Back to list The Sizewell C Project

Representation by Heveningham Hall Estate (Heveningham Hall Estate)

Date submitted
30 September 2020
Submitted by
Members of the public/businesses
  1. The Heveningham Hall Estate (HHE) OBJECTS to NNB Generation Company (SZC) Limited’s (Promoter’s) application for development consent for the Sizewell C project (the Project). 2. Part of HHE is located south of the temporary Northern Park and Ride site (NPR site) west of Darsham, which forms part of the Project. A proportion of HHE also falls within land to be compulsorily acquired to facilitate the roundabout at Yoxford (plot OHI/24/02). 3. HHE’s objection concerns three principal grounds: ecology; transport and heritage. ECOLOGY Shadow Habitats Regulations Assessment (Shadow HRA) 4. The air quality work that underpins the conclusions in the Shadow HRA is incomplete, such that the assessment is not informed by the best available scientific evidence and there are lacunae. (a) Only a limited number of receptor locations used for modelling (usually only one per designated site) and no justification for the location selections. (b) No assessment of ammonia deposition in Environmental Statement (ES). In contrast, see Institute of Air Quality Management’s May 2020 guidance. (c) Promoter assumes predicted exceedance of critical loads and levels for nitrogen oxides concentration, nutrient nitrogen and acid deposition are only relevant to “proportions of the site immediately adjacent the road”. This conflicts with Natural England guidance. Promoter should quantify or model the geographical extent of effects to enable consideration of potential ecological effects. (d) Save for two brief references, there is no evidence that Promoter has considered other plans or projects to identify in combination effects. 5. Assessment of recreational effects not supported by best available scientific evidence and there are issues with Promoter’s approach. (a) Out-of-date data from 2014/2015 informs baseline position on visitor pressure. (b) Focus on the DCO application with no consideration of other plans and projects to identify in combination effects. A material oversight. (c) Reliance on a Rights of Way and Access Strategy to mitigate potential significant effects on designated sites, yet the strategy has no specific details on the affected sites or any proposed measures. (d) Draft s.106 Heads of Terms refer to European sites contingency fund to “support measures where monitoring identifies a potential risk of harm occurring as a result of additional use of these areas” arising from recreational displacement. Also reference to ‘resilience funds’ for RSPB Minsmere and the National Trust Dunwich Heath and Beech relating to “increased use by visitors or works and potential visitor displacement as a result of the Sizewell C project”. The need for these funds undermines conclusions in the Shadow HRA that the proposed development will not adversely affect the integrity of any European sites. Promoter appears to agree that there is uncertainty. Also no clarity as to precisely which avoidance/mitigation measures this would fund, the mechanism for remedial work if required or how this would be agreed with the relevant authorities. 6. Promoter’s compensatory measures for marsh harriers have not been finalised and are uncertain. (a) Feasibility and Design Report not provided. Impossible to assess assumptions and calculations to ensure these are robust. (b) Doubt over adequacy of compensatory measures: Promoter proposes to replace wetlands with 48.7 hectares of terrestrial habitat, which is less than half the size of habitat to be lost. (c) No information provided regarding scope, timings or methodology for monitoring surveys. (d) Unclear whether the methodology for quantifying marsh harrier foraging behaviour to inform compensatory measures is based on precedent. If not, there is uncertainty over the likelihood of success. NPR site 7. There are significant issues with the ecological surveys undertaken at NPR site. (a) Most surveys informing baseline at NPR site undertaken over 3 years ago (most 5 years ago). Chartered Institute for Ecology and Environmental Management advises reports based on data over 3 years old unlikely to still be valid. Updated surveys required, otherwise Promoter’s conclusions on potential effects weak and open to challenge. (b) Limited (if any) weight should be attached to 2018 walkover survey given lack of information about methodology, scope or findings. (c) Promoter has failed to assess whether NPR site supports protected species, specifically roosting bats and reptiles. Further work is also needed to establish whether use of the site by badgers has changed. 