Representation by Great Glemham Farms (Great Glemham Farms)
- Date submitted
- 30 September 2020
- Submitted by
- Members of the public/businesses
Thank you for the opportunity to present professional views and feedback on the application to build a new nuclear power station on the Suffolk coast. I am writing as a Partner in a family owned farming business, Great Glemham Farms. I also work as the owner, director and curator of the Alde Valley Spring Festival Ltd; and on a voluntary basis as Patron of Poetry in Aldeburgh and International Patron of Pesta Nukenen dan Kebudayaan Kelabit - a community owned food and cultural festival in Central Borneo / East Malaysia. My professional interests revolve around sustainable development, with special interests in the interweaving food, landscape and the arts with renewable energy technologies and high capacity ICTs in rural areas. Key targets and measures of success / KPIs that are work with are : protection of natural / heritage / landscape assets; delivering developments that are sensitive and proportionate to the local socio-economic and landscape setting; ensuring direct onsite ecological enrichment; delivering dispersed ownership of new technologies and their economic opportunities; delivering knoweldge gain and deispersal. I have worked on capacity-building projects in the UK and South East Asia, delivering through-supply chain benefits to private businesses, local communities and local economies. Looking at the proposed development, the following issues seem to have remained unaddressed, and are directly relevant to the long term safety and welfare of East Suffolk residents, including the value of their local economy and the quality of their natural resources. Point 1. Risk Analysis : Locating a Nuclear Power Station on a Soft, Low-lying Erodong Shoreline. Strategically, during a period of rising sea levels, climatic instabillty and increased risk of storm surges, it seems to make no sense to locate a new nuclear power station, with a proposed lifetime reaching decades into the 21st century, on a soft, low-lying and rapidly eroding shoreline. To do so would seem to invite unnecessary levels of risk to both the proposed development itself and to the local area. Sizewell A and B were both developed prior to an awareness of the real extent of risk that we are beginning to encounter due to climate change. The Greenland ice shelves and Arctic sea ice are melting at previously unimagined rates. Tidal surges and storm surges are also becoming more severe. Locating a large nuclear power station on this site - compared to a site on an elevated, rocky or secure coastline - seems completely illogical. It makes no geographic sense and introduces risks that are of potential very high, both for the local area and also for the broader region. Point 2. Risk Analysis : Potential Impacts on Local, Regional and National Food Supply Chains Some of the UK's richest farmland lies within a 20-40km radious of the proposed development site. The area produces significant proportions of the UK's root vegetables, potatoes and pork. The nearby Alde Valley and associated Suffolk River Valleys of the Waveney, Deben and Orwell are home to one of the UK's most job-rich, innovative and diverse local food economies - as evidenced by the abundance of small independent food producers, processors, distributors and retailers. The accident at Fukushima has resulted in an exclusion zone that extends up to 20km inland. God forbid that such an accident should ever happen at Sizewell, but the potential impact - and therefore risk - to the local, regional and national food economy should not be ignored nor underestimated - which in turn raises the significance of Point 1 above. Point 3 : Potential Impact upon Subterranean and Surface Water Resources in East Suffolk I work in the Upper Alde Valley. My farm is located in the valley bottom and includes fields / flood meadows that lie in the floodplain of the River Alde. In 2017 I was responsible for researching a WEG / Water Evironment Grant for a larger family-owned farming business that I am a partner in - Great Glemham Farms. Part of the R&D process for this application involved receiving multi-agency advice and input from Suffolk Wildlife Trust, the Environment Agency and Natural England. The intention was to adopt a water catchment area and landscape-scale approach to farm management practices over the five farms that we are fortunate to have in our care. During this process of consultation and field research on our farms, it became clear that the subterranean and surface freshwater resources of the Suffolk River Valleys [previously deisgnated as one of the UK's Environmentally Sensitive Areas by English Nature, as was] are in a parlous and vulnerable state. This is because there is no geological break or seal between the chalk aquifers that underly East Suffolk and the Alde and Ore rivers [including the Upper Alde and Fromus rivers] and groundwater - ie the water column is continuous. This introduces very significant risk of falling surface and groundwater levels in the valley bottoms - including river levels and flow rates, pond levels and well water levels. At my farm, the ground level in fields adjacent to the River Alde has fallen noticeably by up to 40cm as the river level has dropped and groundwater levels have fallen. This seems to be largely due to local water extraction of potable water by a pumping station at Benhall Low Street. This has put pressure on a local protected water source and the local water company has sought to buy out a protected source. From talking to various government agencies and from direct personal experience as a private sector water resource researcher, my observation to the planning inspectorate is that the local aquifers can or could in no realistic way sustain the scale of freshwater supply needed for Sizewell C : neither for its proposed labour force and temporary