Lincolnshire County Council Executive Board

Lincolnshire County Council County Offices

Newland Lincoln LN1 1YL

06 March 2024

Whom it may concern,

National Grid Electricity Transmission – Non Statutory Consultation on Grimsby to Walpole 
Overhead Transmission Lines and Associated Substation 

The comments of Lincolnshire County Council set out in this letter follow the Executive 
meeting of the Council on 5th March 2024; who received a report in response to the nonstatutory consultation by National Grid Electricity Transmission (NGET) upon the Grimsby to 
Walpole proposal, to provide a new 400KV overhead electricity transmission line and 
associated substations. 
This representation sets out the formal objection of the County Council to the consultation.
Given the nature and extent of the matters of concern to the Council, it is not practical for 
these to be expressed using the format of NGET’s consultation feedback form.
At its meeting on 9 January 2024 the Executive received a presentation by representatives of 
NGET on the forthcoming non-statutory consultation for the Grimsby to Walpole onshore 
overhead line proposal. At this meeting the Executive requested NGET to bring forth its 
business case and costing in line with Treasury Green book principles for each of the 3 options 
referred to in the consultation document. At the time of writing, this consultation response 
has still not been received. 
The Council notes that the Grimsby to Walpole proposals are part of a scheme to upgrade the 
electricity network and infrastructure known as ‘The Great Grid Upgrade’ and developed by 
NGET. Whilst the Council notes that the proposal is in the very early stages of development,
the precise location and design of the proposal is not yet available, and there are no 
environmental assessment reports available at this time to assess the environmental impacts 
of the proposal.
It is noted that in addition to the overhead lines five substations are also proposed as follows:-
• One substation, to be located in the vicinity of the existing Grimsby West substation, 
to replace the existing substation and to connect three solar energy/battery storage 
projects, plus two additional supergrid transformers for Northern Powergrid.
• Two connection substations south west of Mablethorpe and north-east of Alford, to 
facilitate the connection of planned offshore wind generation, interconnectors with 
other countries and a subsea link from Scotland.
• One substation near existing overhead lines at Weston Marsh, north east of Spalding, 
to connect an offshore windfarm and two solar energy/battery storage projects. 
• One substation in the vicinity of the existing Walpole substation, to connect proposed 
subsea links from Scotland and a combined cycle gas turbine power station.
It is disappointing that at this stage, other than listing the committed connection points, for a 
significant number of energy projects to connect into the substations, no reference is made 
to the additional onshore infrastructure that each of these energy projects will require. The 
cumulative impact from the overhead lines pylons, NGET substations and those substations 
that will be required for the other energy projects, would overwhelm the community of 
Alford, and have the potential to significantly adversely impact on the character and 
appearance of the Lincolnshire Wolds Area of Outstanding Natural Beauty.
It is of great concern to the Council that the Strategic Options report, that is part of the 
consultation documents, is flimsy in detail without any clear basis of methodology for the 
costs benefits analysis of the different options, or how the conclusions were reached to adopt 
the overhead lines proposal and discount the other options.
The Council questions why the subsea option has been discounted on an economic 
perspective, on the basis that it would be significantly more expensive to both build and 
maintain over a 40-year period. The Council requests that the details of how this conclusion 
was reached is provided as a matter of urgency; and is why the Executive requested the
business case and financial assessment based on Treasury Green Book principles for all 
options during the presentation on 9th January. As previously highlighted, to date no such 
detail has been provided.
Whilst it is acknowledged that the various options that have been provided in the strategic 
options report is helpful in setting out National Grid’s position, it is considered essential that 
a more comprehensive and cohesive evidence base is provided to the Council and the 
communities that it represents, to show that other options such as the reinforcement of 
existing Grid infrastructure, an off-shore subsea connection or underground cables are not 
feasible or desirable alternative.
The strategic report includes 2 off-shore, subsea options from the Grimsby sub-station; one 
of these involves a proportion of the cable being off-shore and making landfall around the 
Anderby Creek area and then following an on-shore route to Walpole. The other option is for 
