RESPONSE TO EDF’S STAGE 2 CONSULTATION ON SIZEWELL C BY THEBERTON AND EASTBRIDGE ACTION GROUP ON SIZEWELL
Leiston Abbey on B1122, near Theberton
January 31, 2017
St Peters Church Theberton, on B1122
Cows grazing on marsh in Eastbridge
The Eel’s Foot Inn, Eastbridge
On the path to Minsmere Sluice
The beach at Minsmere Sluice
1 INTRODUCTION This response to EDF’s Stage 2 Consultation on Sizewell C [SZC] is on behalf of Theberton and Eastbridge Action Group on Sizewell [TEAGS]. This parish will be in the front line of the SZC construction for 10, 12 or more years and has wide-ranging concerns about EDF’s current proposals. Our community group, formed at Stage 1, has the full and formal support of the Theberton and Eastbridge Parish Council and campaigns to minimise the impact of the SZC build on local communities, on our local environment and on our many visitors and, where possible, to seek potential benefits. TEAGS is not campaigning against the new power station, and welcomes the benefits it could bring. We, and the local residents we represent, are concerned that some of the construction proposals will place an intolerable burden on this and neighbouring small rural parishes, on the thriving tourist industry in this special area, and on the unique environment in which we live. It is increasingly clear that some of the impacts, and indeed some of the challenges that EDF face given the awkward configuration of the site, will be magnified simply by the sheer scale of the proposed development – not one but two nuclear reactors, and the associated workforce, groundworks and transport. Is there merit in a review of the size of the development, and the benefits that could be achieved by a reduction in scale? With or without such a review we believe that, given a more imaginative approach on key issues, EDF could do much more to protect the very special nature of this area, the wildlife, tourism, and our quality of life. We wish to highlight that the consultation process so far has been extremely frustrating, falling far short of genuine dialogue. Proposals put forward by EDF at Stage 2 show no sign of any shift towards genuinely responding to the concerns of this and neighbouring parishes expressed at, and since, Stage 1. Despite much talk, residents feel ignored. In the case of the campus location, for example, despite strong local opposition expressed at Stage 1 and since, EDF has simply firmed up its original site preference. In addition, the surprise addition of borrow pits and spoil heaps on the edge of Eastbridge simply exacerbate the impacts. Our response below will address not only the specific questions in EDF’s Questionnaire, but also some of the wider issues of concern relating to people, the environment and the economy. References to tables etc apply to the Main Consultation Document, unless stated otherwise.
Q1 WHAT ARE YOUR OVERALL VIEWS? We are concerned that the proposals pay insufficient regard to the special environment, and have failed to react to concerns expressed at Stage 1. The diversity of our coastal habitats and their importance for wildlife are recognised by local, national and international designations that protect this area – including Ramsar, Special Protection Area (SPA) and Special Area of Conservation (SAC), Area of Outstanding Natural Beauty, Heritage Coast, Minsmere and Walberswick Site of Special Scientific Interest (SSSI) and Sizewell Marshes SSSI. (See also Appendix 2.) The SZC build will inevitably impact the sensitive and fragile area, but as we will set out, some aspects of EDF’s proposals could be changed to genuinely minimise, rather than exacerbate, the impacts and demonstrate the developer’s aim to ‘be a good neighbour’. We are frustrated that, despite many meetings with EDF since Stage 1, the proposals at Stage 2 show little or no evidence that the developer has so far given our suggestions ‘proper consideration’ as required by PINS. This community will be in the front line of the construction chaos, and also given the popularity of this wildlife-rich area with visitors, sees little commitment from EDF to genuinely minimise the impacts. The word ‘temporary’ relating to construction is misleading, as the 10, 12 or more years of the build threatens to damage the particular characteristics of this area for much longer, and we also question whether tourism (the second biggest contributor to our economy, worth over £200m per annum based directly on the natural environment of the AONB) will recover. The suggestion by EDF that this area of Suffolk has the same proportion of tourism income as the average for the UK, ignores the fact that in the Suffolk Coast and Heaths area, the proportion is much higher than the UK average, so the comparison is flawed and misleading. Our main concerns are:
! A new ‘town’ for up to 2,400 workers, on farmland next to Eastbridge, next to an AONB and close to RSPB’s Minsmere Reserve, and completely out of scale with the local parish population of barely 270 people. ! The proposal to use the B1122, a narrow country road not fit for purpose to be used for almost all Sizewell transport, including up to 900 HGV movements per day, and as the emergency and evacuation route ! The impact of construction on the rich variety of wildlife habitats, and the fragile coastline ! The impact on thousands of visitors faced with 10 or 12 years of traffic congestion, noise, vibration and air pollution, and blots on the landscape
