrous impact on residents of the village, on tourism and interrupt the access of emergency vehicles to the village with associated risks to the welfare of residents.

I object to the fact that Stocks Lane and the PROW at the Northeastern corner of Manor Field have been included in the draft order limits whatever the reasons. No roads or lanes/tracks within the Village (inc. B1387, The Street, Lodge Rd and Stocks Lane) should be used in any way for the construction of the landfall site.

No details are given on the precise routes of the haul roads, their size, structure or how long they will be in situ which makes a nonsense of the ‘consultation’. However, I believe that the construction traffic using the haul roads will have a significant adverse impact on both the protected habitats and residents who live close to them.

Inadequate information has been provided on how construction and traffic vibration will be assessed, and what happens immediately if acceptable levels are exceeded. 

NOISE, LIGHT, VIBRATION AND DUST. 

It is not clear from the proposals how LionLink will impact residents and the surrounding protected habitat.  How will changes to this quiet rural village with dark skies and rural roads particularly in relation to noise, vibration, wind-blown dust and night-time lighting be assessed. 

The PEIR says most noise effects would not be significant, but it admits there could be significant night-time noise from 24-hour drilling works. At present, NGV has not clearly explained how loud this would and exactly what measures would be used to reduce or limit disturbance to the community and protected habitats. Without this information, we cannot judge whether the impact would be acceptable.

NGV also says vibration impacts are not expected to be significant but confirms that vibration from construction traffic has not yet been assessed. Heavy vehicles using narrow roads can cause noticeable vibration in nearby homes over long periods. The report does not yet commit to routes, volumes or controls, so these effects remain uncertain.

NGV says dust will be managed using standard measures like water spraying. Wind speed is not assessed at all despite Walberswick’s exposed coastal setting. Wind-blown dust affects homes, public spaces and nearby protected sites. No wind-triggered limits or stop-work measures are defined.

The village has very dark night skies. NGV give no clear detail on construction or operational lighting levels, how long lights would be on at night, or how light pollution would be limited, or the impact this will have on wildlife, birds and bats.

It is recognised that noise can have an effect on health, wellbeing, productivity and the natural environment. 

INTERFERENCE WITH PUBLIC RIGHTS OF WAY – FOOTPATH CLOSURE

I am writing to oppose the proposals based on the significant disruption they would cause to public rights of way in Walberswick.

LionLink acknowledge in paragraph 5.2.79 (p.40) of the PEIR that:

“The construction of the Proposed Onshore Scheme would also require the temporary diversion of public rights of way, which is assessed as likely to give rise to significant effects.”

The Draft Order Limits encompass all major footpaths providing access to the Marshes, the beach, the Spong Bridge, and the routes to the Old Mill and Dunwich. These paths are essential for residents, visitors, and the wider local economy.

Footfall monitoring undertaken by WALL demonstrates the scale of use and the extent of the impact. Between May 2024 and December 2025, a total of 147,447 people used the affected footpaths. Within this period:

38,659 people used the footpath along the east side of the Landfall (Manor Field) in 2025

14,410 people used the footpath on the west side descending from Stocks Lane in 2025

These are not minor recreational routes—they are heavily used public access corridors that form part of the daily life and identity of the village.

Despite recognising that significant effects are likely, LionLink provide only the statement that “mitigation measures are being developed to minimise significant effects” (p.40). No details have been provided, no diversion routes have been proposed, and no assessment has been offered of accessibility, safety, or continuity of public access during construction.

Given the very high levels of footfall and the centrality of these paths to community wellbeing, recreation, and tourism, the absence of clear mitigation is unacceptable. The proposals would cause substantial and prolonged disruption.

For these reasons, I object to and reject the proposals as currently presented. Detailed, practical, and safe mitigation measures must be published and consulted upon before any decision is taken.

AGE AS A PROTECTED CHARACTERISTC

I am writing to register my opposition to the proposals on the grounds that NGV have failed to assess or address the impacts of the scheme on age as a protected characteristic, despite the fact that Walberswick has one of the oldest age profiles in England and Wales.

The Equality Act 2010 makes age a protected characteristic, and public bodies must have due regard to the needs of older people when exercising planning and regulatory functions. However, the PEIR and associated consultation materials contain no detailed analysis of the age profile of Walberswick, no Equality Impact Assessment specific to the village, and no evidence that NGV have considered the heightened risks to older residents living immediately adjacent to the proposed HDD works.