a subsea cable from Grimsby to the Norfolk Coastline involving 190km of cable, without the 
need for the on-shore infrastructure, but would involve landfall in the Wash Estuary on the 
Norfolk coastline line impacting on sensitive nature conservation areas. 
The onshore option that is proposed has a capital cost estimate (including substations) of 
£1,074 million, compared to £4,391.7 million for an equivalent subsea option (including 
substations). This costing has no regard to the compensation required for the loss of tourism 
and property prices; and the Council will want to have assurance that the same approach has 
been taken for both options. For instance, does the onshore option include the costings for 
the connection infrastructure of prospective energy projects which it is understood the 
subsea option does?
Whilst the strategic option report is helpful in allowing a partial understanding of how the 
various options have been considered, it is not helpful in setting out the reasons for dismissing 
the subsea option, other than on purely cost grounds but without detailed investigation of 
technical, environmental and socio-economic criteria being undertaken.
The Council will pursue rigorously the subsea option and NGET should be aware that 
fundamentally this is the only correct approach. It is the Council view that there is no 
mitigation possible that can manage the unacceptable impact of overhead lines and 
associated infrastructure on the natural and historic landscape of the east of the County. 
There are numerous planning decision by Planning Inspectors going back many years that 
clearly indicate that tall vertical structures in flat open landscape can never be justified due 
to the scale of impact on the landscape over a very wide area.
In addition, the Council is confused as to why NGET did not propose the shorter T-pylon design 
for the project as a whole and would be grateful for NGET explanation for this. T-pylons have 
a precedent in being used in other projects. 
Substations – 3 substations are proposed in Lincolnshire 2 between Mablethorpe and Alford 
and one to the north-east of Spalding. The substations provide a means of connection for 
multiple energy projects some from the local area and others from much further afield such 
as Scotland which involve the use of subsea cables for up to 500km 
The Council would like NGET to provide an explanation as why it is cost effective for a 500km 
subsea cable to be used to the Lincolnshire coast from Aberdeenshire, and why is it not 
possible to extend such cables via a subsea option for a further 200km to make landfall at 
Whilst details are still to emerge of the necessary infrastructure for these substations it must 
be questioned if any mitigation and screening can be effective in such an unspoilt landscape 
that currently exist in the areas of search. This is exacerbated by the very fact of the purpose 
of these substations is to provide connection points, for other energy projects, which in many 
cases will require their own substations, and therefore the cumulative impacts from these 
additional infrastructure needs to be taken into account, in both the construction and 
operation of the other substations that will need to be developed in proximity to the NGET 
It is considered essential that NGET commit to producing a masterplan of the substation 
areas; to consider not only the NGET substations, but also the other substations from other 
energy companies that will be necessary so that this can be considered holistically, rather 
than in an unplanned incremental approach as developers bring their proposals forward at 
some future date.
Due to the lack of detail at this stage it is not possible to provide any specific technical 
response to the proposals, as significant amount of background and environmental 
information remains to be presented at later stages as the project evolves. When this 
information is presented at future consultation phases the Council will in due course provide 
specific technical comments in the following areas:-
• Cultural heritage including archaeology and historic environment.
• Ecology.
• Economic Development.
• Emergency Planning/Fire and Rescue.
• Highways and transport.
• Landscape and Visual impact.
• Lead Local Flood Authority and Flood advice.
• Public Heath.
• Pubic Rights of Way.
• Soils and Agriculture.
• Waste and Minerals Planning Authority.
At this stage in the process, however, the Council wish to make it fundamentally clear that
from information provided, and the initial public reaction to the proposal, that the scheme 
will have the potential to have significant impact on large swathes of the landscape of the 
area when viewed from both distance, and locally in relation to the Fens and the impact on 
and from the AONB. The loss of best and most versatile agricultural land which is critical to 
national food security has also been given no consideration.
The Council wish to draw NGET attention to other localised considerations in respect of local 
environmental impact, ecological impact, heritage impact and localised residential amenity 