Given the low baseline currently enjoyed locally in terms of traffic, noise, light and air pollution, the impact of a development of this scale will be felt far more than in a more urban setting. More effort must be made by the developer to respect and protect the qualities that people and wildlife seek here. Q2 MAIN DEVELOPMENT SITE: ENVIRONMENT We believe that the impact for the Minsmere coastal frontage, the inland drains, ground water systems and the functioning of the Minsmere sluice are of major concern, particularly during the construction phase but also during the many years that the station will be in place. We also believe that the environmental impacts described below will inevitably but unnecessarily be exacerbated by EDF’s ‘preferred’ location for the worker accommodation campus, the equivalent of building a small town (with all the necessary services) in a Special Landscape Area that in any other circumstances would not be contemplated. The cumulative impact of SZC development on the Minsmere Levels (part of the Minsmere and Walberswick Marshes SSSI) and Sizewell Marshes SSSI must be set out well in advance of the Stage 3 consultation, with the evidence underpinning these judgements properly documented. A major weakness of the Stage 2 consultation document is that nowhere is the cumulative impact of all the processes brought together so a proper evaluation can be made and informed responses given. See Appendix 2 for a sample visual. The absence of an index and minimal internal cross-reference make it difficult to access information. Given the sensitivity of the coastline both inland and seaward, we have been unimpressed at the paucity of detail regarding the possible, or probable, environmental impact. General statements such as ‘this would be subject to appropriate monitoring and contingency arrangements’ or ‘there is a potential for an effect on surface water flows which will need to be mitigated through detailed design’ are not helpful at this stage. Ash Wood is important for bats, as is the whole area. The development will have a massive impact on the local bat population. This will need new compensation habitat to reduce this impact. What is planned in this regard? The coast and the shoreline Changes to the off-shore sand banks and sediment transfer operates on both very long time frames of decades to centuries but strong tides and storm surges can also have dramatic effects over much shorter time frames, from days to months. For example, over the last 250 years or so, the Dunwich and Sizewell Banks have gone from being a feature with two maxima ~5 metres below sea level with a ‘gap’ some 8-10 metres 4
below sea level, to becoming a long tear drop-shaped bank with its maximum off Sizewell Gap and the minimum off Dunwich. In the last century this has started to reverse with clear maxima off Dunwich and Sizewell, but with the entire bank moving slightly closer to shore. The effects of these changes with a minimum appearing once again between the Minsmere Sluice and the Sizewell Gap, combined with the effects from global warming of rising seas and more frequent storm surges, will be very hard to predict over the full lifetime of the three power stations that will be on the raised platform at Sizewell. The Stage 2 Document claims minimal to no impact on the Minsmere coastal frontage, maintaining that any changes to this very dynamic coastline will be down to natural processes rather than the development. Whilst this may be true for the existing 4-5m sacrificial dune above the shingle beach, once this is breached, the new site protection features could considerably accelerate the natural embayment processes to the north of the site. No evaluation seems to have been made regarding this eventuality. The species-rich grassland along the length of the Sizewell C frontage will be destroyed. What are the plans to mitigate and compensate for this impact? Ground water, potable water and development site drainage Six hectares of Sizewell Marshes SSSI will be lost forever to the 55-hectare SZC station platform development and its access road. The Aldhurst Site Habitat Creation site, whilst welcome, cannot in any way be considered adequate mitigation for the loss of 6 hectares of SSSI at Sizewell. Appropriate mitigation must be provided for this loss and for additional damage and SSSI loss that will be caused during works to establish the SZC platform, creating a bridge across the SSSI and moving the Sizewell Drain. The construction development area will consist of 91 hectares of permeable, semi-permeable and hard standing. Water Management Zones (WMZs) will be used to divert and hold rainwater â€˜run-offâ€™ from the site. There is great potential for water in the WMZs to be polluted from development site workings. It is essential that water reaching the surrounding SSSI is treated in an appropriate Waste Water Treatment Plant (WWTP) and free from any site pollution. It is intended to pump both treated foul water from the accommodation site and other on-site facilities along with any 'excess run-off', collected in WMZs, from the main construction site into the sea through a temporary discharge facility which will terminate at the same distance as the 'fish return' (FR) outlet ~300 metres from the shoreline. The WWTP, temporary discharge and FR facilities will not be available for some time after development starts. No
indication is given about how water from the WMZs will be managed and treated prior to the WWTP and FR being available. We believe it is essential that properly researched baseline water level maps for both the Sizewell Marshes SSSI and the Minsmere Levels south of the Minsmere New Cut are produced. These need to show annual variations throughout the year based on at least 5 years of historic data and have comprehensive flow rates through the corridor where the Sizewell Marshes drains into the Minsmere Levels to the north of the proposed site for the SSSI crossing bridges/causeway. A baseline water level map is also needed for the area stretching west to east from the entrance at the B1122 to the SSSI crossing and north to south from the borrow pits to the green line rail corridor bordering the Sizewell Marshes, which clearly presents the range of scenarios that the development site could be faced with until such time as the development site is fully restored. Data must continue to be collected during the development, into the operational and later to the decommissioning stages of SZC, which can then be compared with the predictions to ascertain whether SZC has impacted the expected behaviour of the landscape and trigger mitigation by EDF. On the basis of these models and the potential disturbance relative to the baseline, EDF should also be explicit about its capability to mitigate should the actual changes deviate significantly from the baseline. There is no mention in the consultation document regarding supply and usage