Representation by Paul Gripton
- Date submitted
- 22 September 2020
- Submitted by
- Members of the public/businesses
Dear PINS, I wish to make the following submission, as my initial written 'relevant representation' to register as an interested party involving the Sizewell C examination. Ref EN010012. Many of my issues regarding SZC, result from unacceptable issues and practices identified during the HPC project. Briefly the issues i wish to raise at the SZC examination involve the following - SZC Transportation issues, including lack of public participation/representation involving the proposed 'exclusive' Transport Review Group'. Remit of the Transport Review Group and 'Section 106' provisions, including potential lack of any safeguarding of recognised 'limits' and the developer having 50% of the vote, raising 'conflict of interest issues'. Developer and Council compliance with the 'Infrastructure Planning (EIA) 2017 Regulations, including Article 35, regarding Objectivity, Bias and Conflict of Interest. Potential Conflicts of Interest through the Councils roles in the TRG, making decisions, Discharge of requirements and as enforcement regimes for the DCO and EIA regulations, without clear commitments to Transparency and Clarity, vitally before public impacting decisions are taken. Lack of ability for public comment on impacting Requirement Discharges. Potential abuse of the 'Exceptional Circumstances' provision involving HGV delivery times under the SZC Traffic Incident Management Plan regarding long term, pre-planned roadworks. Discharge of Requirement issues including potential 'tail-piece' legislation and conflict with the 2008 Planning Act provisions. Ensuring the inevitable 'Project Changes' remain under the 2008 Planning Act remit rather than be circumvented. Need for a clearly defined and mandatory, developer 'Management Change Protocol', identifying, confirming and complying with regulatory requirements, including EIA regulations and impact identification/mitigation issues. Need for Council enforcement powers to ensure clarity and transparency of process/changes. The provision and appropriate use of DCO requirements. Inappropriate remit under the Section 106 agreement.