Representation by Marlesford Parish Council (Marlesford Parish Council)
- Date submitted
- 23 September 2020
- Submitted by
- Parish councils
Submission to Planning Inspectorate Relevant Representation as Interested Party On behalf of Marlesford Parish Council Regarding NNB Generation Company (SZC) Limited DCO Application For Sizewell C New Nuclear Power Station and Associated Works Lord Marlesford Chairman Marlesford Parish Council Melanie Thurston Parish Clerk marlesfordpc@gmail.com 22nd September 2020 Introduction 1. Marlesford Parish Council (MPC) MPC is very worried by the impacts on this village as a result of EDF’s proposals for SZC. We believe that quality of life will be impaired over the likely 12 year build period and for many of the older residents, the impacts will be felt for the majority of their remaining lives – that is a sad prospect for those who have long enjoyed the relative tranquillity of this village. 2. Whilst we acknowledge some benefits to the East Suffolk community from Sizewell C (SZC), for example, employment opportunities, opportunities for local businesses and the inflow of substantial business rates, we feel that these benefits do not outweigh the huge burden that this area will have to bear on behalf of the rest of the country. The impact of SZC in the construction phase will be felt in East Suffolk on many fronts, including increases in traffic (particularly HGVs) using the A12, pressure on rented accommodation and adverse effects on tourism. 3. At Stage 4 consultation MPC withheld its support for SZC on the grounds that insufficient information had been provided on the proposals. MPC’s position has now shifted to one of opposing the EDF proposals for Sizewell C in their current form. MPC feels that key areas such as freight strategy, various aspects of ecology and general impacts on the communities and landscape of East Suffolk have been dealt with in insufficient detail and despite engagement in the consultation process we feel that the concerns of this, and neighbouring parishes have not been addressed by EDF. 4. MPC and neighbouring parishes of Wickham Market, Hacheston, Campsea Ashe, Pettistree, Little Glemham and Parham have identified areas of common interest and many of the issues set out below are shared concerns with our neighbours. We have confined our comments to the four topic areas below which we believe will have greatest impact on our community. We will leave others who may be more directly affected or have greater specialist knowledge to comment on other issues, amongst which we would expect to see concerns about EDF’s ability to deliver the whole project, the impact of SZC on the Suffolk Coasts and Heath AONB, its impact on coastal processes in the Sizewell area, concerns about potable water supplies and impacts on tourism and the local economy. Topic Areas of Concern Two Village Bypass 5. MPC does not support the proposals for the Two Village Bypass (TVB). This is on the grounds that the proposals do not allow for a comprehensive long-term strategic bypassing solution for the A12 at Marlesford and Little Glemham which would provide the only conceivable long term solution to the growing traffic problems faced by these communities. 6. It is accepted by the highways’ authority that the alignment of the TVB and particularly its southern junction with the A12, will preclude the eventual delivery of the Four Village bypass of Marlesford, Little Glemham, Stratford St Andrew and Farnham (Suffolk County Council’s SEGway). Strategically we believe this is a gross error. Southern Park and Ride - Hacheston 7. The elevated position (DCO Application Documents, Book 6, 6.5, Volume 4, Chapter 6, para 6.4.12) of the Southern Park and Ride (SP&R) makes the site an inappropriate one and is the reason that we have opposed its location. The site is located between the two Special Landscape Areas of the Rivers Deben and Ore (Policy AP13 Special Landscape Areas, Suffolk Coastal Local Plan, Saved Policies July 2013). That policy states that “The District Council will ensure that no development will take place which would be to the material detriment of, or materially detract from, the special landscape quality”, we contend that the development of the SP&R in this location will detract from the quality of the landscape. In the event that the site is consented we will require screening commensurate with its sensitive landscape location. 