8. Promoter’s assessment of ecological effects is weak in a number of areas. (a) Assumptions that Great Crested Newt meta-population is spread across 6 ponds is not supported by evidence and is based on aquatic data for one pond, which is over 5 years old. Assumptions about the A12 representing a fundamental barrier to the movements of newts are incorrect. (b) Lack of clarity in relation to the condition and value of habitats both within and adjacent to the site, including Little Nursery Wood. 9. Doubts over adequacy of proposed mitigation measures, which are scant on detail and inconsistent. (a) To protect roosting bats, ES advises that lighting along Little Nursery Wood will not exceed 0.1 lux. However, the Illustrative Lighting Plan (Figure 2.5) shows greater light levels (potentially 7.5 lux). (b) Ecology chapter refers to 20 metre buffer between the development and Little Nursery Wood, yet no details provided regarding the composition or design of this zone. (c) ES states there will be 10 metre buffer between the development and the on-site pond recorded to support a population of Great Crested Newts. However, certain drawings show works in this zone and details are unclear. (d) Considerable uncertainty regarding restoration of NPR site post construction, as the retention of any mitigation planting remains to be agreed with the landowner. Yoxford Roundabout site (YR site) 10. Additional work needed to ascertain the presence or absence of protected Sandy Stilt Puffball, roosting bats and reptiles from within the site. Otherwise, impossible to grant a legally robust consent. 11. Inconsistencies within surveys. E.g. dust report asserts there are no sensitive habitats within 500 metres, yet Roadside Nature Reserve 197 (a non-statutory designated site which the Promoter has assessed to be of national importance) is immediately adjacent. TRANSPORT The Transport Strategy 12. No justification for lack of marine-led strategy. Some abnormal indivisible loads (AILs) to use road. DfT has a “water preferred” AILs policy. No information on numbers of AILs using beach landing facility (BLF)/road. No information on anticipated use of BLF. Justification for road based AILs and underutilisation of BLF required. 13. Shift arrivals/departures should be staggered particularly at peak times. Clarification required whether shift patterns in Transport Assessment (TA) Appendix 7B are to be employed or if only used for worst case scenario modelling. 14. Tidal movements of 3000 on campus/caravan workers Friday evenings/Monday mornings not obviously included in trip generation and model. Confirmation required. 15. On campus/caravan workers not distributed in the gravity model (TA Appendix 7A). 16. Average vehicle occupancy at NPR is given as 1.06 (1,230 workers in 1,158 vehicles; Table 2 of Appendix 7A); this is lower than the range of 1.10-1.54 assumed in TA for home-based and non-home-based workers respectively. Clarification required. 17. Various mathematical inaccuracies in TA Appendix 7B. See tables: (a) 3 and 4 - sum of the workers in the second column is not 580 but 531; (b) 5 - NPR predicted to be used by 1,221 main site workers. 1,230 recorded in Gravity Model (Table 2 of Appendix 7A) and a total of 1,419 workers (they were 1,429)); (c) 6 – Suggests 970 total vehicle trips (of main site workers) predicted to use NPR, while Table 2 of the Gravity Model suggests 1,158 trips. 18. Some data unclear in TA appendix 7B (e.g. did Visum model include “busiest day” or “typical day” HGV figures during the peak construction scenario?). See Tables: (a) 2 - what does “or 20 / 30 / 30 / 20” in Early Shift row (last column) refer to? (b) 8, 9 and 32 - Tables 8 and 9 set out assumptions in relation to lead time for arrival trips to main site and lag time for departure trips from main site, respectively. Why does Table 9 not include allowance for waiting for the bus (like in Table 8)? Same query Table 32; (c) 13 - Car park accumulation during peak construction estimated through arrivals/departures profiles, assuming, however, `base level’ of occupancy during quietest hour of the day. How was 69 cars base level calculated for NPR (Table 13 – between 02:00 and 03:00)? (d) 26 - Why no bus journeys shown in some hours (e.g. between 09:00 and 13:00, including the column of the NPR?) Does it mean no buses will run? 19. Inconsistent use of Junctions 9 (J9) in standalone junction modelling. Base scenario of the YR not modelled in J9. Other junctions modelled in Vissim and J9. Explanation required. 