which cannot be fully assessed at this stage, given the absence of a defined route, and 
therefore detailed technical submissions. 
Also, in close proximity the Lincolnshire coast, forms part of the East Atlantic Flyway and is 
registered as one of the seven sites in the UK on the tentative list for UNESCO World Heritage 
site status. These sites include some of the country’s most valuable natural areas and are 
recognised for being of Outstanding Universal Value for their global significance to nature 
conservation. The East Coast Wetlands are a nationally and internationally recognised habitat 
for waterbird populations, with 29 species found in internationally important numbers across 
21 existing Special Protection Areas (SPAs) including, in Lincolnshire; The Humber Estuary, 
The Wash and Gibraltar Point.
Energy Infrastructure Position Statement
On 5 December 2023 the Council adopted an Energy Infrastructure Position Statement which 
set out the principles that should be applied in responding to Nationally Significant 
Infrastructure Projects. One of the principles of this position statement is that all new grid 
infrastructure required to connect energy development to the grid should be predicated on 
underground first, or on existing routes. 
The Council’s position is that it does not, and will not, support any new overhead pylon lines 
which impact on the county and its vitally important landscapes; and should be prepared to 
explore with developers any new technologies such as smart grids which address the need 
for energy whilst being sensitive and suitable to the natural environment.
The Council recognises that NGET have been tasked with delivering new infrastructure to 
connect energy developments that will reduce carbon emissions, to decarbonise the grid, 
improve energy supply resilience, and help to meet the challenges of climate change. 
However, taking into account the Councils recently adopted Energy Infrastructure Position 
Statement the Council’s clear preference is for a coordinated, offshore centred approach, 
delivered at pace, to minimise onshore infrastructure in Lincolnshire. If this approach can 
deliver an alternative to the current onshore proposals in a timely manner, without risking 
wider Net Zero, renewable generation, and decarbonisation targets, it would be welcomed 
by the Council and the communities it represents. 
Unfortunately, at this stage the Council considers that in the consultation documentation, 
NGET have not presented a comprehensive and conclusive set of evidence that the 
transmission objectives of this project cannot be met using an offshore link or links, with less 
harmful impacts on the terrestrial environment of Lincolnshire.
The Council reiterates the need for NGET to supply the full business cases and costings that 
have been mentioned in the consultation document. NGET should provide this information 
to the wider public as soon as possible in advance of the next round of consultation. 
The Council will be commissioning its own independent review of the strategic options 
appraisal, and this report when available, will be presented to support the Councils case that 
alternative options have been dismissed on the basis of cost alone without detailed 
investigation of technical, environment and socio-economic criteria being undertaken.
For the reasons set out above, the Council is left with no option but to formally object to the 
proposals as currently presented, and would request that further work is done to 
demonstrate in a sequential approach and recognising that the Council will never support 
overhead pylons and the alternatives in order of preference are:-
• Considers alternative reinforcement to the existing National Grid infrastructure.
• Subsea option.
• Underground cabling.
The Council is prepared to continue to work with NGET in developing its proposals and provide 
technical feedback and engagement at appropriate times, based on the above. If you require 
any further clarification or assistance on this matter, please do not hesitate to contact Neil 
McBride, Head of Planning (
Yours sincerely 
Councillor Martin Hill OBE
Leader, Lincolnshire County Council
Chairman of the Executive Board
Councillor Colin Davie 
Executive Councillor 
Economic Development, Environment and 
Lincolnshire County Council
Victoria Atkins MP
Gareth Davies MP
Rt Hon Sir John Hayes MP
Dr Caroline Johnson MP
Rt Hon Sir Edward Leigh MP
Karl McCartney MP
Matt Warman MP
Martin Vickers MP
Holly Mumby-Croft MP 
Andrew Percy MP
Lia Nici MP
Alicia Kerns MP
Claire Coutinho MP, Secretary of State for Energy Security and Net Zero
Lincolnshire County Councillors
Cllr Craig Leyland, Leader of East Lindsey District Council
Cllr Anne Dorrian, Leader of Boston Borough Council
Cllr Nick Worth, Leader of South Holland District Council
Stephen Jack, Lincolnshire Wolds Countryside Service Manager, Lincolnshire County Council 
Dr Tony Juniper CBE, Chair of Natural England
Mark McAllister, Chair of Ofgem
Charley Cranmer, No Lincs Pylons
Paul Learoyd, Chief Executive of Lincolnshire Wildlife Trust

Published: Tuesday, 12th March 2024