Representation by National Trust (National Trust)
- Date submitted
- 28 September 2020
- Submitted by
- Members of the public/businesses
Introduction The National Trust (The Trust) is an independent charity that looks after beautiful countryside and historic buildings in England, Wales and Northern Ireland. Should the Trust acquire land or buildings that it considers to be of outstanding quality, Parliament has created a statutory mechanism that enables our Trustees to declare that land “inalienable”. This means that the land is so important to the nation that it cannot be sold or mortgaged, rather it must remain in the care of the Trust, in perpetuity. Once declared inalienable this designation cannot be reversed. This is one way in which the Trust is able to deliver on its charitable purpose of preserving some of the nation’s most treasured places for everyone, for ever. The Trust owns 140 hectares of land at Dunwich Heath and Beach, which is located approximately 3 kilometres north of the proposed Sizewell C site. Dunwich Heath is a surviving fragment of lowland heath – one of the UK’s rarest habitats. It is subject to international and national designations. The majority of the land was declared inalienable in 1967 demonstrating the importance of the land and the Trust’s commitment to care for it permanently for the nation. The Trust does not object to the principle of the development as we acknowledge the NPS for Nuclear Power Generation (EN-6) identifies Sizewell as a potentially suitable site for a nuclear power station. However, we believe that the current proposal risks unacceptably damaging the integrity and beauty of our site at Dunwich Heath and the wider landscape. Areas of Interest Having appraised the DCO documents, our areas of concern are: Recreation and Tourism • The application does not adequately assess or address changes in recreation and tourism at Dunwich Heath and Beach, including changes in visitor numbers and behaviours. Visitor displacement and visits by construction workforce are underestimated and not precautionary. Limited survey data has been used, the assessments do not take account of uncertainty and there is a lack of clarity about assumptions. • Sufficient ring-fenced funding to cover the duration of the construction phase of development (predicted to last 12 years) is required to enable the Trust to monitor, manage and engage with different types of visitors and manage our operations and visitor infrastructure to cope with changes in visitor activity. Impacts on Ecology • The impact of increased recreational visits and different behaviour patterns on ecological features at Dunwich Heath and Beach are not adequately assessed. The ecological assessments (ES and Shadow HRA) do not consider key species, are based on out of date/missing data and there is a lack of geographical consideration of receptors sites on a landscape scale (including Dunwich Heath and Beach). Accordingly, the conclusions of no adverse effect on site integrity for the European qualifying species and habitats are unqualified. • Unmitigated, an increase in displaced visitors and/or an increase in inappropriate behaviours would detrimentally impact UK and European protected habitats and species at both Dunwich Heath and across the whole SAC and SPA. • Robust monitoring of designated and non-designated features is required with funding available for mitigation linked to monitoring. Landscape and Visual Impacts • The elevated position of our site provides the best vantage point for the Sizewell C site. The development will impact on the setting and views from Dunwich Heath and the wider AONB both during construction and operation. However insufficient information has been provided to demonstrate how the applicant will mitigate/compensate the visual impacts of the development for the extent of its lifetime. • The LVIA submitted with the application acknowledges that there will be significant and adverse impact on views from our site at Dunwich Heath. However, it lacks sufficient information to demonstrate the true visual impact of the development during construction and operation. This includes the absence of Computer-Generated Images (CGI’s) through the construction phases both during daytime and night-time and an assessment of external lighting across the whole site when taken in combination with Sizewell A and B. • The Trust does not agree with the assessment conclusion that landscape and visual effects would only occur over localised sections of the AONB and Heritage Coast and that the effects during operation on these designations is not significant. • The pylons and overhead power lines proposed would have an intrusive impact within the sensitive landscape on Dunwich Heath and the wider AONB. We are not satisfied that all alternatives have been appropriately considered. • Given the magnitude of visual impact at Dunwich Heath it is imperative that the project enables the Trust to access funds to implement interventions either alone or in partnership to mitigate/compensate for this impact. Coastal Geomorphology and Long-Term Change • The application does not adequately assess the impact of the proposal on long term coastal geomorphological processes. The Geomorphological Assessment is narrow in scope and the study area is limited in geographical scale. • There is no assessment made of how cliff processes may be impacted on and/or interacted with during the lifetime of development. • The magnitude, frequency and direction of extreme events is inadequately dealt with under sea level rise and climate change scenarios. • There is uncertainty about the assumptions supporting the baseline assessment of large scale/long term/accelerated coastal change. The Trust is therefore concerned that there are potential/possible impacts of the proposal on our site during the lifetime of the development that have not been fully explored as part of a holistic and integrated assessment. • There is no provision for monitoring, mitigating or compensating impacts arising from the development’s influence on long term coastal change. • The applicant should be required to define and monitor this change for the lifetime of the development and to include the north of the application site, specifically Dunwich Heath and Beach. Should there be impacts to Dunwich Heath and Beach during this period it is important that the project enables to the Trust to mitigate/compensate for this impact. Conclusion • The Trust is concerned about the methodology and conclusions of some assessments submitted with the application, the absence of some key assessments and inadequate proposals for monitoring, mitigation and compensation. There is also a lack of overall integrated consideration of the cumulative impact of the proposal at a landscape scale. • The Trust has welcomed recent engagement with the applicant to discuss issues following the submission of the DCO application and will continue with these discussions in order to try and resolve matters or seek common ground prior to the examination. • The Trust must have access to the appropriate funds to mitigate and manage the impact of the development on Dunwich Heath and the wider AONB during all stages of the development: construction, operation and decommissioning. Although we welcome the applicant’s proposal of a ring-fenced Resilience Fund , the Trust will also need access to other appropriate funds where on-going monitoring identifies that mitigation is required, not least as this enables the Trust to work in partnership to deliver mitigation with conservation partners. We will expand on the comments set out above when we submit our detailed Written Representation, in accordance with the timetable set out by the Examining Authority in due course.