Representation by Erica Rae
- Date submitted
- 19 August 2020
- Submitted by
- Members of the public/businesses
As a resident of Yoxford in Suffolk, and in response to EDF’s planning submission for Sizewell C, I would like to register my opposition to the scheme. Nuclear strategy, cost and renewables: The UK Government’s nuclear policy, and approval for up to eight new plants is a decade old. Whilst I have no major issue with nuclear in general, I do have major concerns about not only the proposed site in Sizewell, but the economics of the Government’s strategy. Current research demonstrates clearly that the lower cost of renewable energy sources could prove a much better cost model for the country, whilst meeting objectives for green and renewable energy solutions. The National Infrastructure Commission (NIC) launched by the Conservative Government in 2015 has stated publicly that: “They [the government] say full speed. We’re suggesting it’s not necessary to rush ahead with nuclear. Because during the next 10 years we should get a lot more certainty about just how far we can rely on renewables.” Given the significant requirement with nuclear to provide significant government i.e. taxpayer underwriting or support, and the recent moves by Hitachi and Toshiba to pull out of nuclear in the UK it would imprudent not to re-evaluate the cost and efficacy of renewable solutions as an alternate strategy. EDF has a guaranteed fixed price for each unit of energy produced at Hinkley for its first 35 years of operation. In 2012, the “strike price” – was set at £92.50 per megawatt hour, to rise with inflation. This means that if the wholesale price of electricity across the country falls below £92.50, EDF will receive an extra payment from the consumer as a “top-up” to fill the gap which will be added to electricity bills around the country. The current wholesale price is around £40 per MWh. This cost to the UK consumer and taxpayer is also significantly higher than the £39.65 fee agreed in the latest round of offshore wind projects, but even so has meant EDF cutting it’s estimated rate of return from Hinkley to 7.6% as from 8.5% two years ago. Even with that commitment from the UK Government EDF are rumoured to be concerned about their ability to complete the project before the current deadline of 2025. Gérard Magnin, a former EDF director, has been quoted as saying that the French company sees Hinkley as “a way to make the British fund the renaissance of nuclear in France”. He added: “We cannot be sure that in 2060 or 2065, British pensioners, who are currently at school, will not still be paying for the advancement of the nuclear industry in France.” The Government is looking at an alternate Nuclear RAB model, but that could mean UK taxpayers undertaking to fund cost over-runs, an equally risky and potentially costly strategy given the escalation in costs and timeline at Hinkley, and EDF’s domestic delays at Flamanville. EDF and other projects: EDF’s cost overruns are material versus the EDF market cap offered by the UK Government, and has negatively impacted their share price. EDF also has problems at home where its Flamanville reactor, using the same design as Hinkley Point is years behind schedule and way over budget. French President Emmanuel Macron has asked EDF to prove that it can build new nuclear power stations at lower cost amid falling renewable energy prices. Construction work began in December 2007 at the Flamanville site. The EPR reactor was originally expected to start commercial operation in 2013 and cost EUR3.3 billion (USD3.6 billion). However, the project has been beset by delays and cost increases. Last October, EDF said necessary repairs to the reactor's main secondary system penetration welds will further increase the cost of constructing the Flamanville EPR to EUR12.4 billion. The loading of fuel into the reactor has also been further delayed until the end of 2022. (Another EPR reactor in western Finland is already more than a decade behind schedule.) Tourism Economy: The proposed construction site will damage the local tourism economy, in addition to substantially reducing the quality of life for residents. In 2018 it was reported from figures released by Visit Suffolk, that tourism delivers £2bn annually in revenue for the county. With growth of +5% in 2017, jobs in the county’s tourism sector rose by 6% to 42,428, and in total delivered 13.6% of all employment in Suffolk. This will be substantially at risk from the proposed construction of Sizewell C Jobs: EDF make much of the undoubted number of jobs the project will create, however there is a strong argument that much of the labour will be from outside the county as it has been at Hinkley