Representation by Felixstowe Town Council (Felixstowe Town Council)
- Date submitted
- 28 September 2020
- Submitted by
- Local authorities
FELIXSTOWE TOWN COUNCIL Consultation on Sizewell C DCO application September 2020 Relevant Representation from Felixstowe Town Council Felixstowe Town Council (FTC) welcomes the opportunity to register representations to the draft DCO. We look forward to being invited to participate in the relevant later parts of the process. FTC takes no stance of principle in relation to nuclear power generally, or whether the coastal site at Sizewell may be an appropriate location. The new power station is not immediately local to Felixstowe; hence FTC will limit our response to those aspects which may specifically affect the town, its economy or wellbeing. These primarily concern a number of elements of the road and rail strategies which have such a potential, 3 in number: • The rail strategy, and the potential negative effects on available freight capacity from the Port of Felixstowe to the west of Westerfield junction, especially in the medium term. • The significant increases predicted during the construction phase in both LGV and HGV traffic volumes at a number of pressure points on the main road network in the wider vicinity of the town, many of which are critical to the daily lives of our residents. • The potential effects on local traffic safety and amenity arising from the proposed Freight Management Facility at Nacton A number of other aspects could be relevant to Felixstowe. FTC would wish to have an opportunity to comment on these at a later stage. These include, but are not limited to: • Tourism, locally or as part of the wider Visit Suffolk concept. • The labour market, both skilled and unskilled, notably around the transport and logistics sector. • Housing issues, noting that the application defines “local employment” as a radius of a 90-minute drive time, which Felixstowe is well within, with an aspiration to employ the maximum number possible within that category. • Coastal processes, given that these may be affected over 150 years and more, may be substantial and that the general mechanism of the coast between Lowestoft and Felixstowe is perceived to be an overall southerly drift of beach sediments 1.0 Rail strategy FTC has been concerned throughout the long series of consultations in regard to the potential impacts on rail freight capacity west and south of Ipswich from the additional rail paths required for SZC construction. These impacts are potentially directly harmful to the short- and medium-term future of the Port of Felixstowe and its large dependent logistics business sector. While we recognise the desirability of rail delivery of materials to the SZC site, those issues are limited in time and in scale in contrast to the importance of rail freight capacity to Felixstowe Port as by far the largest strategic element of the economy of the Eastern region. In that context, we do not believe that the EDF Transport Assessment comes close to examining these issues in sufficient depth, let alone proposing any mitigation thereof. These impacts need to be considered against an understanding of the evolving port and logistics business both globally, in the UK as a whole and specifically for the eastern region, as well as Felixstowe itself - whose economic and social life is highly dependent on the ongoing health of the Port business. The Port is fortunate in its ideal geographic location in UK – but nevertheless critically dependent on further expansion of rail capacity, currently running at very high load factors. The shipping and logistics industry is very sensitive to even short-term disruptions of throughput, and its customers must have long term confidence in all elements of the supporting infrastructure, including rail freight capacity improvement over time. Competing ports at Southampton and especially London Gateway seek to fill spare capacity. While Felixstowe has unique advantages in terms of geographic location, lack of rail capacity in short and medium term is critical to its continued viability, and therefore for some operators, a presence in Felixstowe. The Port was created and has thrived on the back of huge public investment in road & rail in the 1960s and 1970s, but we have seen only small local improvements since. Current rail bottlenecks have suffered constant delays in the emergence of improvement plans from Network Rail: the critical Ely Junction scheme has been under active discussion for at least 10 years, with no firm plans yet in place, but an earliest likely date of 2028/29 at best. FTC has considered the so-called Rail Strategy document. However, while this deals in great detail with the local issues around the SZC site, Leiston and the Saxmundham junction, it has little or no strategic content, other than suggested detailed times of the 3 trains expected daily during the middle years construction phase. Namely: • The 3 outbound trains would be flighted from Saxmundham junction after the last passenger service, passing Westerfield between 2355 and 0120 • 2 inbound trains would be overnight, passing Westerfield at 0350 and 0447 • The third inbound train would utilise the existing unused morning SZA/NDA path, passing Westerfield at 0807. There is unfortunately no strategic consideration of whether and how these trains would impact on the (largely freight) services to the west, the critical strategic matter at issue. The principles around this are discussed below. But it is germane to regret here the unfortunate continuing use of the 0807 Westerfield path, which precludes a rush-hour commuting service between Ipswich and Woodbridge. Locally, for Felixstowe residents, that is manifested in the need to leave Felixstowe at 0636 in order to reach Woodbridge in time for the normal working day (at 0751), the next arrival being 0932 – neither being a realistic commuting schedule.. FTC has carefully considered the Rail Network chapter of the Transport Assessment. We recognise and are pleased to see that this chapter has now been added, in contrast to earlier consultation phases. However, we do not perceive the issues raised have themselves been addressed. That must be corrected before a DCO should be granted. The discussion of the