20. Modelled queues at Darsham level crossing do no match observed queues (see Figures 8 to 13 of the Technical Note at Appendix 9B). Not even “reasonably well matched” (see Paragraph 4.3.6 of the Technical Note (Doc Ref 8.5)). Typical conditions not modelled. Tables 12, 13 and 14 misleading as all individual sections of the routes appear to meet WebTAG criteria (“Pass”). 21. No evidence for assumption that North/South HGV distribution is 15%/85%. Evidence to be provided. HGV routes queries. HGVs appear (from the plans) to use the B1122 even east of the new link (via a roundabout) with the Sizewell Link Road (SLR), some 800 metres east of the Yoxford roundabout. Is that right? Construction Traffic Management Plan (CTMP) does not specify how many HGVs are anticipated to arrive from south and how many from north. 22. Total and daily numbers of AILs not assessed. AIL route assessment not yet undertaken. Considered required for DCO to properly assess impacts on local roads and villages. 23. Not yet clear that impact assessment relies on solid and flawless assumptions and models. Whole assessment is to be questioned. NPR site 24. Site selection process fundamentally flawed: (a) Not a “rail and bus interchange”. 100 workers predicted to come by train daily, across two stations, Darsham and Saxmundham; i.e. around 50 at Darsham (see Table 7.1 of the TA). Increase in rail mode share not predicted/encouraged in Construction Worker Travel Plan (CWTP). Shuttle bus could easily include a stop at Darsham to collect these workers. Reality is NPR could be anywhere on A12. (b) No assessment of Darsham level crossing. Fails to acknowledge risks associated with the crossing. 25. Inconsistencies in data in numbers of hourly and daily bus movements. Also appears that there are hours with no bus services. Are there 322 daily bus movements (See Table 7.1 of TA – 644 assumed to be split 50-50% between NPR/Southern Park and Ride (SPR)) or 198 (Table 26 of the Technical Note at Appendix 7B of TA)? Clarifications required. 26. Gravity model has produced unreliable results. Workers living west of Saxmundham are predicted (Plate 7.4 of TA) to use NPR when they live closer to SPR. Workers living adjacent to the NPR are predicated to drive to the main development site. Query if TA numbers therefore reliable. 27. No evidence that NPR needs 1250 car parking spaces to meet demand. TA suggests 1006 max number needed at construction peak. Say 1056 (5% buffer). Could be less given flaws in gravity model. 28. No direct pedestrian connections to Darsham station. Link to southbound platform and footbridge to northbound platform could have been provided. Lack of connections surprising given suggestion is NPR located at station to create multi-modal hub. 29.Pedestrian infrastructure at Darsham station includes narrow footways and a level crossing. Mitigation package proposes no improvements to existing provision. Existing provision may present challenges for mobility impaired workers. Upgrades required. 30. Network Rail’s (NR’s) risk rating for Darsham level crossing is F2, with an Individual risk rating: F (Moderate), and Collective risk rating: 2 (Very High). “Very high” is one step below max level. NR identify key risks as: (a) Crossing is near a Station (b) Large Numbers of HGVs (c) Large Numbers of Users (d) Sun Glare (e) Deliberate Misuse or User Error (f) Blocking Back Addition of 150 HGVs (15% of 1000 HGVs from/to the north) plus 322 bus journeys (or perhaps 198 bus journeys) could exacerbate the Collective risk rating. Fundamental highway safety issue overlooked in the evidence base. 31. NPR would result in “unacceptable impact on highway safety”, (para 109 NPPF); it should be located elsewhere, or mitigation proposed to lessen the impact to an acceptable level. 32. Promoter needs to justify current NPR location. Alternative locations for NPR should also be explored, as there are better options. YR 33. Fundamental flaws in J9 modelling. Geometries manipulated to replicate anticipated driver behaviour and predicted uneven lane usage – J9 model is able to carry this out with Lane Simulation tool. Promoter should update model accordingly. Model therefore underestimates capacity, overestimates queues/delays. Existing layout (simple priority) to be modelled too in all base/forecast scenarios to demonstrate need for a roundabout. 