Government Census 2021 data shows that:

• 43% of Walberswick residents are aged 65 or over, compared with 18.6% nationally.

• 35% of the village is aged 70+, far higher than both national and district averages.

• 11% are aged 85+, an exceptionally high proportion for any community.

This means Walberswick is not simply an “older than average” village; it is a retirementdominated community, with a concentration of residents who are more vulnerable to noise, vibration, disruption, anxiety, access changes, and constructionrelated hazards.

Despite this, NGV have:

• Not undertaken any agespecific assessment of construction impacts.

• Not identified older residents as a vulnerable group.

• Not proposed any tailored mitigation, communication methods, or access arrangements.

• Not demonstrated compliance with the Public Sector Equality Duty.

This omission is particularly serious given that HDD works are proposed within 50 - 100 metres of homes, and the attached document highlights that older people are more susceptible to:

• Sleep disturbance and cardiovascular stress from continuous drilling noise

• Anxiety and confusion caused by prolonged disruption

• Increased risk of falls or isolation if footpaths or access routes are altered

• Difficulty navigating construction traffic, uneven surfaces, or diversions

• Reduced ability to evacuate quickly in the event of an incident

Planning policy, HSE guidance, and statutory nuisance legislation all require heightened protection for vulnerable groups, including older residents. Yet NGV have provided no evidence that they have considered these duties or the specific demographic reality of Walberswick.

Given the scale of the proposed works and the exceptional age profile of the community, this lack of assessment is unacceptable. The proposals cannot be considered compliant with the Equality Act 2010 or with good practice for major infrastructure projects.

A full, transparent, and locally specific Equality Impact Assessment—explicitly addressing age as a protected characteristic—must be undertaken before the scheme progresses further.

ECOLOGY

 I object to and reject the proposals because the PEIR lacks the baseline ecological information required under the Environmental Impact Assessment Regulations 2017. Without adequate survey data, it is impossible to assess the likely significant effects of the development or judge whether the proposed landfall at Walberswick is environmentally acceptable.

Reptiles: No reptile surveys have been carried out around Manor Field or along key parts of the cable route, despite East Suffolk being known for important reptile populations. Independent surveys by WALL show reptiles are present and at risk of being killed or injured, meaning the proposal could breach wildlife legislation without major mitigation.

Marsh harriers: Although reedbed vantage point surveys were undertaken, surrounding farmland—including Manor Field—has not been surveyed, despite being regularly used for feeding. Marsh harriers are a qualifying species of the adjacent SPA, and disturbance could affect the integrity of the SPA population. The only safe drilling window (September–March) conflicts with other species’ requirements.

Nightjars: LionLink surveys failed to record nightjars in areas where WALL surveys confirm their presence. As another SPA qualifying species, inadequate survey effort creates a real risk of significant adverse effects.

Redthroated divers: Large numbers forage offshore in winter. Natural England has already advised that offshore works should not occur between November and March to avoid unacceptable impacts. This directly conflicts with the seasonal constraints needed for marsh harriers.

Bats: Ten bat species have been recorded around Manor Field—an assemblage of national importance—yet the PEIR incorrectly assigns only district/county-level value. Several breeding roosts rely on a narrow habitat corridor leading directly to Manor Field. Proposed 24hour drilling and lighting would cause major disturbance. The only safe working window (November–March) again conflicts with other species’ requirements.

Otters/WaterVoles: Both species are frequently seen on the marshes below Manor Field and above the HDD zone and are sensitive to disturbance and changes to water quality. These risks have not been assessed.

Invertebrates: Important invertebrates, including moth species sensitive to light, hydrology and water quality changes, use the marshes below Manor Field. These risks have not been assessed.

Summary: The ecological baseline is incomplete and does not meet EIA Regulations. The PEIR wrongly concludes that internationalscale impacts are unlikely, despite clear risks to SPA species and functionally linked land. Seasonal mitigation is impossible because the requirements of different protected species directly conflict. This demonstrates that Walberswick is not a viable landfall site.

For these reasons, I object to and reject the proposals as currently presented.

ARCHEALOGICAL AND HISTORICAL REMAINS

I am writing to oppose the proposed Landfall site on Manor Field and the Draft Order Limits near Walberswick. The area includes land where the ancient village and medieval harbour of Walberswick were located, yet the PEIR has not adequately assessed the archaeological risks.

