The views expressed in this page do not represent those of the Planning Inspectorate. This page consists of content submitted to the Planning Inspectorate by the public and other interested parties, giving their views of this proposal.
The Sizewell C Project
Received 24 September 2020
From Allan Warner
“Relevant Representations of Stop Sizewell C (the campaign name of Theberton and Eastbridge Action Group on Sizewell Ltd) 1. Application Explanatory Memorandum We wish to raise concerns about the Planning Statement generally including Status of DCO plans and proposed use of ‘Not for Approval’ plans Consents and Powers in the Draft DCO Approach to environmental mitigation, management and development flexibility Approach to Subsequent Approvals Planning conditions and legal agreements Approach to Environmental Mitigation and Management The Approach to Flexibility (Rochdale Envelope) NPS EN-1 and NPS EN-6: Applying the Policies to the Sizewell C Application Compliance with Planning Act 2008 (as amended) and relevant national policy statements for major infrastructure Regional and Local Planning Policy UK Marine Policy Statement 2011 Construction worker Social/Community Mitigation Transport and Freight Management strategy Planning Assessment – Benefits and Assessment Principles Common Law Nuisance and Statutory Nuisance 2. Site Selection The UK Government’s 2011/existing National Policy Statement for Nuclear Power Generation EN-6 concludes that Sizewell is a potentially suitable site for new nuclear power stations before 2025. This conclusion is out of date as the EN-6 assessments predate government acceptance of the Paris agreement on climate change and legislation to make the UK Zero Carbon by 2050 We believe this is the wrong project in the wrong place because The development cannot be operating before 2025; The site is at risk from climate change, sea level rise and fluvial flooding; It will have an adverse impact on adjacent internationally designated sites of ecological importance; It will have an adverse impact on coastal processes; It will have an adverse impact on sites of amenity, cultural heritage and landscape value; The carbon footprint of Sizewell C’s construction will have an adverse impact on carbon targets; it cannot positively contribute to UK’s carbon neutral timetable until 2040 at the earliest; The 32 ha twin reactor development (c.f. Hinkley Point C 45ha) requires unacceptable increased coastal exposure, relocation of existing Sizewell B facilities, other design compromises and is well below the EN-6 presumption of 30ha for a single reactor installation; There are eight other uncoordinated energy projects planned for the locality; resulting in significant cumulative impacts to the East Suffolk environment and economy; There is no sustainable solution for the safe disposal of nuclear waste. Spent fuel and high-level waste from Sizewell B and C would stay on this eroding coastal site until at least 2135. Climate change and rising sea levels mean that the site is likely to become an island containing 5 nuclear reactors. There are major concerns over flooding and overtopping during storm surges, and ultimately the site will become an island if sea levels rise to predicted levels. 3. Local communities The development would have unacceptable impacts on local communities, in particular Leiston, Sizewell, Eastbridge and Theberton; and settlements along the B1122 and A12. Residents of our Parish will experience noise increases of 600 times ambient noise including Old Abbey Care Home can expect noise to increase 200 times current levels. 4. Worker Campus The campus would have significant impacts on local communities during construction and thereafter because of noise, light, pollution, traffic and social pressures. The developer does not provide sufficient justification for its location and impacts. Following a consultants’ study on site options Suffolk CC suggested consideration of relocation of the proposed campus to alternative locations. EDF has not adequately responded to this suggestion. 5. Transport EDF’s transport strategy has rejected a marine/jetty component due to environmental and geomorphological concerns but the extensive use of rail has also been rejected with insufficient justification. The “integrated” road based transport strategy is not sustainable and would have an adverse impact on local communities and result in significant damage to the East Suffolk visitor economy. HGV numbers are as high as under EDF’s “road led” strategy rejected at Stage 4 consultations. Significant upgrades to the A12 and B1122 are not proposed to be started before site preparations and significant earthworks start. Several of the other energy projects are likely to be in progress at this time with the Sizewell B facilities relocation likely to be at its peak of HGV movements. The proposed timing of these upgrades needs to be brought forward to avoid significant impacts to communities along the A12 and B1122. The current proposal for the Sizewell Link Road will isolate and sever communities, damage the rural footpath system and divide farmland threatening viability. The proposed route has little legacy value for communities and would perpetuate damages and community severance. Sizewell Link Road alternative routes have been dismissed as options by EDF with insufficient justification. 