Representation by Ian KH Galloway
- Date submitted
- 18 September 2020
- Submitted by
- Members of the public/businesses
Relevant Representation of Mr I Galloway, [Redacted] I am a resident of Kelsale cum Carlton Parish and have contributed to responses made to EDF Energy during the Pre Application Consultation Phases. I wish to raise concerns in a number of specific areas: 1. Pre Application • Incomplete, incorrect and misleading data. • Charts without axis labelling or data tables. • Portrayal of complex data poorly executed. • Maps, photographs, overlays were poorly; reproduced and electronic renderings rapidly pixilated. 2. Application • Impacts; underuse of avoidance, sub-optimal mitigations, ineffectual management proposals and inadequate compensation are widespread • Traffic movements; underuse of avoidance, sub-optimal mitigations, ineffectual management proposals and inadequate compensation are widespread • Little adherence to the principle of “…Water-borne or rail transport is preferred over road transport at all stages of the project…” is self-evident. • Freight transport; strategy, method, means and management • Highway safety impacts; analysis and completeness • Environmental impact assessment; timeliness, analysis and completeness • Sustainable transport modes; appropriateness and adequacy for place • Community impacts; timeliness, analysis and completeness • Relevance and suitability of ONS “Wards” • Maps, photographs, overlays were poorly; reproduced and electronic renderings rapidly pixilated. 3. Traffic, Traffic Analysis Modelling • The omission from analysis of weekends, Bank Holidays and holiday periods in Pre Application unashamedly ignored East Suffolk as a popular all-year round; holiday, weekend and day-trip destination with growing economic importance. • The addition of a perfunctory execution (2015 data) of this “…good practice…” (DoT correspondence 4th March 2019) in no way discharges the need to explore and understand this devastating omissions more fully. • “Self routing” - analysis, impact and consideration of unforeseen consequences • Against this backcloth the veracity, suitability, completeness and applicability of EDF Energy’s traffic modelling is questionable. • High potential for “…an unacceptable impact on highway safety…” • High likelihood that “…residual cumulative impacts on the road network would be severe.” • The proposal of a 45 kilometre non-trunked heavy haulage route, without any notified or viable alternatives gives rise to unquantified widespread risk. It likely understates the likelihood and impact of; short, medium and long duration closure of the principal route during the 12 year construction. There are no degrees of confidence stated or a body of evidence provided from of lessons learnt from existing comparators, if indeed any exist in the UK? • “Early years” without substantiated mitigations. • TIMP; intent, scope, limitations, threats to life and overall credibility. • Haulage company and HGV driver routing autonomy; risks, analysis, impact and consideration of unforeseen consequences. • Seven Hills FMC; A14J58 circulatory congestion and impacts on Seven Hills Crematorium operations • Freight Management and especially the largely unexplored Northern HGV routes, plans for dealing with A12 incidents and closures. • HGV “…diversionary routes…”; definition, agreement, protocols and community safeguarding mechanisms • Sizewell C buses “…diversionary routes…”; definition, agreement, protocols and community safeguarding mechanisms • Unplanned closures of Orwell Bridge • Orwell Bridge planned closure, Sizewell C construction traffic “…appropriate diversionary routes…”; definition, agreement, protocols, community safeguarding mechanisms. • The assertion “It is expected that planned maintenance work on the A12, B1122, and other roads …could be restricted to overnight and/or weekend.” and the potential impacts on residents, local businesses, event organisers, tourists etc. • TRG should be formed - ‘prior to the commencement of any construction’ • TRG meetings should meet monthly until all TRG members unanimously decide to meet otherwise. • TRG delegation should be able to delegate issues or functions to a sub-group if agreed unanimously.’ • Local Transport and Traffic Groups should be formed ‘prior to the commencement of any construction. They provide and monitor actionable transport-related issues that impact the wider public.’ • Main Site mode share assessment targets; adequacy, sustainability and predisposition toward the line of least resistance. • The proposed “…package of measures…” in respect to sustainability and their impact in reducing utilisation of some sustainable modes. • Park & Ride targets • CWTP ‘early actions’ lack credibility and depth. More akin to an excerpt from a Project Pre-initiation Document. • Timing and delivery inter-dependencies of LEEIE, Northern, Southern Park & Ride facilities and Main Site parking provision. • Park & Ride principles – lack quantification of forecast numbers of workers living within 800m of Park & Rides and the relevance of this distinction. • Rail Shuttle Pick-Up Point at Saxmundham Station impact assessment; timeliness, analysis and completeness • Car Share Scheme • Main Site 1,000 space car park - construction workforce assertions are