Although NGV state that the historic environment has been considered (PEIR para. 5.2.35), no meaningful investigation has been carried out beyond the end of Stocks Lane or around the caravan site—precisely where the medieval harbour is likely to lie. This omission is serious. From the early 14th to late 16th centuries, Walberswick was a major trading port serving Dunwich, Southwold and Blythburgh. Recent research by Dr Tom Johnson (University of Oxford) indicates that the harbour would have contained substantial structures linked to trade, shipbuilding and fishing. When the new river entrance was cut in 1590, the old harbour silted up, increasing the likelihood that remains are well preserved and potentially of national significance.

The site is difficult to investigate due to mudbanks, saltmarsh and shifting river channels, which explains the lack of finds to date but not the lack of assessment. The proposed cable route may pass directly through this sensitive area.

Historic England have already raised concerns about slurry breakout from Horizontal Directional Drilling (PEIR Vol. 1, Table 11.4). The applicant’s response—that any remains would simply be removed—is inadequate and inappropriate. If a medieval harbour survives, it should not be removed, and it is impossible to remove remains that have not yet been identified. Even deeper drilling risks destabilising waterlogged deposits, including older maritime timbers.

Given these risks, the harbour area must be given far greater priority. A thorough archaeological evaluation is required before any decision is taken, with specific assessment of the potential impacts of HDD.

On this basis, I object to and reject the current proposals.

CUMULATIVE IMPACT

I am submitting this response to oppose, object to, and reject the LionLink proposals on the grounds that the PEIR fails to provide a meaningful, transparent or assessable cumulative effects assessment. The cumulative impacts of this project—when combined with the extensive programme of energy and infrastructure schemes already affecting the Suffolk coast—are central to understanding the true scale of harm. Yet NGV have deferred almost all substantive cumulative analysis to a later stage, preventing consultees from making an informed judgement at this statutory consultation.

1. Cumulative impacts are deferred beyond consultation NGV repeatedly state that cumulative effects and any additional mitigation will be addressed only at ES stage. This means the consultation is taking place without the essential information needed to judge regional impacts.

2. The PEIR provides methodology, not assessment Chapter 28 describes a process but does not present a cumulative picture by receptor, quantify combined effects, or map overlapping construction phases. This is not an assessment of significance.

3. Scoping rules risk underestimating real cumulative impacts Automatic exclusion of Tier 3 plan allocations and treating completed projects as “future baseline” both risk understating the true cumulative burden on communities already facing sequential disruption.

4. The cumulative baseline is out of date Appendix 28.1 relies on an “August 2025” status snapshot for a January 2026 consultation, meaning key projects may be missing or mischaracterised.

5. No coordinated cumulative mitigation is presented There is no enforceable strategy for managing combined traffic, noise, ecological disturbance, landscape change or socioeconomic impacts. References to “coordination” are not mitigation unless secured through binding controls.

Conclusion The cumulative assessment in the PEIR is incomplete, outdated and overly reliant on future work. It does not allow consultees to understand the real combined impacts of LionLink within an already heavily burdened region. On this basis, I object to and reject the proposals and request that NGV publish updated cumulative information before progressing toward a DCO application.

CONVERTER STATION AND KILN LANE SUBSTATION

The converter station for LionLink will be built right next door to the proposed converter station for SeaLink. Both these converter stations are in totally the wrong location, too close to Saxmundham and put residents at risk from noise, EMF and other hazards. The buildings are much too big and none of the design options are acceptable. The site is wholly unsuitable.  Similarly, the location of the Kiln Lane Substation is fundamentally unsuitable for a major energy hub. It would intensify the industrialisation of Friston, adding, noise, light and landscape harm. 

THE CASE AGAINST LIONLINK

The current plan to construct Sea Link, LionLink, and associated onshore infrastructure on the Suffolk coast represents a fundamental failure of economic judgement, strategic planning, and modern energy system design. The proposals are misaligned with the UK’s own Green Book appraisal standards, inconsistent with international best practice, and blind to the severe cumulative economic harm they would impose on one of the most sensitive coastal regions in the country.

A coherent economic assessment leads to only one conclusion: This entire programme must be reconsidered, strategically reset, and compared properly with an offshore grid alternative before any consenting decisions are taken.