8. Important aspects of the site are shown on plans as “Not for Approval” including detail on buildings, signage, drainage and lighting (see DCO Application Documents, Book 2 Plans, 2.7 Southern Park and Ride Plans). MPC will want positive assurances that these areas will be properly conditioned and discharge monitored. 9. There are significant visual impacts that do not appear to have been fully considered. As a minimum, we will be pressing for bunding to be reinstated to what was shown at Stage 4 (see DCO Application Documents, Book 5, 5.1 Consultation Report, Appendices F1-F2, Appendix 1 Stage 4 Consultation Summary Document Pg 19) and we would expect our concerns regarding old and new hedgerows and existing specimen trees to be addressed. 10. The construction start date for the SP&R is scheduled for Year 2 of the project. We believe it should be started in Year 1 to ensure the earliest and maximum capture of A12 SZC traffic. 11. EDF claims that in general, noise from the construction, operation and removal phases will have negligible impacts on the identified receptors (see DCO Application Documents, Book 6 Environmental Statement, 6.5, Volume 4 Southern Park and Ride, Chapter 4 Noise and Vibration) - we will challenge this. We do not believe all receptors have been considered. 12. As part of EDF’s noise and air quality mitigation we will press for EDF’s contractors to use electric buses. 13. Marlesford is a “dark skies” area. We will argue that EDF must mitigate the illumination of the SP&R site to ensure that dark skies are protected. Wickham Market and Surrounding Area Traffic Issues 14. The inappropriate proposed location of the SP&R will put enormous pressure on already congested local roads. Wickham Market is a service centre for its neighbouring villages. MPC has been working closely with its neighbouring parishes to ensure that traffic issues in and around Wickham Market are addressed by EDF. Dialogue is ongoing with EDF, but we will expect to see commitments to improvements secured early in the Examination process and enshrined in the Decision. 15. We will need to see evidence that EDF is taking seriously the need to direct all traffic via A14/A12 in order to alleviate pressure on the B1078. 16. We expect innovative solutions to be applied to tracking of LGVs and private cars using the SP&R to ensure that the A14/A12 objective (above) is met. 17. We consider the cycle and pedestrian access to the SP&R is lacking detail. As a legacy issue we will press for a cycle and pedestrian route from the Marlesford Road/A12 junction to the SP&R. A12, Freight Strategy and Traffic Numbers 18. MPC regards the A12 through Marlesford as wholly inadequate to carry the increased traffic arising from SZC and Scottish Power Renewables construction projects. We will challenge assumptions made on cumulative impact. 19. The lived experience of Marlesford residents suggests that the junctions of Bell Lane/A12 and Marlesford Road/A12 are dangerous and MPC disagrees with EDF that, “As no capacity problems are foreseen no mitigation is proposed or deemed necessary at the existing junction” (see DCO Application Documents, Book 8, Other Documents, 8.5 Transport Assessment 9.29.1 - 9.29.17). 20. MPC will argue for A12 baseline studies of noise, air quality and vibration before construction. Monitoring should continue during construction and for an agreed period after the construction phase ends. 21. The unimproved A12 through Marlesford creates community severance. This will increase with the SZC and other projects’ traffic. A safe crossing will be required as a legacy benefit. 22. MPC will want an explanation of why a predominantly road led strategy has been preferred over marine or rail led. 23. The list of issues outlined above is not exhaustive and we will seek full and appropriate mitigation of these and other issues for the benefit of local residents. Conclusion 24. This community will suffer heavily as a result of the direct impact of the SP&R, increased HGV, LGV and bus use of the A12 through Marlesford, and will be affected by the expected congestion in Wickham Market. This is a high price to pay over the anticipated 12 - 15 year build period and, EDF should be held responsible for the considerable costs involved in making life bearable for the residents of Marlesford and Little Glemham and providing legacy benefits in the event that the two villages are not bypassed. 25. We expect the establishment of a forum through which community concerns can be voiced during the construction and operation phases. o0o Lord Marlesford Chair 23rd September 2020 Marlesford Parish Council