misleading. • The submission “A key parking control measure is that only workers living inside the area bounded by the A12, River Blyth, and River Deben…will be issued a parking permit for main development site…parking.” and the implication that this reduces unnecessary vehicle movements local roads. • The submission “the mode share targets are ambitious.” without evidence being provided. • The submission ‘…limitations of EDF Traffic Modelling cannot reflect influences impacting traffic on the local road network…’ and the implications thereof. • The submission “The scale of the proposed development is such that significant transport impacts would have arisen if only road transport were to be used for the movement of construction materials.” and the implication that the proposed levels of rail and sea use will negate “…significant transport impacts…” • The unsubstantiated assertion “Quality of life for residents has been at the heart of the development of the transport strategy.”, when the majority of freight, construction workforce and independent service deliveries have no alternative other than a journey on a local roads. • The unsubstantiated assertion by EDF Energy that their actions in “Minimising congestion and maximising the resilience of the highway network is a fundamental part of the transport strategy: it contributes to high-quality spaces by minimising emissions…” • The assertion “Users of the highway are not limited to car drivers: pedestrians, cyclists, and equestrians have all been considered extensively during the development of the transport strategy…” when acts of omission and the unfettered opening up of access to single track lanes demonstrably contradict the claim. • The submission “The transport strategy has been designed to minimise the need for worker car trips to the main development site, in turn reducing the noise and visual impacts of large volumes of cars passing through the wider area.”, when 1,000 ‘shared shift’ parking spaces are proposed at the main development site. • The lack of any significant quantitative or qualitative evidence demonstrating EDF’s understanding of the cultural, entertainment and recreational programmes hosted in East Suffolk in any year, beyond a passing reference to “The Latitude festival is an annual music event … SZC Co. would liaise with SCC in advance of the festival to understand peak arrival/departure times for the festival and would minimise HGV movements during these times.” 4. Sizewell Link Road • The submission “The site selection and design evolution process for the proposed development has been iterative and informed by consultation with statutory consultees and the public.” lacks credibility insofar as EDF also state “No direct link road from the A12 to the main development site was proposed in the Stage 1 or Stage 2 consultation.” • The predetermination (by EDF Energy) of a single issue to dominate the selection of a route for a Sizewell Link Road is evident in the submission made by EDF Energy that “The initial transport assessments predicted that the B1122 would be the main route for construction traffic travelling to the development site. Therefore, the rationale and purpose of the Sizewell link road is to relieve the B1122 from the anticipated construction traffic associated with the main development site, and consequently reduce traffic passing through Theberton and Middleton Moor.” rather than undertaking an objective assessment of whether any suitable route existed for modern HGV, LGV, bus, car and motorcycle traffic to access the Main Development Site prior to the early stages of the Pre-Application Consultation. • The lack of transparency demonstrated by EDF Energy in being unwilling to disclose the process(es) and methodology(ies) employed in assessing the relative merits of various routing options for a primary HGV route to the Main Development Site. • The efficacy and integrity of the Peer Review undertaken by AECOM. It is understood to have been undertaken largely by means of desked based review, calling largely on historic documents (some dating back to the 1980’s). • The thoroughness of the Peer Review. It is understood that a single site visit over the 18th and 19th April 2019 and was conducted on a drive-by basis and from some vantage points afforded by PROW’s. • The questionable value and objectivity of The Peer Review. It is stated that “AECOM was commissioned by EDF Energy…to carry out a peer review of the assessment work undertaken by EDF Energy to assess the identified options for the…SLR and the rationale in selecting a preferred option.”, yet the Draft Peer Review does not identify any EDF Energy documents relating to the process for the selection of EDF Energy’s “…identified options for the…SLR”. Nor does it refer to the review of any assessment work undertaken by EDF Energy that provides a rationale used “…in selecting a preferred option.” • The Peer Review does however call on various historic documents (some dating as far back as the 1980’s) and a report entitled “Sizewell C, Route D2 and B1122 Study – Rev 3”, undertaken by AECOM in 2015. • Paras 4.2 onwards of The Peer Review seem wholly inappropriate to “…the assessment work undertaken by EDF Energy to assess the identified options for the…SLR and the rationale in selecting a preferred option.”.