Representation by Suffolk County Council (Suffolk County Council)
- Date submitted
- 3 November 2022
- Submitted by
- Local authorities
Thank you for notifying Suffolk County Council that the above application has been accepted by the Planning Inspectorate for examination. I am responding on behalf of Suffolk County Council to your email and letter communication dated 20/09/2022 regarding the above. Where separate responses have been submitted by individual teams of the County Council they have been summarised in this letter. While as a neighbouring authority, Suffolk County Council is not directly involved, the authority wishes to remain an interested party as the scheme will have impacts on the residents and economy of Suffolk. SCC Highways: SCC welcomes investment in SRN which supports our position stated in the LTP https://www.suffolk.gov.uk/assets/Roads-and-transport/public-transport-and-transport-planning/2011-07-06-Suffolk-Local-Plan-Part-1-lr.pdf Our main concerns relate to the construction phase of the project: • There the potential for disruption of the SRN (A12) linking Suffolk to London and the South East during the construction period and short term impact on the economy, particularly the Port of Felixstowe which has been announced as a free port. https://www.freeporteast.com/ . SCC is aware that Highways England is considering using demand management as a mechanism to reduce vehicle trips on the A12 corridor during construction and would support such measures. • SCC would look for Highways England to continue with investment in the SRN, for example to deliver improvements to the A12/A14 Copdock Interchange during RIS3 as the proposed A12 Chelmsford to A120 Widening is likely to increase demand and traffic volumes on the A12 corridor between Ipswich and London. Of concern is the lack of investment to improve substandard junctions on the A12 between Colchester and Ipswich where local roads join the SRN. • The project appears to provide benefits to cyclists, walkers and equestrians but SCC defers to Essex County Council regarding whether the measures set out in the consultation documents assist in addressing the transport needs identified by the Government in the National Policy Statement for Nation Networks Table 1. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/387223/npsnn-web.pdf • Construction starting in 2023 lasting for 4 years will coincide with a number of Energy NSIPs in Suffolk. Most critically this will include the construction phase for SZC which is forecast to peak in 2028. A significant proportion of road movements in terms of freight and workers are expected to use the A12. SCC notes that the cumulative impact of the regional NSIPs is not scoped in to the assessment presented in DCO DOCUMENT TEMPLATE - PW INTEGRATED.docx (citizenspace.com) • A wider concern is the national and regional demand for materials and labour from now until the end of the decade created by the number of NSIPs proposed in the East of England, national schemes such as HS2 and regional growth in housing. These pose problems in terms of availability and cost which may have consequential impacts on local authorities undertaking their duties as local highway authorities. • SCC presumes that the road and structures will be designed to carry the Abnormal Invisible Loads to enable it to remain as a DfT preferred heavy load route HR82 from the M25 to Bramford substation, notwithstanding the governments water borne or rail transport preference in the NPS1. https://www.gov.uk/government/publications/preferred-routes-for-high-and-heavy-abnormal-load-movements https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/47854/1938-overarching-nps-for-energy-en1.pdf SCC Economic Development and Skills: Considerations raised by Economic Development that resonate with the LHA include, the presence of other largescale construction schemes. The construction period for the widening scheme is expected to be 2023 to 2027, during this time period we are expecting significant activity on a number of other NSIPs that will put pressure on available labour. SZC will be in its Civil construction phase and ScottishPower Renewables will also be undertaking its three-year onshore construction phase. These projects alone have the potential to draw in all available local civils construction labour leading to negative displacement effects in our local labour market. With the additional pressure of another local NSIP providing a draw on an already pressured labour market this could be further exasperated. This proposed scheme could also have a significant cumulative impact on the SZC transport modelling assumptions. If labour in the South of the county is expected to be drawn as employment at SZC and modelled as such if another scheme, such as this, is delivered it will significantly change these assumptions and we may see more labour being drawn from more North and/or West of the county. Economic Development does also offer more positive feedback, acknowledging that the scheme has the opportunity to provide legacy employment/opportunity for the region, creating a workforce and talent pools of people that can take up the opportunities that SZC and other projects present. Dependant on timing, this project can either support a lead into major projects or help with re-brokering of workers and companies as projects demobilise.