of potable water or other abstracted water for use during the construction or onwards into operation of the site. It has been estimated that the accommodation site alone will require 250 m3 per day and no estimate or indication of the additional requirement for construction activities such as the concrete batching plant are given. In production the two power stations will need about 1,600 m3 per day, although why this cannot be reduced in what should be closed loop cooling circuits is a surprise and a disappointment given the technologies available today for recycling water. The only open loop is that of seawater intake and output. Suffolk Coastal District Council has recently approved a significant set of new housing developments in Leiston, which will put added pressure on the potable water supply in the area. To have a significant short and long term addition to requirements for potable water from the local supply has to be demonstrated as both available and not detrimental to the overall water supply situation as clearly stated in EN1 5.15.3. This is a significant omission in the Stage 2 Document provided by EDF regarding water requirements through both the development and operational phases. This is a clear and 6
regrettable omission from both Stage 1 and Stage 2 consultations and needs to be addressed, considering this area is known as one of the driest areas in the UK. A full breakdown of water requirements for all stages of construction and operation over time must be provided at Stage 3 consultation, along with proportions that will come from direct water abstraction licenses, together with locations, and from mains water supplied by Essex and Suffolk Water. Q3 MAIN DEVELOPMENT SITE: NEW ACCESS ROAD The two bridge designs will offer least disturbance to the natural hydrology and Option 3 offers the least disturbance overall and is preferred. Options 1, 2 and 4 are inappropriate. Any causeway crossing the ‘neck’ of the Sizewell Marshes and Minsmere SSSI sites will compress the underlying material and effectively block the natural hydrological flow between these two areas and is additional loss of SSSI to the 6 hectares already taken by the main SZC platform. Bridges would also allow the early restoration of the access from Kenton Hills to Sizewell and Minsmere beach frontage, whereas causeways would close this access for the estimated 12year term of the development. Comments in Q2 above about baseline water level maps, modelling and onward monitoring are also applicable here as the access road choice and implementation could radically affect the hydrology of the Sizewell Marsh to Minsmere Levels drainage. Q4 MAIN DEVELOPMENT SITE: MANAGING CONSTRUCTION MATERIALS We find the borrow pits and spoil heaps to be wholly unacceptable as a part of this development. Construction materials should be sourced from existing sand and gravel resources and brought to site by rail or sea. Spoil should be removed from the site by rail or sea to a location that requires such materials, such as RSPB Wallasea Island. All three options are therefore inappropriate, with Option 3 being the ‘least worst’. If despite this borrow pits are introduced on to the site, we would expect to see robust evidence from EDF to show that potential alternatives had been fully investigated, and why they had been found to be impractical. As the borrow pits penetrate the secondary aquifer, they would need to be pumped out regularly during their open lifetime. One WMZ is sited to the north of the borrow pits but without any potential for intervention to manage polluted water. Natural drainage and water flow is to the north and thus poses a significant pollution risk to the Minsmere Levels SSSI.
There is significant potential for the borrow pit back-fill materials to introduce pollutants to the secondary aquifer and consequently the local waterways that form part of RSPB Minsmere and Minsmere Levels SSSI in the decades after the pits are filled and closed. The borrow pits are very close to the marsh harrier fields being developed and, as a consequence, noise and light pollution from the development are likely to disturb the feeding and breeding patterns for this protected species and other nesting species in the Minsmere Reserve. The locations of Fields 1 to 3 are too close to Eastbridge and Minsmere and the prospect of a crossing of the Eastbridge road from Field 1 unconscionable. The hedging along the Eastbridge Road is an excellent example of old hedging with larger oak trees, and any damage to such an environment must be avoided. Likewise Field 2 moves the site northern boundary closer to Eastbridge and Minsmere. It also completes the surrounding of The Round House and must be rejected. We stress that no borrow pits should be allowed to be created at the development site, so all options are inappropriate, with Fields 3 and 4 representing the least worst. If any fields are used, groundwater seepage from the pits must be monitored once they are back-filled to ensure no pollution is caused by leachate from the buried materials. Peat from the Sizewell Marshes is extremely acidic and should be disposed of at a site where such materials are already present and where such material would find a natural home. Plans for mitigation, should any pollution be detected, need to be specified in any future consultation. Fifteen hectares of spoil heaps and extracted sand and gravel resources are proposed. These heaps are to be between 20 and 35 metres high at their maximum and the heaps will be on site for up to 8 years in total. The heaps will be visible for most of the development time from Eastbridge, Minsmere and Dunwich Heath and most of the Public Rights of Way that crisscross the area to the north. With prevailing winds from the southwest, the natural travel for dust and sand pollution will be directly across Minsmere Levels and on into Minsmere Bird Reserve and onwards to National Trust Dunwich Heath property, threatening wildlife on the Minsmere Levels and Reserve. There are no proposals as to how sand and dust will be contained and prevented from leaving the site or how potential leachate pollution from spoil heap run-off will be managed on site.
