Representation by Together Against Sizewell C (TASC) (Together Against Sizewell C (TASC))
- Date submitted
- 29 September 2020
- Submitted by
- Members of the public/businesses
Together Against Sizewell C (TASC) is a group of people formed to oppose the building of Sizewell C and its associated works in a legal, open, peaceful and fully accountable manner. At this preliminary stage, TASC’s main concerns are summarised below and stand as TASC’s Relevant Representation. TASC will refine and amplify its case through its written representations. (1) The insufficient justification for the proposal. Whilst SZC is noted within EN-6 as a potentially suitable site, that only applies to reactors deployable before 2025 (EN-6 para.2.2.2). Pursuant to that framework, a DCO was granted for Hinkley Point C in 2013. A new nuclear policy statement (for post 2025 deployment) has yet to be published, following consultation on siting criteria in 2017-2018. It follows that there is no NPS which establishes the “need” for a new nuclear power station post 2025, or the appropriateness of SZC for that purpose, when judged against the reasonable alternatives. To this end TASC will draw attention to the Government’s siting criteria in the December 2017 consultation (“Draft Siting Criteria”), as a material consideration pursuant to s.105(2)(c) Planning Act 2008. (2) The impact on the landscape character and visual amenity of the area. TASC endorses the observations of the AONB Partnership Board and notes the Promoter acknowledges adverse effects during the operational phase (60 years) on the character and appearance of the area, including on the AONB. These include a significant adverse effect on the Estate Sandlands and Coastal Levels LCA and a range of prominent viewing points, even after mitigation, see ES Volume 5, Chapter 13. The impact principally arises from new roadways, access connections to the rail head and potential new transmission lines, potential impact from new flood defences and loss of the historic landscape character, acknowledged in ES Volume 2, Chapter 16 at paragraph 16.6.122. The Government’s view is that new nuclear power stations should be sited to avoid “significant adverse impact” on designated sites of amenity and landscape value (Draft Siting Criteria, para.2.81). (3) The impact on cultural heritage. The Government’s Appraisal of Sustainability of SZC (October 2010) identifies the potential for an impact on a number of heritage assets, including a Scheduled Ancient Monument, Conservation Areas, Listed Buildings (paragraph 5.60). EN-1 provides that there is a presumption in favour of conservation of assets (paragraph 5.8.14). Within the ES, Volume 2, Chapter 16, the Promoter identifies harm to the significance of a number of heritage assets during the operational phase, of particular concern is the impact on the Pillbox in Pillbox Field and Leiston Abbey. Moreover, there are significant effects identified during the construction phase (9-12 years) on the Leiston Abbey Scheduled Monument (first site) and a Grade II Listed Cottage 450m west of Upper Abbey Farmhouse. (4) The impact on the public rights of way network. The proposal would seek the stopping-up and diversion of a number of rights of way (ES Volume 5, Chapter 2). EN-1 acknowledges the social importance of rights of way (paragraph 5.10.24). TASC are particularly concerned about the enduring adverse effect on the coast path arising from the beach landing facility and loss of Bridleway 19 known as “Black Walks” and the connectivity to other well used footways along the coastal stretch. (5) The impact of the construction, decommissioning and storage phases on carbon generation. TASC considers there to be inadequate evidence on the carbon impacts of the construction, decommissioning and storage phases of the proposal. Without assessment, TASC consider the proposal cannot be said to make a meaningful contribution to meeting the UK’s obligations under the Paris Agreement. (6) The proposed freight and transport strategy is inadequate. TASC endorses the observations of Suffolk County Council in this respect. Moreover, TASC notes the acknowledged significant adverse effect during the operational phase on pedestrian access arising from the two-village bypass and Sizewell link road (ES, Volume 2, Chapter 10). Access to and from the very rural and remote site during construction will cause an unacceptable level of HGV, bus, van and car movements. It will also promote car and van displacement onto many minor roads. The proposed Link road will cross and divide existing viable farms, impinging on many C class roads and cycle routes. The suggested rail delivery programme is also a contentious matter with many unresolved issues (7) The impact on the Sizewell Marshes SSSI, SPA and SAC. TASC endorses the observations of Suffolk County Council in this respect. The promoter acknowledges that during the construction phase, even with mitigation, there would be a significant adverse effect on Red Data Book species such as Deptford Pink (plant species), Marsh Harrier and barbastelle and Natterer’s bats which have been identified due to habitat fragmentation during construction. The Government’s view is that it would be preferable for sites to be located in an area unlikely to cause an adverse impact on nationally designated sites of ecological importance (Draft Siting Criteria, para.2.71). Moreover, EN-1 provides that proposals should avoid significant harm to biodiversity and that appropriate weight is afforded to designated sites (such as here) (paragraph 5.3.8). (8) The impact of the access road dividing the AONB in two together with the SSSI crossing over the water courses to the SZC site by a culvert. This is unacceptable, causing irreparable damage to the SSSI: water management, quality and levels are key to the overall ecology of the Sizewell Belts SSSI and changes must be avoided. No mitigation will suffice to counter the damage to this sensitive area. (9) TASC’s other concerns:- The Planning Statement - excessive use of Rochdale envelope where more detail should be provided now - lack of application of the UK Marine Policy Statement 2011 - use of IROPI to justify the development - Common Law Nuisance and Statutory Nuisance - lack of integration with numerous other energy infrastructure projects affecting the region -implications of local and regional planning policy Coastal Processes, Flooding & Hydrology - insufficient detail of hard sea defences -inadequacy of hard sea defences to protect SZC site, staff and local communities until decommissioned/waste removed-should be applying precautionary principle - adverse impact of sea defences on SZC’s neighbours especially as seaward building line further east