rail system from Sizewell to Ipswich is thorough, and largely correct, but the wider network issues beyond Westerfield have not been properly researched, let alone addressed. The issues involved are complex and technical regarding the operation of the rail system. We submit that the Rail Network document is an inadequate presentation of the issues involved and /or mitigation which may be required. It contains a number of significant inaccuracies, and errors or omissions in certain places. We would be happy to supply details of our evidence in that respect at the appropriate time. We request that the Inspector fully consider these alongside this Relevant Representation document. Critically, it does not establish that adequate freight capacity is available on the rail network to accommodate the SZC traffic. We request that the Inspector fully consider these alongside this document. Paragraph 2.7.55 is highly misleading in respect of the prospects for any improvement during the current Network Rail “Control Period 6” – 2019-2024. It appears to be based on a comment in Network Rail’s Anglia Route Strategic plan dated January 2018: to “Ely Area Capacity Enhancement projects”. https://www.networkrail.co.uk/wp-content/uploads/2018/02/Anglia-Route-Strategic-Plan.pdf However, that document was revised in March 2019, and again in March 2020, removing any hope in early investment at Ely, or anywhere else other than the now completed Trimley Loop, as follows. The Anglia Route Strategic Network Plan dated March 2019 contains no commitment to work at Ely junction – just the following comment under “Freight”: “What freight particularly want from the Anglia route is a reliable asset performance whilst ensuring fair regulation whilst on the network. With Trimley Long Loop being completed during CP6 this will add much operational flexibility to better current performance for intermodal services. We need to concentrate our efforts on increasing infrastructure reliability on the Cross Country route from Haughley Jn to Ely and Peterborough which is a major artery of the UK PLC.” https://www.networkrail.co.uk/wp-content/uploads/2019/06/Route-Strategic-Plan-Anglia.pdf i.e. the only work planned which is relevant to SZC is increased reliability of current lines and equipment – welcome, but of no effect in increasing planned line capacity. And the later updated Network Rail Delivery Plan Update Summary for CP6, dated 26/3/2020 makes no reference to any work at Ely or elsewhere, beyond the completed Trimley Project. https://cdn.networkrail.co.uk/wp-content/uploads/2020/03/cp6-delivery-plan-update.pdf FTC understands from many sources that the current expectation for significant improvements at Ely are now expected in 2028/29 at the earliest. We consider that, taken in the round, the Rail Network document is deficient in almost all regards relating to the strategic rail freight network. It is poorly prepared, and at most a discussion of solutions to the matters at issue. It is essential therefore that this unpalatable situation is fully recognised in regard to the feasibility of EDF’s plan for any rail delivery to SZC. And from that it follows that significant mitigation should be required from EDF, in order to provide in consultation with Network Rail and all interested parties, funding for such improvements as can be identified to permit the additional SZC rail freight capacity to be provided without prejudice to existing users of the rail network, passengers and freight alike. 2.0 Effects on the main road network FTC has significant concerns in regard to the volumes of traffic, and especially the degree to which the nearby main road accesses to the town are predicted to suffer from significant over capacity at critical junctions, and the increase in queuing thereby predicted to occur during the Construction phase of SZC. FTC acknowledges that traffic in the town of Felixstowe and its immediate vicinity is unlikely to be directly affected. However, our geographical situation on a peninsular with only a single main road access via the Seven Hill interchange we submit represents a major issue for the economic and social well-being of our residents and indeed our visitors, given that tourism plays a major part in our economy. FTC have carefully considered the numerous statistical analyses and predictions contained within the Transport Assessment (TA) in regard to both light and heavy goods vehicle traffic flows, as an increased part of already very heavy general traffic – which is itself predicted to increase by some 25% during the period, according to the figures presented. FTC acknowledges that very detailed analyses of current traffic and future trends have been undertaken as part of the TA, which are most useful in understanding the potential issues likely to arise. This situation paints a picture which would be of concern to any community, but especially in our specific geographical situation: The Seven Hills Roundabout and the main roads it links are fundamental to convenient and safe access to our town. It is already normal at peak times to experience queues on the south east A12 slip road, the A1156 and frequently on the A12 north approaches. Hence we are disturbed that even without accounting for the SZC traffic the capacity of the routes is predicted to increase sharply, to a situation of 170% overload, even with the proposed Adastral Park mitigation. While our prime concern is in regard to the Seven Hills junction, many of our residents have daily commitments in Martlesham, Woodbridge and beyond, and vice versa is true for some residents of those areas. Accordingly, we have similar concerns about the whole series of junctions from Seven hills to Woods Lane, all of which are predicted to have similar congestion issues. We note that it is claimed that the SZC traffic will make only a marginal increase on these numbers, and hence that EDF state that no further mitigation is justified in connection with the SZC build. We reject that claim and that approach strongly. We note that the SZC traffic, just for LGVs and HGVs, represents some 2.1/2% of the volume. While it may be true that in a situation of adequate capacity, a change of that size may be of modest concern, we suggest most strongly that in a