Q5 ACCOMMODATION: OVERALL STRATEGY We do not understand EDF’s refusal to properly consider and report on alternative campus locations, perhaps multiple sites, in urban settings with suitable infrastructure in place (as is the case for Hinkley Point C). EDF insists that a single onsite campus is more ‘efficient’ – for the developer, perhaps, but not for residents or tourists – and that contractors ‘don’t want’ split sites, an observation that demeans our wishes and is insulting to the local community. We also have concerns about the worker take-up of private rented and other accommodation, thereby affecting availability for tourists. We are not equipped to comment on the estimated split between home-based and other workers, but we note that more than a third might be home-based with a commute of up to 90 minutes, yet EDF resists suggestions to house 2,400 workers in towns (rather than beside a hamlet beside AONB land), citing travel time and additional vehicles on the road. Ipswich and Lowestoft, for example, surely possible alternative accommodation campus sites, are approximately 40 minutes from site, not dissimilar to the situation at Bridgwater in Somerset. Suitable organised transport would limit the number of private cars, and would remove the pressure of an on-site campus on this environment and our rural parish (see also Q6). The onsite campus would have car parking for 1500 worker vehicles and 500 campus staff vehicles (the latter using the construction site car park), which completely undermines the claim that a single on-site campus reduces road traffic, at least at our community level. Q6 CAMPUS LAYOUT The location for a single on-site campus is unacceptable. None of the layout options are appropriate or acceptable. The campus would blight the landscape, affect visitors’ enjoyment and damage the health and wellbeing of residents. If, despite fierce and well-reasoned opposition from TEAGS and other bodies, EDF still refuses to react responsibly to this consultation and fails to change its Stage 2 proposals for a worker campus, then Option 2(ii) would be, whilst still wholly unacceptable, the least worst option. The scale and location of the single on-site campus is a travesty of common sense, and would never even be considered under normal planning rules. EDF intends to build a new ‘town’ for 2,400 workers - including accommodation blocks between 3 and 5 storeys high, car parks, and restaurant and leisure facilities. The location is manifestly unsuitable for such a build. It would sit on agricultural land, part of the Special Protection Area, bordering the AONB, very close to RSPB Minsmere and 500 metres from Eastbridge, a hamlet of 70+ people living in village houses. EDF defends the location saying it is outside the AONB, but the strict boundary is meaningless in amenity terms. This is a deeply rural area, recognized as a Special Landscape Area, with no street lighting, enjoying dark night skies, clean air and a very low base line of noise. Such 9
qualities are special and rare, and must be protected, not needlessly destroyed. Modern lighting techniques, sound-insulated accommodation blocks and soil mounds would not solve the issues. See also Darsham Parish Council Response regarding dark night skies. Table 7.8 cites some of the issues raised at Stage 1 about EDF’s Preferred site location and alternatives. In the light of these it is difficult to understand how EDF can conclude that ‘on balance’ (para 7.6.19) its original preferred option is preferable. The campus will unnecessarily exacerbate the already considerable environmental impacts of the build, and place a disproportionate burden on Leiston, Eastbridge and Theberton. Viable farmland would be lost for the period of construction (which could necessitate compulsory purchase), and thus the possible loss of livelihood for those who currently grow crops and rear livestock. The high-rise accommodation blocks, and spoil heaps up to 35m high would not sit well in this low-lying landscape, with an average elevation of 16 m.1 Note too that the campus, spoil heap and borrow pits, with associated noise, light and air pollution, would sit beside a hugely popular footpath – Minsmere Sluice FP, running over meadow and marsh from Eastbridge to the coast and once quoted in The Times as one of the top 10 walks in the country. Longer term, there are, we believe, grounds for concern that after a decade or more of construction mess, an unwelcome ‘legacy’ might be the perception that the area is now a potential brownfield site, thus encouraging development ‘creep’. Traffic would increase significantly on the B1122, with workers using their cars at the start and end of their shift cycles and for non-work trips. Workers on shift would also be bussed to their place of work within the site, adding to the air pollution and noise. It is disappointing that no details of anticipated car use by campus workers and campus staff has been provided by EDF. From data provided, we estimate that the campus will add around 40 per cent to current (2015) traffic flow on the B1122 at the proposed entrance to the construction site. (Construction traffic, visitors and locally-based workers would add over 50 per cent to current traffic flow at peak construction. Hence traffic would almost double over current (2015) levels on the B1122 at the construction site entrance.) The health and wellbeing of local residents will be affected by noise, air and light pollution, a serious increase in local traffic, and the potential for anti-social behavior – a major concern that is outlined in more detail under Q13. There are concerns too about security. Depending on the ultimate layout option, the Eastbridge Road would be diverted to a new route. Tourists – many of whom approach Minsmere via the Eastbridge Road – will be deterred. The local pub, The Eel’s Foot, currently so popular with locals and walkers, will suffer loss of income. We call on EDF to disperse the accommodation in one or more urban settings, that has 1 2