1. The Combined Sea Link + LionLink Onshore Approach Is Economic Madness

The idea of bringing gigawatts of electricity ashore on the Suffolk coast—only to route it back offshore or across the country—is structurally irrational. It ignores the now established European model of integrated offshore grids, which are cheaper, more secure, and far less socially disruptive.

The UK is alone in attempting to deliver offshore energy growth via multiple independent onshore landfalls, each carving up the same communities and landscapes while delivering system benefits that could be achieved offshore with a fraction of the impact. 

The Sea Link + LionLink combination:

• fails the test of whole system efficiency

• misallocates economic risk

• misrepresents cumulative impacts

• ignores place-based sensitivity

• breaches modern appraisal standards

• creates irreversible planning lock in

It is not the “least cost” solution. It is simply the solution that fits outdated planning constraints, not the realities of the energy system of the 2030s and 2040s.

2. A Strategic Offshore Grid Must Be Properly Evaluated

The updated H.M. Treasury Green Book (2026) requires government and delivery bodies to assess genuine strategic alternatives, especially where cumulative or place specific impacts are severe.

An offshore grid is:

• already being pursued by Belgium, the Netherlands, Denmark and Germany

• demonstrably cheaper at system level

• far more resilient

• able to eliminate the need for multiple coastal landfalls

• able to avoid years of disruption to visitor dependent economies

The National Infrastructure Commission, Ofgem, and the ESO all acknowledge that emerging offshore hybrid solutions will dominate the next phase of energy system expansion. Before Sea Link or LionLink proceed further, a full, strategic, place sensitive comparison with an offshore grid solution should be mandatory.

Anything less is fiscally negligent.

3. If Sea Link Proceeds, Adding LionLink Is Economically Disastrous

Once Sea Link is added to an already congested Sizewell C corridor, the system becomes fragile. Adding LionLink on top:

• multiplies non-linear congestion and transport harms

• adds critical path risk to Sizewell C

• intensifies wellbeing and mental health burdens

• compounds tourism and amenity losses

• creates multiyear reputational damage to the Suffolk coast

• locks the region into decades of sequential NSIP disruption

LionLink’s own PEIR admits that its evidence base is preliminary and non-quantified on transport impacts—yet its traffic will land precisely where the system is most fragile. “Layering LionLink on Sea Link” is not an energy project. It is an economic self-harm exercise.

4. Isle of Grain Is a Proven, Lower Impact, Regulator Tested Alternative for LionLink

The relocation of Nautilus to the Isle of Grain is a watershed moment.

It proves that:

• major offshore hybrid interconnectors do not require Suffolk landfall

• the UK already has a Netherlands–UK interconnector (BritNed) at Grain

• the site is a mature energy hub with far lower marginal social cost

Ofgem will support relocation when the strategic case is clear. National Grid Ventures can and will release Suffolk connection agreements when they are unjustifiable. If the UK wants LionLink, Grain is the logical location. The Suffolk coast is not.

5. If LionLink Goes Ahead Regardless, Walberswick Is Categorically Not a Viable Landing Site

Walberswick is:

• a high end, reputation sensitive tourism destination

• adjacent to internationally designated habitats

• dependent on tranquillity, landscape quality and nature-based recreation

• served by a single, fragile access route (B1387)

• identified in LionLink’s own PEIR as having significant landscape, health and amenity impacts

The idea that Walberswick can absorb a year of night lit construction, noise, heavy works compounds, and coastal disruption without severe economic and wellbeing consequences is indefensible.

If LionLink proceeds at all, its UK landfall must be reconsidered. The options requiring serious examination are:

• Isle of Grain, as the strategic and low impact model (preferred)

• Integration adjacent to Sizewell / Sea Link, where infrastructure is already concentrated and impacts can be co-managed (fallback)

Walberswick is not an appropriate, fair or sustainable location.

Conclusion

The economic logic is overwhelming:

• The Sea Link + LionLink onshore programme is fundamentally flawed.

• A strategic offshore grid is the only credible whole system solution.

• If Sea Link proceeds, LionLink must be reconsidered—economically, spatially, and strategically.

• The Isle of Grain offers a regulator tested, low impact alternative for LionLink.

• And under no circumstances is Walberswick a viable landfall site.

This programme needs to go back to strategic drawing board level before irreversible harm is done to Suffolk’s economy, communities and natural capital.