Representation by Norfolk County Council (Norfolk County Council)
- Date submitted
- 9 September 2020
- Submitted by
- Local authorities
Norfolk County Council response to Proposed Sizewell C Project – Submitted DCO Application September 2020 (a) General Comments As the proposed development is located outside of Norfolk within the neighbouring County of Suffolk, it is unlikely that the proposal will have any immediate impacts on Norfolk in terms of landscape, ecology and archaeological matters. Furthermore, it is not felt that there will be any significant transport impacts on Norfolk arising from either the construction or operation of the new Nuclear Power Plant. (b) Employment and Training Comments It is understood from the EIA (NTS) that during construction there will be up to 7,900 people employed on-site and that a further 25,000 jobs would be created in the wider supply chain during this phase. When operational it is understood that the Plant would employ a workforce of around 900 staff. While Norfolk County Council welcomes the employment opportunities the Power Station will have within the local/regional area both during construction and once operational, there are significant economic issues, which the proposal will need to address with regard to: (a) The potential impact on the local labour market – will the development lead to shortages of construction and other key skilled workers in other location in East Anglia; (b) What measures will be taken to mitigate any potential impacts; and (c) What support and investment will be given to the training in the local area (e.g. covering the construction sectors). Norfolk County Council would especially welcome measures that will enable permanent, long term job opportunities to be taken up by local people. Norfolk County Council would welcome measures which would encourage/enable people currently excluded from the formal labour market being supported into jobs at any level /degree of permanency which could help ease competition for people already active in the relevant local labour market. The County Council recognises that EDF Energy are: (1) Working with the Suffolk Chamber of Commerce on Supply Chain matters; and (2) Developing an Employment, Skills and Education Strategy which will form part of the DCO application. The Environmental Statement Non-Technical Summary (ES NTS) makes specific reference to EDF Energy preparing an Employment, Skills and Education Strategy, which is welcomed. The NTS also refers to a Supply Chain Strategy which is again welcomed. While welcoming the above commitments by EDF Energy, it is felt that given the proposal’s proximity to Norfolk and the likelihood of additional major construction projects in both Norfolk and Suffolk arising from the offshore wind energy sector (i.e. associated with the: Norfolk Vanguard (approved DCO July 2020); Hornsea Project Three Project (Secretary of State is minded to approve DCO July 2020); Norfolk Boreas (Examination extended to 12 October 2020); and East Anglia Offshore Wind One (North) and Two (Examination to begin shortly) - there is a need for any accompanying Strategies having regard to: (a) Wider consideration of supply chain issues to include working with neighbouring authorities particularly Norfolk County Council; (b) Ensuring that any Education, Skills and Employment Strategy addresses/considers the wider cumulative impacts arising from other planned NSIPs in the area (i.e. covering the above offshore wind energy projects) ;and ensures appropriate collaboration with neighbouring authorities (e.g. Norfolk County Council) and the Local Enterprise Partnership in any potential initiatives arising from the above Strategies; and (c) There needs to be clear evidence provided through the above Strategies that the significant construction workforce needed will not adversely affect the delivery of other key sectors such as local house building and other employment sectors. The delivery for the above Strategies by the applicant should be set out as a Planning Requirement in the Development Consent Order (DCO); or agreed separately through a S106 legal agreement. Norfolk County Council would expect to be consulted on any emerging Strategies along with Suffolk County Council and the Local Enterprise Partnership. The above Authorities along with the LEP would need to be satisfied with the Strategies’ content before the Requirement could be discharged (or S106 fulfilled). It is suggested that Suffolk County Council ought to be the discharging authority on such a Planning Requirement/s; or signatory on any S106 along with the applicant. Such Requirements have been used in in other DCO proposals (e.g. Norfolk Vanguard) – see below: Skills and employment strategy 33.—(1) No stage of the onshore transmission works must commence until a skills and employment strategy (which accords with the outline skills and employment strategy) has been submitted to and approved in writing by Norfolk County Council. (2) Prior to submission of the skills and employment plan for approval in accordance with Requirement 33(1), the undertaker shall consult North Norfolk District Council, Broadland District Council, Breckland District Council, Norfolk County Council and the New Anglia Local Enterprise Partnership on the content of the strategy. (3) The skills and employment strategy must be implemented as approved. (c ) Transmission network – grid connection comments It is understood that Sizewell C will generate enough electricity for 6 million homes. There are wider grid connection issues in respect of the 400kV network which runs between Norfolk and Suffolk. The Stage 2 Report (Autumn/Winter 2016) indicated that electricity from Sizewell C will be stepped up to 400 kV through on-site transformers and connected via underground cables to a new National Grid 400 kV sub-station. This previous report indicated that no additional overhead line circuits would be required for Sizewell C in the “vicinity” of the site. It is understood that further studies will be completed to confirm the details of the revised overhead line connection. The NTS suggests that apart from the provision of a new National Grid 400 kV substation; and the minor relocation of an existing National Grid Pylon and overhead lines, there is no further impact on the wider transmission networks. It is considered that there needs to be clarification from both EDF Energy and the National Grid as to whether there is likely to be any requirement in the wider area for either: (a) reinforcement; of the existing 400 kV network; or (b) new overhead lines (400kV). Given the amount of electricity coming ashore from offshore wind energy projects off the Norfolk and Suffolk Coasts, EDF Energy and National Grid will need to address the in-combination impact on the 400 kV transmission network in the wider strategic area i.e. including the potential for reinforcement and new lines in both Norfolk and Suffolk. These cross-boundary electricity transmission issues were raised by the County Council at both the Stage 1 consultation in 2013 and the Stage 2 consultation in January 2017 and at the Section 42 consultations stage (2019). As such the County Council would like to see further evidence and studies setting out the full implications of both the Sizewell C; and the planned / emerging offshore wind energy projects on the existing 400 kV network across the two Counties. Any such study / evidence will need to take into account the current Offshore Transmission Network Review (OTNR) being led by the Department for Business, Energy and Industrial Strategy.