Source: Natural England (2010) Considerate Constructors Scheme survey in May 2016
existing infrastructure to cope with the massive influx of workers, and which could benefit from the investment. At Hinkley, in Somerset, EDF will build two campuses, on brownfield sites in Bridgwater (population 40,000) some 10 miles from the build, and a small campus right next to the build. Another company, NUGEN, planning to build a nuclear power station in Cumbria has proposed locating workers at 3 sites on the edge of villages 2-7 miles from the build. NUGEN is inviting comments on legacy options in its consultation questionnaire and is looking at how best to integrate workers into the local communities. Why can this approach not be adopted in Suffolk? We are told that the proposed arrangement is â€˜more efficientâ€™ for the developer and contractors, but that is little comfort for local people. In Suffolk, given an urban location and appropriate design, the accommodation could ultimately offer a significant legacy of affordable housing, much needed in the wider area. In addition, one suggestion would be to use the proposed caravan site, on the edge of Leiston, for at least part of the built campus to house some of the workers, and the accommodation blocks could longterm become a permanent facility for EDF for outage workers. It would not be difficult to site the caravans elsewhere. Given the size of the caravan plot, it might also be possible to build a small training unit where local apprentices could prepare for work at SZC, thus leaving the area with another positive legacy. It would also help to overcome the current transport and cost issues for local young people seeking specialist training further afield. See also our response to Q8. Q7 TRANSPORT: OVERALL STRATEGY We endorse the use of rail and sea transport, park and ride facilities and the postal consolidation facility, with reservations as detailed in our responses to Questions 8, 9 and 10, as part of the strategy to reduce the volume of freight that would be delivered by road. We oppose the proposal for a single-site workersâ€™ campus next to Eastbridge, as detailed in our response to Questions 5 and 6. We are concerned that EDF proposes that not only all HGV traffic but also all bus traffic will use the B1122, thereby maximising traffic impact on residents living on or close to this rural road. However we recognise that other rural roads are also not fit for the proposed traffic. We believe there is a strong case for a relief road from the A12 south of Saxmundham direct to the SZC site, which would benefit EDF and this area. See Appendix 3 for a possible route. We regret the lack of data on what materials, and quantities thereof, will be carried by road, rail and sea, making it difficult to properly assess the overall transport strategy. We recognise that EDF has tried to minimise the impact of SZC road traffic across the area as a whole but, in doing so, has maximised the impact on the villages of Theberton and Eastbridge, as well as Middleton Moor and Yoxford. This places an unreasonable burden on these small rural parishes and is hence unacceptable. Much more must be done to minimise the impact on these villages as far as practicable. 11
The road traffic data presented in the Consultation Document is based on 60 per cent of materials being transported by rail and/or sea transport. We would like to see some indications of the additional road traffic that would be generated if the assumed use of rail or sea transport proved not to be possible, for example if a maximum of only two trains per day was possible or the Beach Landing Facility or jetty could not be built due to possible irreparable damage to the coast. Traffic flow data does not appear to take into account the additional traffic caused by emergency evacuations or outages for SZB. • Traffic flow data is also far from complete. For example, it does not include: • traffic in and out of the main construction site entrance • traffic in and out of the on-site campus (and for option 2(ii) for the campus layout, the increase in traffic between the campus and off-site sports facilities • SZC peak construction traffic flows on Busiest Day (only HGV and bus traffic provided for Busiest Day) • SZC peak construction traffic flows on Busiest Hour (or Busiest Hours if peak flows for HGV, bus, cars or vans are likely to occur at different hours or different days) • increased traffic during local events when serious congestion can already occur, for example Latitude festival, Bank holiday tourist traffic and Aldeburgh Carnival. The traffic volumes estimated for SZC peak construction and resulting road congestion on the B1122 will have a significant detrimental effect on the important tourist industry, deterring visitors not only during construction but also, in ‘breaking the habit’ of visiting for some years afterwards. We do not accept that the B1122 can carry the traffic that EDF Energy wants without unacceptable increases in accidents, pollution, noise, vibration and congestion. In addition, cracking can be seen in many places along the B1122 between Yoxford and Lovers’ Lane, Leiston. We believe these cracks follow the join of the original road with sections of extra width added for the construction of Sizewell B. It follows that substantial repair and reconstruction will be needed before construction traffic can start, as well as during the 12-year construction period, which will exacerbate congestion still further for extended periods of time. Given the significant cost of such work, we argue that surveys of the state of the B1122 and cost estimates for its repair and reconstruction should be completed well in advance of Stage 3 consultation, so that viable alternatives such as the D2 relief road can still be fully considered. Furthermore, EDF has not yet assessed peak hour traffic rates and composition particularly at likely congestion points beyond the B1122, for example the A12/A1120 junction, A12/B1119 junction, B1119/B1121 junction, B1119 outside Waitrose/Tescos, B1119/B1122 junction, and B1125/A12.