6. Landscape & Heritage The proposed development, by virtue of locality, design and scale, would have a catastrophic long term impact on landscape character. It would have an adverse impact on integrity of the AONB and many nationally and internationally important nature conservation areas. The planned mitigations for landscape and ecological damage are inadequate and would not compensate for the damage done during construction and for the lifetime of the power station. The proposed development would affect the settings of 90 heritage assets. 7. Environment Impacts on Minsmere Sluice cannot be assessed due to the combination of changes in ground and surface water combined with an incomplete plan for access to potable and construction water supplies. The environmental implications of the proposed stockpile and spoil storage areas is unclear with contradictory statements and assessments The construction phase of the development would result in unacceptable levels of environmental pollution, including from light, noise, traffic and dust. Mitigation of the environmental impact of the proposed borrow pits and subsequent landfill and other areas of landfill has not been addressed. The development does not address the potential adverse impacts on the ecological value of species and habitats in the marine and terrestrial environment. Implications for the integrity of designated sites, including internationally designated sites - European sites and European marine sites - nationally designated sites - SSSIs, the AONB - and impact on local, regionally and nationally significant natural history is not adequately addressed. RSPB Minsmere is of international significance. We are concerned that Minsmere would be irreparably harmed by the proposed development. This would damage the UK’s reputation for conservation as well as the visitor economy. EDF recognises that there could be impacts on Marsh Harriers which are protected species The proposed development does not fully address the need to provide an adequate drainage and water supply for the construction period and beyond. Abstraction of water will have impacts which will need to be managed to avoid risks to the environment and to protected species. The risks to groundwater levels and surrounding habitats and ecology have not been adequately assessed and mitigated. Proposals increase flood risk due to the loss of flood storage from the main development site footprint. 8. Marine and Coastal processes The effect of Sizewell C on coastal processes is unclear as its current hard coastal defence structure is incomplete and therefore cannot be assessed. Site safety, ecological and flood risk impacts by an incomplete hard coastal defence feature cannot be assessed. The rates of erosion and recession along the site frontage, to the north and south of the site cannot be understood until there is a completed design for the hard and soft coastal defences The Monitoring and Mitigation Plan, being discussed with local authorities, needs to be made public for assessment at the examination and the Marine Technical Forum responsibilities, powers and transparency need to be defined. EDF predictions of when the hard coastal defence will be exposed cannot be taken seriously when no finalised design has been made available and any adaptation strategies for the incomplete design have been specified. EDF have not justified the assertion that coastal effects to the south will not extend beyond the coralline crag to the north of Thorpeness. EDF cannot justify the assertion of shingle accretion north of the site until a complete design of the hard coastal defence is presented for assessment. The impacts on marine ecology during construction and operation has not been adequately assessed. 9. Economic and social impacts EDF’s own surveys show that a significant percentage of visitors will be deterred from visiting the area during construction, thereby damaging the Suffolk coast visitor economy. Suffolk Coast Destination Management Organisation found that tourism could lose up to £40 million a year, with the potential loss of up to 400 jobs. Unacceptable pressure on local housing accommodation. Inadequate information to address local supply chain advantages and disadvantages. Does not address the funding of a Leiston economic development/ regeneration programme. Does not address the impact of the development on the availability of tourism accommodation, particularly during construction. Does not adequately address the impact on jobs and skills, during construction and operation. Does not address the issue of locally based employment. Sectoral work is inadequate and does not help to explain what jobs, at what skills/remuneration levels, will be available to local people. Socio economic aspects of development are not adequately addressed by the developer. Details of proposed housing and tourism funds inadequate. Minimal consideration of potential negative impacts on local businesses outside the nuclear supply chain whether through competition or disruption to investment. No account of the long term negative impact on the environment and the future natural capital and tourism value of the site, i.e. no long term view emerging of the economic legacy of a comparable project other than jobs created in the nuclear sector. Applicant fails to explain how vulnerable children and adults in the local area might be impacted in the short, medium and long term. 10. Associated Development Impact of the Yoxford roundabout on local residents and traffic Location of the Park and Ride facilities The Two Villages ByPass Location of the Freight Management Centre”