Representation by S.A.G.E. (Suffolk.Alternative.GreenEnvironment) Community Group (S.A.G.E. (Suffolk.Alternative.GreenEnvironment) Community Group)
- Date submitted
- 25 September 2020
- Submitted by
- Non-statutory organisations
Relevant Representation: Sizewell C DCO 25.09.2020 From: Regan Scott for S.A.G.E. (Community Monitoring Group). Following our posted correspondence on the likely standard of this DCO (2.4.20) and acknowledgement of same by Suffolk County Council (9.6.20) in their Statement of Community Consultation, we suggest the following as principal is which may be considered within the three relevant pillars of planning consideration, namely site suitability (construction, operation and decommissioning), project need and project sustainability. The complexity of these issues and variety of opinion and spread of evidences suggest that open issue hearings are appropriate. Deficiencies in the DCO in respect of proposals for decision, statements and reports, evidences, reasonings and the draft Order itself reinforce our view. These shortcomings of the draft DCO have been well established in the consultations and public narratives, most notably by Suffolk County Council. We wish to contribute on some principal issues where we believe that environment regulation has not been applied fully or in a resolved manner with respect to the precautionary principle, proportionality and practicality of mitigation, the duty of pursuing reasonable alternatives and consequent compensation proposals. We further believe that in important respects the DCO’s proposals and reasonings do not conform with Government policy and law. NPS-EN1 and EN6 are the base referents, but we note that there is an ongoing and partially determined review of EN6, with a declared new “standalone” status from NPS-EN1, that the review is to reflect “changes in law and policy” and “to be consistent with current law and policy” (EN6 Review 12.2017). Policy change has been pursued by Government from 2015, while Court decisions have changed definitions of lawful duties in planning, most notably in respect of climate change Net Zero and associated imperatives. On the third pillar of sustainability, we believe there are principal issues arising from the full life-cycle of the project. These arise in numerous relevant ways, from legal duties to sustainability to policy developments concerning aspects of energy security, value for money and funding models; to ecology in respect of biodiversity net gain and natural capital preservation, to governance and ownership of a strategic resource, and ESG doctrine including the “no harm” principle. Issue Specific Hearings on principal issues might be grouped to reflect the three pillars of planning consideration: • Site suitability – construction stage and life-cycle, including nuclear waste storage, size of site, water supplies • Transport strategy, logistics: sustainability/resilience of community and road infrastructure • In combination effects: energy projects and housing development plans • EIA issues – construction period e.g air pollution • HRA, ecology, natural capital preservation – large scale of protected habitats and species - IROPI • Community amenity, structural life-cycle change, economic/social impacts • Governance, draft DCO provisions - EIA licence variations, licence assignment (ownership) and funding model • Climate change, decarbonisation and Net Zero in full life-cycle. We will make a written contribution on these issues.