Once EDF has updated its traffic estimates and taken into account the costs of maintaining and upgrading the B1122, additional travel times and fuel for HGVs and buses travelling via Yoxford and B1122, additional congestion, accidents, noise, vibration, air pollution and greenhouse gases, it should find that building a relief road along the lines of the D2 proposed for SZB is more cost-efficient than staying exclusively with the not fit-for-purpose B1122. We fully endorse the additional points raised by the B1222 Action Group in its responses to the Stage 2 Consultation Questionnaire in relation to the B1122. Q8 TRANSPORT RAIL Rail could play a vital role in managing the transport of materials and reducing the HGV movements. EDF is aiming to transport 60 per cent of materials by sea and/or rail and but it is not clear on whether or how it can achieve this. We would like to see EDF address how maximum use of both sea and rail can be achieved. TEAGS would select Option 1 as appropriate, and reject Option 2 as inappropriate. Subject to clarification on data, Option 1 Green route would be the most appropriate option, provided it would cause no damage or inconvenience to Leiston Abbey and the Pro Corda music school. However, it would add to traffic disruption close to the construction site – we question how EDF would manage this. Use of this rail route would release a large part of the alternative site east of Eastlands Industrial Estate, which could then be used for campus accommodation, close to the amenities of Leiston, including the current Sizewell Sports and Social Club. We would welcome a move by EDF to positively promote and facilitate more rail transport for workers. This could include the provision of double-tracking between Saxmundham and Woodbridge. This provision would also become a legacy for residents and visitors to the area. Q9 TRANSPORT SEA A guiding principle of the Sizewell C development and operation should be to not accelerate any natural coastal process. We have grave concerns about the impact of features such as the Beach Landing Facility on this fragile coast. Option 3 is therefore inappropriate. TEAGS cannot comment on Options 1 and 2 (so ‘don’t know’) as selection would depend on rail strategy for the movement of bulk materials (sand and gravel for construction, ‘unsuitable’ material from site). 13
Changes underway to the off-shore Sizewell and Dunwich banks could allow more destructive waves to find their way to the northern end of the Sizewell C platform (see previous comments in coast and Shoreline section). On the Suffolk coast, it is well understood that hard points significantly advance the embayment process to the north of such structures. Local examples include Minsmere Sluice outfall and Walberswick/Southwold harbour entrance on the Blyth estuary. Proposals for the Beach Landing Facility (BLF), for use during development and as a permanent facility, coupled with site armouring extending right to the toe of the sacrificial dune, and the possibility of an 800-metre jetty, present hard points much closer to the sea than those at Sizewell A or B. At the north of the site, the sacrificial dune is in far worse condition than that to the south. As the BLF extends right out to the sacrificial dune and has piles driven into the shore beyond the dune, the potential for this structure and the northern perimeter of SZC platform to cause accelerated embayment to the north, allowing Minsmere Levels south of Minsmere New Cut, part of the Minsmere and Walberswick Heaths and Marshes SSSI, to become saline much earlier, is a very real concern. There is no mention of this possibility or of any efforts to assess the possibility of this occurring. Mitigation of such an outcome would be very difficult or impossible and the potential damage to the habitats on Minsmere Levels SSSI catastrophic. The 800-metre jetty, either the narrow or wide version, will be in place for most of the 12 or so years of the development phase. The likelihood of erosion resulting from the slowing of sediment movement is acknowledged, but no information is given as to what â€˜the appropriate contingency arrangementâ€™ might be. Little is said about the impact of dredging that may be required to keep the jetty operational. No reference is made to the effect the jetty may have on navigation, recreational sailing or the Walberswick, Dunwich, Aldeburgh and Sizewell fishing boats. No information is provided as to how the jetty and piles are to be removed at the end of their use. The 1,000 piles cannot be left to become a permanent legacy in the marine environment, influencing sediment movement for decades to come. EDF must specify how the piles will be fully removed or, if they are to be cut below the water line, provide clear evidence and mitigation for the longterm effects of any such strategy.