than SZB - impact of permanent beach landing facility on coastal processes and environment - EDF’s unsubstantiated reliance on recent history and offshore geomorphology leads to an understatement of the vulnerability of the site to flooding - recent concerns over the rapid melting of the East Antarctic icesheet predict a 3.5m sea rise over a relatively short period of time - impact on water-level dependent flora and fauna, affecting nationally and internationally designated areas, due to fluctuations the development will cause to groundwater levels and drainage Site Safety - danger to SZB from construction - proximity to SZB viz physical security with 1,000s of workers adjacent to working plant - at 32ha the site is too small for all the buildings to safely accommodate 60+ years of operation (lack of location/description of all essential buildings and structures in DCO) - SZC will be a de facto nuclear waste storage facility for at least 150 years, but indefinitely if no Geological Disposal Facility (GDF) built - impact on SZB emergency planning Landscape, Heritage & Visual Impact - impact on the qualities that gave rise to the AONB designation, compromising the status/integrity of the AONB - nighttime light pollution for a twelve year period causing negative impact on Suffolk’s celebrated ‘dark skies’ - visual and ecological impact of SZC site buildings, associated construction works and pylons unacceptable and mitigation measures inadequate or non-existent - lack of visuals during construction Land Habitats & Wildlife - damage to protected habitats: SSSI, Ramsar, SPA, SAC, - impact of vibration, noise, dust, light, air pollution on wildlife/residents - inadequacy of compensatory wildlife areas eg for Marsh Harriers - question biodiversity net gain - chemical, particulate run-off from vehicles/construction activities/ concrete batching plant into extremely sensitive water systems and wider environment - EDF promote new roads, roundabouts, park and ride facilities and rail as mitigation, but they cause more environmental damage and pollution in the affected communities, also adding to the project’s carbon debt - no assessment of overall cumulative impact within the environmental statement - inadequacy and omission of Environment Impact Assessment data means proper scrutiny not possible Marine Environment & Marine Conservation Zone - unsustainable fish/other marine life take from cooling water intake pipes, impacting on dependent wildlife - impact on recreational/commercial fishing - pollution & heat from sea water outlet pipe - environmental damage from constructing pipework & beach landing facility Community Impacts - boom & bust effect - EDF overstatement of local employment gains, including the unemployed - transfer of workers from HPC & not being locals ie undermining the economic case - negative impact on existing tourism industry - loss of qualified staff by existing local businesses e.g. care services - construction starts before new infrastructure in place - 24/7 noise, vibration air, dust and light pollution from traffic, construction, accommodation blocks, spoil heaps, borrow pits, concrete batching plant etc - potable water consumption by SZC is unsustainable: water co. says they can't supply amount needed during 10+ year construction and 60-year operation - inadequate assessment of predicted impact on fresh water supplies due to climate change/new housing/commercial developments and seasonal demand fluctuations on people, farmers & businesses - usage during operation understated when compared to the Environment Agency Generic Design Assessment for UK EPR reactors - post-operational low-level radiation health effect poorly understood - up to 7,900 workers overwhelming the area - impact on health and fire emergency services, doctors' surgeries, hospitals - impact on local housing availability is unacceptable - risk of virus introduction into local community from large influx of personnel National Policy - matters referenced to the Draft Siting Criteria in paragraphs (1), (2) & (7) above are similarly referenced in the extant EN-6, including paragraphs C.8.2 and C.8.4, C.8.68, C.8.52 onwards and C.8.60 onwards, respectively - no energy white paper despite promises from Government - no public consultation since 2007/8 on need for new nuclear, despite promises - Defra’s 25-year environment plan- SZC fails on most/all of 10 key aims Finance - EDF's precarious financial position means it is unsuitable as developer and/or future operator of SZC - EDF’s application states that it does not have the funds to build SZC - EDF cannot demonstrate they can meet payments for compulsory purchases - Nuclear electricity is more expensive than from renewables: unfair on the consumer, particularly lower paid - EDF has proposed RAB funding model. Unfair to expose UK bill/taxpayers to SZC’s costs and risks Carbon Targets - IROPI undermined by historic reduction in electricity demand and plant’s predicted failure to make significant contribution to climate change gas reduction as net zero carbon required by law in 2050, only ten years after Sizewell C has repaid its carbon debt from construction, leaving no energy sector carbon to off-set between 2050 and plant’s predicted closure in the 2090s - lack of information for independent verification of EdF’s carbon emission claims: which government body is responsible for checking EDF’s carbon calculations? TASC are dissatisfied with how EDF have conducted the DCO application process - Developer should have postponed the process until such time as communities impacted by SZC had no Covid-19 restrictions - potential that possible restrictions on public gatherings/shielding/ lack of access to libraries etc will have compromised the ability of many to fully engage in the DCO process - Non-availability of reports referred to in DCO - the maps in the DCO documents are, in many instances, hard to read and understand especially as they show no grid references - the mobile bus was a pitiful attempt to engage, especially when many were too scared to visit due to Covid-19 worries - SZC DCO is not suitable for a purely digital examination/virtual hearings TASC reserve the right to comment further if the developer releases additional information. TASC refutes as entirely false the EdF claim that the proposed development will bring a net gain in either economic activity or environmental gain in respect of increased biodiversity. Conversely, it will wreak havoc on a heritage coast renowned for its tranquillity and natural beauty, bring economic hardship to its thriving tourist industry and devastate the lives of residents over a protracted period of time, leaving a lethal nuclear waste legacy for future generations to assume.