Point. In figures for 2017, Suffolk had unemployment rates of 3.7%, under the UK national average of 4.1%, so whilst job creation is always attractive, there should be serious consideration of the potential benefits, versus threats to jobs from damage to the Tourism economy EDF’s definition of ‘local’ workers for Hinkley Point also generously includes those with up to a 90 minute commute. Not only does this stretch the definition of ‘local’, but it risks increasing the already worrying amount of vehicular traffic. Security: The Government’s decision to eliminate Huawei from the UK’s 5G networks and the negative impact on Chinese relations, must have a bearing on whether to green-light a major nuclear project with significant Chinese investment. HUAWEI will be completely removed from the UK’s 5G networks by the end of 2027, the government has announced, following new advice produced by the National Cyber Security Centre (NCSC) on the impact of US sanctions against the telecommunications vendor. [Redacted] Local transport/Yoxford Bypass/D2 relief road: EDF have proposed a road by-pass between the A12, originating between Yoxford and Kelsale, and the B1122 ONLY in the event of a road led strategy being deployed. I would argue that a road by-pass of Yoxford must be implemented in any eventuality. The A12 through the village is already a busy pinch point with a sharp bend that raises safety concerns. If between 450-750 new HGV journeys were introduced each day, this risk would be substantially increased. The proposed road by-pass as proposed by EDF, will not provide any long-term benefit to the community, and is not supported by Local Highways. The optimal solution would be to build a direct route to the A12 with a connection just south of Saxmundham, known as the D2 route. The creation of the D2 relief road would have positive effects for the delivery of materials and workers to the Sizewell C development, the evacuation plans for Sizewell B and for the construction and maintenance of a substation infrastructure sited at Friston or Sizewell. It would also help to alleviate significant resident disruption, illegal levels of toxicity from slow traffic and environmental damage. Safety: The current road proposal does not adequately provide for safe, fast evacuation plans in the event of any accident or emergency at Sizewell. In 17/18, six postcodes in east Suffolk were ranked among the ten worst in the country for ambulance response times. EDF’s proposal for Sizewell C will substantially increase road traffic (with either strategy) on inadequately designed roads, and significantly exacerbate this risk for residents. [Redacted] There is no provision for a pedestrian crossing on the A12 at Yoxford. The A12 is already a busy road to cross safely at peak times, and increased traffic will further compromise the safety of residents and fragment the village. Pollution/Emissions: EDF’s proposal estimates increased road traffic at between 450-750 HGV’s per day, dependent on whether the rail or road led strategy goes ahead. Heavy goods vehicles (HGVs) are estimated to account for around 17% of UK greenhouse gas (GHG) emissions from road transport and around 21% of road transport NO? emissions, while making up just 5% of vehicle miles. The Government has stated that meeting our climate change targets will require GHG emissions reductions across all sectors of the economy, including road freight. The government has a stated commitment to improving UK air quality and has published increasing evidence that air quality has an important effect on public health, the economy, and the environment. According to Public Health England, poor air quality is the largest environmental risk to public health in the UK1. Evidence from the World Health Organization (WHO) shows that older people, children, people with pre-existing lung and heart conditions, and people on lower incomes may be most at risk. [Redacted] EDF’s proposals do not adequately prescribe the emissions standards of either freight vehicles, or local supplementary supplier traffic. However, what is in no doubt, is the inevitable negative impact on the health of local people due to traffic pollution. Environmental impact: Suffolk and the area directly around the proposed scheme at Sizewell is home to some significantly important areas of scientific interest and the natural habitat for many indigenous and migrant species. This obviously includes the RSPB reserve at Minsmere and the valuable work done by the Suffolk Wildlife Trust. Nothing I have read in the submissions from EDF can adequately compensate for the destruction of, and damage to this area from an environmental perspective. Yours Sincerely, Erica Rae [Redacted]