Representation by Stop Sizewell C (Theberton & Eastbridge Action Group) (Stop Sizewell C (Theberton & Eastbridge Action Group))
- Date submitted
- 29 September 2020
- Submitted by
- Members of the public/businesses
Relevant Representations of Stop Sizewell C (the campaign name of Theberton and Eastbridge Action Group on Sizewell Ltd) 1. Project Financing There is no certainty the project can be financed. EDF’s indebtedness is widely acknowledged and the government has given no assurances regarding funding models or direct investment. 2. Site Selection The UK’s 2011 National Policy Statement EN-6 concludes that Sizewell is a potentially suitable site for new nuclear power stations generating to the grid before 2025. This conclusion is out of date as EN-6 predates government acceptance of the Paris agreement on climate change and legislation to make the UK Zero Carbon by 2050 We believe this is the wrong project in the wrong place because The site is at risk from climate change, sea level rise and fluvial flooding; It will have an adverse impact on adjacent internationally designated sites of ecological importance; It will have unpredictable and adverse impact on coastal processes; It will have an adverse impact on sites of amenity, cultural heritage and landscape value; Sizewell C’s construction will be slow, 10-12 years, and have an adverse impact on carbon targets. EDF documents show Sizewell C cannot contribute to UK’s CO2 targets until 2040 at the earliest whereas CCC says urgent reductions are needed before 2030 to meet our 2050 net zero target The 32ha twin reactor development (c.f. Hinkley Point C 45ha) requires increased coastal exposure, relocation of existing Sizewell B facilities, other design compromises and is well below the EN-6 presumption of 30ha for a single reactor installation; Eight other uncoordinated energy projects planned for the locality will result in significant cumulative impacts on East Suffolk’s environment and economy; There is no sustainable solution for the long-term safe disposal of nuclear waste. Spent fuel would stay on this eroding coastal site until at least 2140. There are major concerns over flooding and overtopping during storm surges, and ultimately the site will become an island if sea levels rise to predicted levels. 3. Local communities Unacceptable impacts on local communities, in particular Leiston, Eastbridge and Theberton; and settlements along the B1122 and A12. Nearby residents will experience noise increases 600 times ambient levels; noise levels at Old Abbey Care Home will increase 200 times. 4. Worker Campus The campus would have significant impacts on local communities during construction and thereafter because of noise, light, pollution, traffic and social pressures. The developer does not provide sufficient justification for its location and impacts. EDF has not adequately responded to suggestions from Suffolk CC for other locations, based on a consultants’ study. 5. Transport and related associated development EDF’s has rejected a marine transport strategy due to environmental and geomorphological concerns but extensive use of rail has also been rejected with insufficient justification. The (“integrated”) transport strategy proposed is not sustainable and would have adverse impacts on communities and significantly damage East Suffolk’s visitor economy. HGV numbers are as high as EDF’s “road led” strategy rejected during consultations. Upgrades to the A12 and B1122 are not proposed to start before site preparations and significant earthworks begin. Other energy projects are likely to be underway, including Sizewell B facilities relocation. Road upgrades must be brought forward to avoid significant impacts to communities along the A12 and B1122. We oppose the Sizewell Link Road which will isolate and sever communities, damage the rural footpath system and divide farmland threatening viability. It has no legacy value for communities and would perpetuate damages and community severance. Alternative Link Road routes have been dismissed by EDF with insufficient justification. We share the concerns of the respective Councils, Parishes and communities about location, design and impacts of the Yoxford Roundabout, both Park and Rides, Two Villages Bypass, A12 modifications and Freight Management Facility. 6. Landscape & Heritage The development, by virtue of locality, design and scale, would have a catastrophic long-term impact on landscape character. It would have an adverse impact on integrity of the AONB and many nationally and internationally designated nature conservation areas. The planned mitigations for landscape and ecological damage are inadequate and would not compensate for damage done during construction and the lifetime of the power station. The proposed development would affect the settings of 90 heritage assets. 