Advice to Jen Wilson
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- From
- Jen Wilson
- Date advice given
- 12 March 2020
- Enquiry type
Dear Sir/Madam I have read that EDF are imminently planning to submit their application for a DCO for the proposed Sizewell C. I feel it is necessary, despite four consultations, to voice my concern at the inadequacies of information that has been shared with the public. I am aware that planning rules for major infrastructure projects are that the consultation should be carried out in an open and transparent way to all consultees and should contain as much detail and information as possible. EDF’s Sizewell C four consultations have failed to do this. I personally have been left with many unanswered questions. 1. I have repeatedly expressed my concerns that the site is too small for the two proposed EPR reactors. After four consultations there is still no floor plan indicating where the buildings will be located on a map which includes visible grid lines, contour lines and road numbering. This means it is also impossible to fully understand where roads, rail lines, auxiliary buildings, borrow pits, stockpiles etc etc are located, how much land take is required and what environmental damage will be caused. The maps supplied in the consultation document are small and the key so tiny it is almost impossible to read. 2. I am particularly concerned on the impact on the AONB, Sizewell Marshes SSSI, RSPB Minsmere with its European and International designated habitats so have contacted all the environmental NGO’s and the Environment Agency to find out their opinions. All have told me that they have not had the necessary information from EDF to make an informed response. After four consultations EDF have not supplied Environmental Impact Assessments to the public. Is this because they are yet to do them or they have and are not being transparent, either way this is totally unacceptable. 3. At EDF stage three exhibition I asked how much mains water would be needed during construction and once Sizewell C was operational and the source of that water. Three out of the four EDF representatives I asked where unaware that Sizewell C would use mains water! The fourth took my email address and said he would let me know. To date I have heard nothing. East Anglia is one of the driest counties in the country. Sizewell C’s water consumption must not take priority over farms, businesses and residents. 4. The proposed permanent access road to Sizewell C will take up 12 hectares of Sizewell Marsh SSSI and will require a culvert over the SSSI and water courses. This is likely to cause pollutants to run off into the delicate water system. Throughout all the consultations many have asked for other options or alternative routes, none have been considered. 5. Sizewell was nominated as a potential site in 2008. I am aware that the siting criteria for new nuclear EN6 is out of date. The consultation for EN6 ended March 2018 the Environment Agency and the Office for Nuclear regulation have yet to submit their responses. I therefore do not understand how the Planning Inspectorate can consider EDF Sizewell C’s planning application as there is no valid siting criteria. This is particularly important as since Sizewell was originally nominated as a potential site the impacts of climate change are predicted to be far more severe. Please can you explain. 6. The site is on an eroding coast in flood zones 2 and 3 and will require radioactive waste to be stored 150 years on site (or maybe indefinitely as there is still no geological disposal facility in UK). Surely EDF should have provided information about sea level rise, storm surges and more extreme weather events for both coastal and fluvial flooding. When I asked about this I was told by an EDF representative that to protect the site EDF will just increase the height of the sea wall and that it is likely that the Sizewell site will become a nuclear island. My home is at risk of flooding and [redacted]. EDF have provided no information about how their hard sea defences will affect neighbouring properties, businesses and farms. Protecting the Sizewell site will result in damage to the extended coast yet there is no mention of how coastal erosion will be managed or paid for. If EDF Sizewell C’s hard sea defence results in surrounding properties being flooded, policy should be put in place that EDF must pay for damage caused, burden should not be on the taxpayer. 7. The Government has declared a Climate Emergency. EDF Sizewell C’s 10/12 year build will create a huge upfront carbon footprint and will need to operate for 60 years to become what is deemed low carbon. At a Sizewell C stakeholders meeting EDF claimed the carbon footprint of Sizewell C will be similar to that of Hinkley C 4gC02/kWh (even though IPCC claims nuclear is 12gC02/kWh) Where is the supporting documentation for this? How can Hinkley C and Sizewell C have the same carbon footprint? Hinkley has a marine led strategy Sizewell is most likely to be entirely road driven. EDF have been unable to state how much material is needed for construction of Sizewell C or where materials will come from, precise location of road and rail needed yet can say what the carbon footprint will be! EDF are claiming Sizewell C is needed to help generate low carbon electricity yet in the decade of its construction it will hinder UK climate goals. Who in government is responsible for checking the carbon footprint of major infrastructure projects and their impact on climate goals. EDF must provide supporting documentation that can be verified by an independent party. 