34. Clarification required why roundabout designed for max RFC 0.77; RFC 0.85 would be expected, potentially RFC 1.00 during peak hours of peak construction period (i.e. limited time period where degree of queues and delays acceptable). Roundabout oversized. 35. Vissim model does not replicate observed queues “reasonably well” as validation report claims. Reliability of its outcome questioned. 36. No evidence junction requires a 60m ICD roundabout to offset development impact. Evidence needed to demonstrate why smaller one inappropriate. 37. Central overrunable / demountable island with demountable signs and bollards to be used for AILs should be removed and AILs rerouted to BLF. Overrunable / demountable areas should be removed at end of construction period. 38. Given inconsistencies, flaws and errors, query whether transport assessment can be relied on. 39. At the written representations stage Promoter will be asked to explain/justify various points, including: what has been agreed with stakeholders e.g. Suffolk County Council and NR; the size and location of NPR (including impact on Darsham level crossing), underutilisation of BLF; over-engineering of YR. HERITAGE 40. For circa 12 years construction traffic will pass through towns and villages that contain heritage assets. E.g. approximately 150 heritage assets are located on HGV/park & ride (P&R) bus routes noted in TA and CTMP, including Grade 1 and Grade II* buildings and scheduled ancient monuments (based on HGV routes 1a, 2a, 3a on Plate 3.2 and 1b, 2b, 3b on Plate 3.3. of CTMP and P&R routes on TA Plate 7.5). Yet the Promoter has only assessed the effect of construction traffic on heritage assets near the two village bypass, YR and SLR during the “operational” phase. A material oversight given significant construction volumes. At peak construction (busiest day) 12,694 movements are predicted by the Promoter and 12,342 movements (typical day) (excluding motorcycles/mopeds): (a) TA includes following daily figures: 10,092 car trips (Table 7.2); 702 LGV movements (Table 7.3 and Table 7.1); 1140 HGV movements (busiest day) (Table 7.4; Table 7.1 states 1000 HGV movements); 790 HGV movements (typical day) (Table 7.4; Table 7.1 states 650 HGV movements); 700 P&R bus movements (Table 7.5; Table 7.1 states 644 bus movements); 24 shuttle bus movements (Table 7.1); 32 coach trips (Table 7.6); (b) CTMP predicts 2.2 AILs daily (paragraph 3.3.11 CTMP) based on 4 abnormal deliveries by road per day on 50-60% of days. 41. Other concerns not addressed by Promoter include: (a) the need to ensure character of ancient settlements/landscape not eroded by accretive change in vehicular movements. Noise and visual intrusion can be very harmful in rural settings and 12 years is a long time; (b) even small changes in a sensitive setting can be harmful; (c) noise and visual mitigation measures may be inappropriate for heritage assets (e.g. additional glazing or screen planting); (d) deposits from vehicle exhausts may damage or effect the appearance of heritage assets; (e) given its proximity to YR, unassessed effects on Cockfield Hall. 42. Heavy volumes of daily construction traffic (including HGVs/AILS) over circa 12 years may adversely affect the setting (rural or otherwise) and therefore the significance of certain designated heritage assets. While some assets located on the A12 may already experience some noise and visual intrusion, it cannot be assumed that there will be “no harm” without assessment. 43. Some assets on HGV/P&R routes include places of quiet contemplation, faith and remembrance and therefore may be particularly sensitive to additional noise intrusion (even a minor change may have significant adverse effects on setting). As all of these heritage assets are Christian places of worship, Equality Act 2010 considerations are engaged. Promoter has not carried out an assessment. Compensation 44. Compensation considered most appropriate, since mitigation or compensatory measures in respect of each potentially affected heritage asset would be impracticable. A historic environment fund should be established and secured by s.106 agreement from which sums can be drawn down for compensatory measures relating to specific assets, or groups of assets, at a later date. Appendix 8.4J (Draft Section 106 Heads of Terms) proposes various different funds; none relates to the historic environment. Petition 45. TASC and SSC have launched an on-line petition asking the public to confirm their objection to the application. The petition has already been signed by 9300 people.