7. Environment Impacts on Minsmere Sluice cannot be assessed due to the combination of changes in ground and surface water and an incomplete plan for access to potable and construction water supplies. The need to provide an adequate drainage and water supply for the construction period and beyond is not fully addressed Abstraction of water will have impacts on the environment and protected species. The risks to groundwater levels and surrounding habitats and ecology have not been adequately assessed and mitigated. Proposals increase flood risk due to the loss of flood storage from the main development site footprint. The environmental implications of the proposed stockpile and spoil storage areas are unclear with contradictory statements and assessments The construction phase would result in unacceptable levels of environmental pollution, including light, noise, traffic and dust. Mitigation of the environmental impact of the proposed borrow pits and subsequent landfill and other areas of landfill has not been addressed. The development does not address the potential adverse impacts on species and habitats in the marine and terrestrial environment. Implications for the integrity of designated sites, including internationally designated European sites and European marine sites and nationally designated sites - SSSIs, the AONB - and impact on local, regionally and nationally significant natural history is not adequately addressed. RSPB Minsmere is of international significance. We are concerned that Minsmere would be irreparably harmed by the proposed development. This would damage the UK’s reputation for conservation as well as the visitor economy. EDF recognises that there could be impacts on Marsh Harriers which are protected species. EDF has invoked “IROPI” due to the impacts that cannot be mitigated or compensated for. 8. Marine and Coastal processes The effect of Sizewell C on coastal processes and flood risk is unclear as there is no submitted plan for the hard coastal defence structure and therefore cannot be assessed. The Monitoring and Mitigation Plan, being discussed with local authorities, needs to be made public for assessment at the examination and the Marine Technical Forum responsibilities, powers and transparency need to be defined. EDF predictions of when the hard coastal defence will be exposed cannot be taken seriously without a completed design being specified. EDF have not justified the assertion that coastal effects to the south will not extend beyond the coralline crag to the north of Thorpeness. EDF cannot justify the assertion of shingle accretion north of the site until a complete design of the hard coastal defence is presented for assessment. The impacts on marine ecology during construction and operation has not been adequately assessed. 9. Economic and social impacts An independent consultant concluded the Sizewell C Economic Statement does not comply with the developer’s responsibilities to properly assess impacts as described in EN-6 EDF’s own surveys reveal a significant percentage of visitors will be deterred from visiting the area during construction, thereby damaging the Suffolk coast visitor economy. Suffolk Coast Destination Management Organisation found that tourism could lose up to £40 million a year, with the potential loss of up to 400 jobs. Unacceptable pressure on local housing accommodation. Does not address the impact of the development on the availability of tourism accommodation, particularly during construction. Inadequate information to support claims of supply chain benefits. Does not adequately address the impact on jobs and skills, during construction and operation. Does not address the issue of locally based employment. Sectoral work is inadequate and does not help to explain what jobs, at what skills/remuneration levels, will be available to local people. Details of proposed housing and tourism funds inadequate. Minimal consideration of potential negative impacts on local businesses outside the nuclear supply chain whether through competition or disruption to investment. No account of long-term negative impacts on the environment and future natural capital and tourism value of the site or long-term view of the economic legacy of a comparable project other than jobs created in the nuclear sector. No detail on how vulnerable children and adults might be impacted in the short to long- term. 10. We wish to raise concerns about the Planning Statement generally including; Proposed use of ‘Not for Approval’ plans Consents and Powers in the Draft DCO Approach to environmental mitigation, management and development flexibility (Rochdale Envelope) Approach to Subsequent Approvals Planning conditions and legal agreements NPS EN-1 and NPS EN-6: Applying the Policies to the Sizewell C Application Compliance with Planning Act 2008 (as amended) and relevant national policy statements for major infrastructure Construction worker Social/Community Mitigation Transport and Freight Management strategy Stop Sizewell C endorses the Relevant Representations of Royal Society for the Protection of Birds Suffolk Wildlife Trust Theberton and Eastbridge Parish Council Minsmere Levels Stakeholder Group Nick Scarr Stop Sizewell C believes that the Sizewell C DCO is totally unsuitable for “virtual” examinations. Under Rule 14(3) of The Infrastructure Planning (Examination Procedure) Rules 2010, Stop Sizewell C may wish to call expert witnesses in support of this representation or subsequent written representations.