situation of near permanent overload , a marginal increase in numbers would be likely have an entirely disproportionate effect on delays. We therefore believe that the stance of EDF is wholly unreasonable, and that accordingly the DCO should not be granted on this basis, but should be conditioned that EDF make a proportionate contribution to fund more significant works than those currently conditioned in connection with the Adastral Park development. Additionally, while those improvements are expected around 2023 in connection with that development, that outcome is contingent on many unknowns, and may not happen on time, or indeed at all. We therefore further contend that it is unreasonable for the SZC Assessment to be accepted on that basis, given the extreme congestion predicted should those not be completed appropriately. We suggest this matter further underlines the need for the DCO to require an appropriate contribution from EDF, to cover that eventuality. We are not clear whether the Adastral Park proposal includes full, interactive signalling of these roundabouts, which proved so enormously effective when the roundabout and signalling at Junction 58 were completely re-designed and rebuilt in 2010, but if that is not the case, then an EDF contribution should be used to enable that, primarily at Seven Hills. 3.0 The Freight Management Facility FTC has many years’ experience of the effect of very heavy flows of HGVs into and around the Port of Felixstowe. The efficacy or otherwise of the combined effect of the local road system and the evolving, now sophisticated, Freight Management System operated by the Port of Felixstowe (PoF) has varied widely over the last 25 years or so. However, the current situation, with Port volumes having increased broadly year on year is largely successful in avoiding undue congestion from the HGV traffic. For a long period between c.2000 to 2010, there was frequent need for “Operation Stack” to be invoked, whereby large numbers of HGVs were diverted and held, originally on the carriageway south of Junction 58, and later on the Old Felixstowe Road. However in recent years this has been a relatively rare occurrence. Two major factors have successfully procured this outcome: A) The major rebuild of the roundabout at Junction 58 in 2010, critically with the use of fully interactive computer controlled signalling, which can be observed to change behaviour very significantly at different times of day and according to changing traffic volumes B) The implementation by PoF of the Freight Management System (FMS), which remotely allocates entrance times to the port for all HGVs. Accordingly FTC, having observed the ability of good HGV traffic management to largely eliminate the previous major congestion, strongly supports the concept of a Freight Management Facility to mitigate potential negative effects of SZC HGV traffic, not only locally, but throughout the route to Sizewell. FTC takes no view on the suitability of the site chosen, in terms of the impact of the site itself on the appearance of the local area in comparison to other potential sites. We believe that is a matter for the local parishes directly affected to consider. However, we have considerable concerns about the proposed traffic management to and from the chosen site on the Old Felixstowe Road. We note that the intention is for all traffic, other than HGVs originating from the PoF, to enter and leave the site from / to the north along the Old Felixstowe Road, via the Crematorium junction. We take the view that not only will this arrangement significantly exacerbate the clear problems at the Seven Hills interchange above, but also that the proposed intensification of use of the A1156 / Old Felixstowe Road junction (“the Crematorium junction”), without any mitigation applied, is likely to cause significant difficulties. In particular, the need for significant numbers of HGVs to emerge from old Felixstowe Road onto the A1156, on a right turn, across a busy single carriageway road, on a long bend with limited visibility is clearly liable to problems. Currently very little traffic needs to make that turn, with the majority of westbound traffic on Old Felixstowe Road making the left turn towards Ipswich. Numbers of HGVs being required to make that sharp turn, inevitably slowly, across often fast-moving westbound traffic going to be problematic at best, and potentially with significant danger of collision. If this approach is adopted, we submit that a significant mitigation is required by provision of a redesigned layout, ideally with signalisation, at the Crematorium junction. We would therefore ask that the DCO be conditioned to require that. However, beyond the difficulties at the junction itself, we note that the requirement for some 60% of all HGV traffic bound for SZC to use the Seven Hills junction twice and thereby substantially exacerbate the clearly identified congestion issues there is also a matter of concern. There can only be a significant difference between the direct approach to SZC, simply using the well-designed dedicated slip lane directly onto the A12 northbound, and the need a) to use the right hand slip lane, enter the roundabout, conflict with the A12 southbound and south east sliproad entry traffic, and leave by the A1156 exit, and then later to enter the Seven Hills roundabout from the A1156, conflicting with traffic both from A12 northbound and from A14 south east slip road, will be a major factor in exacerbating congestion at Seven Hills. A possible alternative could be considered and explored of inbound traffic continuing on the A14 to Junction 59 Trimley, using the flyover there to access the A14 westbound, and enter the FMS site from the east via the existing slip road near Levington. This would remove the inbound traffic entirely from the Seven Hills junction. And similarly, for HGVS leaving the FMS bound for Sizewell to leave the site eastward and then use the A14 westbound to Seven Hills, using the south east A14 slip to enter the roundabout. (This may probably require some improvement to the Levington entry slip lane). FTC is not in a position to analyse this option in detail but suggest that it may have considerable advantages in reducing congestion and should be explored.