Representation by Anne Westover
- Date submitted
- 28 September 2020
- Submitted by
- Members of the public/businesses
I strongly object to the proposal to build SZC. The location on the sensitive Suffolk coast and within our nationally designated coastal ‘Area of Outstanding Natural Beauty’ (AONB) is unacceptable for many reasons. One of the statutory purposes of the designation of a landscape as an AONB is that it should be both conserved and enhanced. 1. Overarching The development and all aspects of the construction and its subsequent operation will result in a legacy of carbon emissions and radioactive waste which will plague and pollute both Suffolk and the UK for many centuries into the future. The construction impacts for the proposed 12 year period will be over a ‘long term’ period (GLVIA 2013). Likely delays (evidence from France, Finland and the UK) will extend this into an even longer term period with resulting damaging consequences. This development, ancillary works/laydown/accommodation/access arrangements and works areas will result in significant detrimental physical landscape and visual impacts across the coastal area. I have concern that new jobs and apprenticeships for local people will be limited in both scope and longevity. It is clear to see that the construction of both SZA and SZB did not have lasting economic benefits for Leiston and the surrounding areas. Any jobs which support the production of a toxic waste legacy should be feared and not welcomed. If DCO is consented: • Guarantees must be given that the local population will benefit from new jobs and apprenticeships being created. • Specific measures to support plant nursery (local provenance propagation will be needed), landscape and environmental management trades must be put in place. Local people and visitors enjoy this region for its tranquillity, coastal landscapes, beaches, Minsmere bird reserve, natural habitats, and dark skies. Sizewell C will have a negative impact on all these elements and keep visitors away from many parts of the coast and inland area. Local people from an expanding population will lose a treasured green space and recreational resource. The region will suffer greatly from a diminished tourism business and scope for people to enjoy the coastal landscapes. 2. Main development site I worked on the SZB and C (proposed) projects in 1990’s with the LPA; dealing with landscape mitigation, northern mounds, woodlands, marshland and tree belts amongst other aspects. These features are just maturing after some 30 years of life and much will now be removed by the construction of SZC. Since the first submission of a SZC plant in the mid 1990’s the development, lay down area, accommodation, and transport issues have escalated in terms of scale, site coverage and resulting impacts. The main development site, as a result of its poor design, scale/mass, and loss of natural landscape will result in many impacts: • Significant landscape and visual impacts across a wide area of coastal and inland landscapes. • The two nuclear reactor domes will look ugly and incongruous. They will be framed by a mass of box shaped buildings dwarfing the current SZB white dome and making the impact from SZB seem fairly minor. This dome has become a familiar and iconic design albeit visually prominent in many views. • A development of this magnitude should be designed with the upmost skill in order to create a high-class design both in terms of architecture and landscape setting. The poor design approach is summed up in the Design and Access statement which indicates a series of disparate structures across the site area, with many of the ancillary roads, buildings and car parks intruding beyond the main site area and into the natural landscape setting. • The proposed pylons will create additional detrimental visual intrusion and harm to the landscape. • The landscape setting of the current B station will be fragmented by the loss of Coronation Wood with the adverse intrusion of development into this area. The woodland may have elements of poor condition, but this is purely a result of a lack of management over the years which could be remedied if EDF had the interest in doing this. Removal of woodland should not been seen as an option whenever more development space is needed. • The Sizewell B relocated facilities, proposed Outage car park and access/fencing will intrude into the setting of the current station causing fragmentation and detrimental impacts on the acid grassland natural habitat and landscape. This proposal along with the works associated with Coronation Wood and the use of Sandy Lane as a haul route creates further intrusion into the Sandlings landscape area west of the SZB station. • The cumulative landscape and visual impacts with the Greater Gabbard and Galloper sub stations have not been fully considered. LVIA Para 13.4.49 states that these developments exert an influence on local character, they clearly do. Further visual intrusion into the area will result in cumulative harm to the character of the AONB landscape. This aspect of industrialisation, coalescence of development, and lighting will result in significant harm to the Sandlings landscape. • The existing wind farm substation developments have resulted in loss of habitat and woodland with the alleged landscape mitigation resulting in scattered dead trees and redundant plastic tubes across the Sandlings landscape including Broom Covert. This does not represent any form of sensitivity towards the treatment, protection or enhancement of the AONB landscape. • The permanent northern plant site access road and car park. This was proposed to be temporary at Stages 1 and 2. At Stage 3 EDF failed to include any information or questions relating to this change of approach. The road will cause harm to the landscape (which currently has SSSI status) using hard materials, drainage, traffic movement, air pollution, noise, lighting, and the causeway to the car park. It is not clear how workers access the site from the car park, further hard footways/on site transportation is inevitable. Longer term, with a permanent access road there will inevitably be pressure for further ancillary developments within this northern area. • The restoration of the construction lay down area should be back to natural landscape and green space without any permanent road or car park. All operational access arrangements for Sizewell B and C should be from the current Sizewell road and site access. If this is not appropriate, then a northern access only could be considered. 3. Transport: Southern Park and Ride site EDF chose to ignore both residents’ and Wickham Market Parish Council’s (WMPC) concerns regarding this site expressed during the consultation. Instead at Stage 3 the SP&R site was increased in size (to 1250 capacity plus a traffic incident management area) after the A12 Woodbridge site was removed from any further consideration. The SP&R will draw traffic from a wide regional area and create significant highway problems for the A12 and the local road system, through the neighbouring parishes and villages. Traffic through Wickham Market is already problematic and often dangerous. The overall cumulative increase in traffic from SP&R and other local development traffic (allocated sites in LDF) will exacerbate traffic volumes, road and pedestrian safety, noise and air pollution. EDF have stated (DCO) that they will fund mitigation measures for Wickham Market to deal with the adverse impacts arising from the massive increase in traffic which will pass through the village. To date EDF have failed to provide any overview or detail of such proposals despite heavy input from WMPC. Liaison over a 15-month period initiated by WMPC working through SCC has not resulted in any specific proposals. WMPC and its neighbouring parishes have also advised on a number of design improvements which would reduce the landscape and visual impacts arising from the siting and design of the SP&R. Mitigation is needed to reduce visual impacts from a number of public right of way locations which EDF have failed to recognise. Night time lighting impacts will be significant and harmful to the landscape character of dark skies and residential amenity. We have requested simple and affordable landscape and habitat enhancements which will provide a legacy benefit beyond the life of the facility. I support the further specific concerns and detailed points raised by WMPC in their DCO RR submission dated 21st September 2020. If the DCO is consented: Full design detail incorporating the requested mitigation to be secured by Planning conditions and incorporated into a legal agreement for the SP&R and Wickham Market road network. Guarantees to ensure that EDF and the County and District LPA’s commit to process detailed design and monitoring effectively through the planning process. Guarantees to ensure that EDF and the County and District LPA’s are equipped to ensure full compliance with the implementation, environmental restoration, long term landscape and habitat management. Guarantees to ensure that the Parish and local interest groups are engaged with the submission at all stages. Anne Westover BA Dip LA CMLI 28th September 2020