Representation by Bill Parker
- Date submitted
- 30 September 2020
- Submitted by
- Members of the public/businesses
As the former Head of Coastal Management for Suffolk I wish to express deep concerns about the proposed EDF development at Sizewell C, especially: Application process and documentation A digital examination process in the current pandemic is totally unsuitable for this application due to its complexity and size, making it very difficult for local community to respond. Documentation is excessive and incomplete. Illustrations/cross-sections are often misleading and without reference points. Some evidence documents have been withheld preventing proper independent examination. The EDF application fails to adequately address many issues: Site selection: • The site is at significant risk from sea level rise, flooding and climate change with inadequate mitigation. • Non-compliant with EN-1 or EN-6. • Inappropriate scale for such a fragile coastline and environmentally sensitive location. Coast and marine: • Ambiguous location of hard coastal defence feature (HCDF). • Defences fail to meet design standards or requirements of ONR/EA FCERM advice. • EDF’s unevidenced confidence about the exposure of HCDF from 2053 on coastal processes for 160+ years if not in perpetuity. Inadequate mitigation of the impact coastal processes on adjacent coastline, especially Minsmere and Thorpeness. • Vulnerability to climate change of site critical functions (eg nuclear waste). • The DCO submission doesn’t reflect CEFAS scientific reports’ evidence • Intake and discharge proposals contravene Habitat Regulations • Confused/misleading timescales • Failure to follow precautionary principle, inadequate mitigation. • SSSI crossing and culvert function lacks clarity and hydrology is poorly assessed. • Unclear future for fresh and potable water management and Minsmere Sluice • Incomplete tsunami and Coralline Crag risk assessments. • Unacceptable loss of beach access • Potential in-combination risks ignored • Lack of independent assessment of proposals. • Environmental Impact Assessment severely compromised. Local Community: • Woefully inadequate road infrastructure to deal with huge increases in traffic/HGVs. Marine/rail options not fully explored. No legacy value in road improvements. • Delayed access to emergency services and inadequate healthcare capacity. • Heightened pandemic risk • Distortion of the housing sector due to worker influx. Economic impact • Devastation of tourist economy and infrastructure with predicted loss of visitors. • Disruption to existing businesses through loss of staff for unsustainable short-term EDF roles. Environment and Landscape • Poor air quality; existing high regional ozone pollution exceedances exacerbated. • Disastrous impact on landscape which is impossible to compensate for • Catastrophic destruction of fragile protected habitats: impossible to mitigate for; intolerable given UK biodiversity losses. • Poor understanding of ground and surface water relationship despite being a Scoping Report Opinion requirement. Long Term Future • A contaminated residual core will remain and impact the coastline in perpetuity, this has not been taken into account. • Climate change predictions do not take the precautionary approach are woefully underestimated. • Claims of benefits in tackling climate change are selective and inaccurate • Issue monitoring and mitigation response is weak. • The long-term legacy will leave East Suffolk with untold costs and have little benefit I wish to endorse the Relevant Representation submitted by Stop Sizewell C, TEAGs, RSPB, Minsmere Levels Stakeholder Group, Suffolk Coastal FOE, Alde and Ore Association and from Mr Nick Scarr. This application should be rejected by PINS as being unsuitable for this location.