Representation by Suffolk County Council (Suffolk County Council)
- Date submitted
- 18 July 2023
- 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 07 June 2023 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 concerns regarding workforce movements are: ?Simultaneous NSIPs relying on the same pool of workers resulting in greater travel distances for workers than assumed due to a shortage of local labour. Our Business and skills colleagues may also have views on this. ?Recent NSIP applications have used set shift patterns to avoid workers travelling during network peak hours. However, with the multiple NSIPs using the same mitigation this may move the network peak to the times their works are travelling. Both can be explored through sensitivity testing. The site is located away from the western boundary of Suffolk so presume transport impacts will be limited. Whilst there may be some goods / products originating from Suffolk there should already be planning controls in place (eg quarries). Greatest concern is likely to be AIL movements. If compliant with NPS1 movements should be by water or rail wherever practical. The closest port is likely to be Ipswich. The Examiners attention should be drawn to the discussion of AIL movements during the Sunnica examination (and SPR, SZC) where we pressed for the applicant top prove that there was a feasible route for AILs to the site from an appropriate port. The Sunnica applicant presumed that the SRN can cope with such loads which is not necessarily true. Heavy or high loads may have to use the local road network to avoid restrictions on the SRN, for example deviating through Stowmarket to avoid the A14 Hillhouse Viaduct. Reliance of the ESDAL system is causing us problems, for example for an EA3 movement to Bramford the haulier has proposed 5 alternative routes without success due to weak structure on SCC’s network. Another applicant is trying to get 3 large loads to Eye. During the movement this requires closure of the A140, probably the busiest major road in terms of HGVs that is maintained by SCC. In addition, the routes, including structures, are improved where necessary by the applicant to allow construction but no safeguard is put in place to make these routes resilient in the longer term operational or decommissioning phases. SCC Skills: Environmental statement Volume 2 Chapter 11: We note that operational employment has been scoped out due to no/small uplift in existing employment opportunities (Table 1-3; Table 2-6), however there is expected to be a peak workforce of over 360 during construction of Phase 1. We would expect that impacts of construction employment, during both Phase 1 and Phase 2, to be examined further. Demand for local accommodation and public services during construction has been scoped out (Table 1-2; Table 2-6) due to a large local and regional labour market (Table 1-2). We would welcome further clarification on the basis of the assumptions made regarding locally available labour, as well as further details on number of home-based workers. We welcome that the Applicant will conduct monitoring to maximise benefits for local residents relating to employment, supply chain contracts as well as apprenticeships and training opportunities (4.2.66). However, the Applicant specifies that this relates only to Cambridgeshire residents. We would expect areas of Suffolk to be included within this monitoring due to several communities being located within reasonable commuting distance to the Proposed Development, such as Newmarket. We would also expect that there be a proactive plan in place to maximise these benefits, including relating to equality, diversity and inclusion, alongside monitoring.