residential development; nor, especially, for the scale of the proposed building works and cement mixing. And to suggest otherwise would seem to defy reality. I would queston the abilty fo the aquifers to deliver the required water; and, given that the water column in the chalk aquifers is directly connected to and continuous with river levels and groundwater levels, there seems a very real and very significant risk of very considerable environmental disruption through sustained damage to the local groundwater resources. The Upper Alde Valley is already under water stress from current abstraction licences; increased housing developments in the area are also introducing similar stresses into the Fromus Valley in Saxmundham - and I presume closer to the coast too. It seems reasonable to place a requirement that all freshwater for the proposed development - for both drinking water and construction purposes, should be provided by a de-salination plant. To suggest and propose that the water requirements could be derived from local aquifers seems unreasonable and unwise, given the above-explained vulnerabilities. Point 4 : Impact of the Development Works on the Landscape Identity of East Suffolk The exceptional landscape quality of East Suffolk, The Suffolk River Valleys and the Suffolk Coast is one of the area's primary or foundational assets. It serves as both an anchor and a value multiplier for much of the local economy : through high value food production, processing and retailing; and also through relatively low impact, high income tourism. Recent estimates place the value of the local food and landscape based tourism sector for East Suffolk at over £1billion / annum. The scale, character, duration and above-identified risks of the proposed development do not seem proportionate or sensitive to, nor in keeping with the character and quality of the local landscape and its associated economy. Point 5 : Proposed Energy Supply Prices and Opportunity Cost The proposed supply prices of electricity generated by Sizewell C do not seem to compare favourably to electricity generated by offshore wind or onshore solar installations. From 2012 - 2018 I was responsible for managing the Landscape Management Agreement at Great Glemham Solar Park for BayWa renewables. As a local comparison, this 19MW site provides electricity at a fraction of the cost of nuclear - in terms both of the installation cost per MW generating capacity and the supply price to consumers per KWh. The conventional argument is that we need nuclear to bridge the transition gap between fossil fuel dependency and renewables, primarily onshore solar and offshore wind. In 2003 I spent a year researching onshore and offshore wind power for a farm policy report. It became clear that issues of intermittency in windpower begin to fall away as the grid geography increased - with a geographical grid reach of 1000km at the time being considered a critical threshold at which intermittency issues would begin to subside. With grid connectors now running between the UK and continental Europe, we are reaching this threshold. At the same time, as solar and wind generating technologies are improving, installation costs per MW or GW installed capacity are falling away rapidly - and battery storage technologies are also beginning to follow very similar trajectories, in terms of cost per MW / GW capacity and supply prices for re-released electricity. The time delay in building Sizewell C means that it is very likely - if not certain - that the entire development would be out of date by the time it became operational. The water resource needs, environmental impacts, build costs and electrocity supply costs of the equivalent installed generating capacity for renewables are miniscule by comparison. On most if not all fronts, nuclear power seems to be a fading energy technology. It is also one which generates highly dangerous waste as a bi-product - a waste for which the UK still has no long-term storage capacity. Overall, Sizewell C does not look like a development that is proportionate to or sensitive to the local Suffolk socio-economic and landscape setting. Nor does it seem to stack up financially in terms of installation costs and electricity supply prices, relative to cheaper, low-impact / high yield, less polluting renewable energy sources. Continued innovations in windpower, wave/tidal power and solar, combined with battery storage technoligies, seem to be the future : they are the sectors in which innovation, jobs, commercial opportunities and environmental gain all seem to be clustered; and, given appropriate investment in low-impact transmission infrastructure, they would seem to offer much more appropriate and relevant opportunities for expanded generating capacity in Suffolk and off the county's coastline. To push for or promote further nuclear power development would, from this perspective, certainly have an unneccessary, costly and potentially damaging impact on East Suffolk - whilst also introducing very real risks. A push in this direction, instead of and therefore at the expense of equivalent investment in renewables and associated 21st century grid infrastructure can therefore be viewed as a very real negative opportunity cost for the area : - on the basis that the Planning Inspectorate could instead issue a policy statement that favoured renewables for the area. Note : National Security I include this as an aside, but it seems bizarre that Sizewell C is being proposed in its present form, whilst central government is rapdily stripping out Chinese commercial interests from the UK telecom 5G network on issues of national security. Regardless of the merits or veracity of claims one way or another, there seems a huge inconsistency or contradiction in not applying the same rules to the UK telecoms 5G network and the UK's nuclear power generating capacity. Yours sincerely, Jason Gathorne-Hardy Copy retained. 30th Sept 2020.