Q10 TRANSPORT: PARK AND RIDE We support the principle of using Park and Ride facilities where necessary to reduce the number of workers’ cars on the roads, subject to appropriate siting and layout and subject to the better informed views of the parishes directly affected. TEAGS would require more detail to make an informed comment on both P and R sites, so both are at this stage ‘don’t know’. It must be said that such provision, like so much of the development, feels out of scale with the typical characteristics of this area. We note the specific concerns of Darsham Parish Council, concerns raised at Stage 1 but we understand not addressed at Stage 2. We also note their request for a small car park, as a legacy, though clearly the scale of a P and R would not meet this request appropriately. As indicated elsewhere, we consider that much more work is required to look at better options for SZC traffic generally, and the workers’ campus location in particular, that may require further consideration of the need for and/or location of these two P and R sites. Q11 TRANSPORT: ROAD IMPROVEMENTS - A12 We believe EDF’s ‘road improvement’ proposals on the A12 – at best a 2-village bypass round Farnham and Stratford St Andrew – fall far short of appropriate mitigation and must go much further to address the massive increase in traffic that the SZC build will bring to Suffolk. All options are therefore inappropriate, although if EDF contributes in some way to the 4village bypass (see below), then Option 4 would be appropriate. There has long been a case for a 4-village bypass on the A12 around Farnham, and as part of EDF’s package we consider the developer should be helping to support SCC/SCDC in this. More importantly, EDF should build a relief road to Sizewell from the A12 south of Saxmundham, along the lines of the D2 proposed for SZB (see our response to Question 7). Q12 TRANSPORT: ROAD IMPROVEMENTS - YOXFORD/B1122 Neither the roundabout nor the traffic light options will be capable of handling the planned traffic onto the B1122. The Stage 2 document takes no account of the effect on, and the traffic access to and from the A12/A1120, which is a serious omission. Both options are inappropriate. There is insufficient data and modelling to allow us to select either. In any case, as highlighted elsewhere in this report and by others, the B1122 is manifestly unsuitable. The fact that some of the changes to the B1122 have been buried in this section is derisory and an insult to the residents alongside the B1122. 15
Minor changes to the B1122, such as speed limits, badly planned crossings and straightening small areas of bends amount to no real change and fail to address the real issue that the B1122 is totally unsuitable for the massive increase in construction and related traffic. The crossings proposed for Theberton show a poor understanding of the villagers’ needs. A key requirement is to reach the bus stop used by school buses, which is located opposite Doughty Wylie Crescent, where several younger families live. Both proposed crossings are at the other end of the village. Neither would be required if the relief road is built. It is not clear whether the crossings would have Belisha beacons, traffic lights or street lighting. In the event that the relief road is not built, EDF Energy should engage directly with Theberton Parish Council and its residents to see whether these are wanted. Without lights, the crossing proposed near St Peter’s Church is too close to the blind corner at the junction with Pretty Road, and could be very dangerous. The population along the B1122 includes retired and older people, and the residents of two retirement homes. Health impacts are especially important given this vulnerable group. EDF Energy has yet to research the noise, vibration and pollution levels that can be expected. Why has this not been conducted in the four years since Stage 1? The understanding of the cumulative damage to health from traffic through pollution and noise is growing all the time. We trust that EDF Energy’s research takes into account the very latest studies, including those on dementia, Parkinson’s Disease, heart attacks, hypertension etc. There are many properties along the B1122 that will suffer vibration damage. This is especially true of older (frequently listed) properties that have little or no foundations. How will EDF Energy mitigate this and compensate owners? We consider that the above points add to the case for EDF building a relief road as the alternative to using the B1122 as main route for SZC traffic. Q13 PEOPLE AND ECONOMY Of course, we welcome the benefits that the SZC build could bring to the area, including training and employment, especially for young people, and opportunities for the supply chain etc. However, in reality, for many residents there is little prospect of direct benefits. Critically, the cumulative negative impacts of the construction period on the local communities are woefully ignored in the Stage 2 documents. We question what support EDF will put in place for education and skill straining – para 5.3.8 highlights EDF’s strategy ‘to focus on the quality of roles secured by local people’, but there is no indication of when or how this will be achieved. Surely training facilities should be in progress now to prepare a skilled workforce drawn from local people? 16
We are concerned that local health services – GPs, nurses, hospitals - are already overstretched, and will not be able to cope with the potential demand from SZC workers. Patients at Leiston Surgery for example know the wait is long for an appointment, and the practice struggles to recruit sufficient GPs – a nationwide problem. Much more information is needed on what provisions EDF will make to cater for its workers. On-site nursing support would not be able to cope with more serious illness and injury. Appropriate facilities to look after a peak workforce of 5,600 must be in place before construction begins. So far there is no Health Impact Assessment. It is well known that noise pollution (the ‘modern plague’, according to World Health Organisation) is a real threat to health, causing heart disease, hypertension, hearing impairment, sleep disturbance, dementia. People living close to the site, let alone visitors, will be seriously affected. It is difficult to imagine effective mitigation, and so EDF must do much more to remove the causes of additional noise pollution in the first place, such