8. Little is said about storage of the spent fuel for the EPR reactors. This fuel will be high burn up fuel. Where are the storage ponds and Dry fuel store sited? This is extremely important as radioactive waste will be on site for decades after the plant is operational and maybe indefinitely. French Govt owned EDF finances are in dire straits, how can UK Government be sure EDF will take responsibility for the waste which will need protecting possibly indefinitely, on an eroding coast at risk from flooding and sea level rise. Is there any documentation to say they can and will? EDF when asked have implied the waste is not an issue as a GDF will be available but as yet there is little supporting evidence that there ever will be. The Government has made a big deal about consulting communities regarding the siting of a geological disposal facility yet it is allowing EDF to foist radioactive waste on communities indefinitely without proper consultation. 9. Where is the new sewage works? How is the sewage to be managed and where is the discharge point? Also dewatering of the site where is the water going? 10. At the stage three consultation EDF realised four pylons are necessary, apparently to feed the National Grid these will scar the landscape in the AONB. The height and siting of these are still unknown. There are still so many unanswered questions. The Fish entrainment at the cooling water intakes still unknown. Social-economic case only mentions perceived gains but gives no assessments of the losses on health, tourism and other businesses or house values. Footpaths and bridleways particularly the Heritage Coast Path, soon to become the English Coast Path. The beach frontage the green line agreed for Sizewell B is not being adhered to. Etc etc. The fact that there is still so many unanswered questions and the total lack of supporting documentation highlights the Duty of Regard for the Suffolk Coast and Heaths AONB and the integrity of the Sizewell Marshes SSSI has not been taken into account. Consultees must have this information in order for them to arrive at an informed opinion. Crucial information like this must not be wrapped up in the Rochdale envelope at DCO stage. I feel EDF’s four stages of consultation show little detail or supporting evidence on that basis it renders the process inadequate and invalid. I hope this information will be taken into consideration when EDF submits it’s DCO application to PINS and for the reasons above I urge you to reject the application. Yours Sincerely J. Wilson
Advice given
Dear Ms Wilson, Thank you for your email expressing concerns about the adequacy of the developers consultation and consultation material. We note that you have sent your letter to the developer and the local authorities. The local authorities can consider your comments as part of their Adequacy of Consultation Representation submission to the Planning Inspectorate (on behalf of the Secretary of State) at the Application Stage of the process. The Planning Inspectorate will consider any adequacy of consultation representations received from the relevant local authorities when deciding whether or not to accept the application, as required under section 55(4)(b) of the Planning Act 2008 (as amended). It is therefore important to ensure the local authorities are informed of your concerns. Further information about Community Consultation can be found here: https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/General/General-Advice-00632-1-170702s47CommunityConsultationFAQ.pdf As you are aware the proposed application by EDF Energy is at the Pre-application stage of the Planning Act 2008 process. The Planning Inspectorate is unable to consider representations about the merits of any application until it is accepted for Examination. Further information about the process can be found in the link below to the National Infrastructure Planning website: https://infrastructure.planninginspectorate.gov.uk/application-process/the-process. Should the application be accepted the application and all the supporting documentation will be published on the project page of the National Infrastructure Planning website: https://infrastructure.planninginspectorate.gov.uk/projects/eastern/sizewell-c-new-nuclear-power-station/. The ‘Registration and Relevant Representation form’ will be made available here during the Pre-examination stage and all parties will have an opportunity to outline their views about the project. The appointed Examining Authority will then use these to carry out an initial assessment of principal issues. Further information about registering as an Interested Party can be found in the Planning Inspectorate’s ‘Advice Note 8.2: How to register to participate in an Examination’: https://infrastructure.planninginspectorate.gov.uk/legislation-and-advice/advice-notes. Please note that the Department for Business, Energy and Industrial Strategy (BEIS) have responsibility for reviewing and designating National Policy Statements, including EN-6. The link below provides the latest information about the designation of the new National Policy Statement for Energy for nuclear power generation (NPS EN-6): https://www.gov.uk/government/consultations/national-policy-statement-for-new-nuclear-above-1gw-post-2025-siting-criteria-and-process Please note that page 6 provides details of the timeline towards designating the new NPS. I hope you find the above information useful. Kind regards Liam Fedden