as the amount of traffic on the B1122 and its preferred siting of the campus and borrow pits. Some decisions would seem to be made in the wrong order, if the local people are to be respected. Para 5.2.4 cites the need to assess ‘the impacts on individual communities, including but not limited to Leiston, Theberton and Eastbridge, once the full range of likely effects is known’. This quote recognises that this parish is in the hot seat, yet there is little, if anything, here to reassure residents. Figure 5.2 lists air quality, noise, transport and landscape among the topics that would inform a local Community Impact Report at Stage 3. Yet these are among the very topics that concern all those that live near the proposed campus site. The likely impacts of the campus on residents and visitors should be assessed before the site location is firmed up. Worker behaviour, even with a Code of Conduct, is inevitably a major concern, not without foundation. Local police support has already been reduced, and the police station at Leiston (the town closest to SZC and which suffered from poor worker behaviour at SZB construction) is no longer staffed. What, in practical and financial terms, will EDF do to ensure sufficient police and emergency provision, and effectively enforce the Code? What is meant by ‘appropriate resources’? And how much evidence has so far been gained about the effectiveness of the Code, from HPC, given that the build there is still at a relatively early stage (para 5.2.25)? A survey on alcohol and drugs in the UK construction industry2 revealed that 59 per cent of people working across the industry have concerns over the effects of drugs and alcohol on the industry, and 35 per cent have noticed their colleagues under the influence of drugs and alcohol. We struggle to believe that SZC workers will be markedly different. Many of the residents of this parish are retired, and unlikely to benefit economically from the build. Many are also elderly, and feel vulnerable, given the proximity of the campus and 2
Considerate Constructors Scheme survey in May 2016
the anticipated traffic on the B1122. Across the parish, and in the wider community, the stress over the proposed development and local impact is already a significant factor in people’s health and wellbeing, not helped by the time the process is taking. Another concern is the potential drop in value of property, exacerbated by the extended period of uncertainty. Q13 PEOPLE AND ECONOMY - TOURISM We believe the local tourism industry – currently worth more than £200m and supporting more than 3000 jobs - will be hit hard. EDF Stage 2 documents pay scant regard to the impacts on tourism: EDF is ‘working to identify the key reasons tourists come to the area’ and how SZC might affect ‘the attractiveness of the area for tourists’. It is already well known why people come to Suffolk. Suffolk’s Nature Strategy recognises the importance of peace, tranquillity and landscape and states that visitor experiences must ‘match and surpass expectations’. RSPB’s flagship reserve at Minsmere draws 120,000 visitors a year. The wild coastline, the dark night skies and mosaic of open heathland, woodland, marsh and farmland offer a rich variety of experiences. The deep quiet, the wildlife, lack of pollution, the visual amenity all draw visitors here, many of whom visit several times a year, and stay for several days. Ecotourism is on the rise. We believe tourism in and around this parish, to Minsmere and to the Heritage Coast, will be unnecessarily affected by EDF’s current plans for the siting of the campus, borrow pits and spoil heaps, and by its transport proposals. Local hotels, holiday lets, B&Bs and caravan parks may lose significant business for at least a decade as visitors are deterred by the construction impacts, and any accommodation take-up by SZC workers would most likley generate lower income levels. Visitor patterns, once shifted to other destinations, will be hard to recover – it has taken significant investment, time and effort to build up a thriving year-round tourist trade to this special coastal area, which would have to be undertaken all over again. Footpaths and bridleways crisscross this area and are widely used by locals and visitors alike. Noise, dust and visual impacts both to the north and south will deter tourism to Minsmere, Dunwich, Thorpeness and Aldeburgh. Public access through Sizewell Belts to the foreshore will be blocked completely during construction. We share others’ concerns that unsympathetic behaviour by construction workers in the countryside could damage special habitats and associated wildlife, and spoil visitors’ enjoyment. The massive increase in traffic, especially on the B1122, will deter visitors to the area. Congestion and delays will also affect specific cultural activities, such as the world-renowned annual Aldeburgh music festival at Snape, the Southwold literary festival etc. Interest could be affected by the perception (if not the reality of) lack of accommodation, general disturbance, a reduction of quality of life and severe traffic problems. 18
Q14 CONSULTATION PROCESS TEAGS has a number of concerns about the consultation process, including timing, woeful lack of information at Stage 2, and lack of transparency. There is little evidence that EDF genuinely appreciates the challenges this location presents and its responsibility to protect it. TEAGS was bitterly disappointed that yet again, this major consultation took place over Christmas and New Year, just as happened at Stage 1 (and to which we objected at the time). EDF has had four years to prepare the complex documents, for lay people a mountain to climb in just weeks at the best of times, let alone over the biggest festive time of year. Any extra time given hardly compensated. It is surely not a fair way to consult with those who will bear the brunt of the construction disruption from this major NSIP. We have actively sought to engage with EDF since Stage 1, and acknowledge that the developer has been willing to meet with us, but given the lack of any meaningful response to the issues we have raised over four years, our concerns appear to have fallen on deaf ears. We have also been frustrated by the lack of transparency from EDF and by the non-disclosure agreements that consultee organisations have been bound by. The process feels heavily weighted against local people. The Stage 2 Consultation Document, at more than 300 pages, is a weighty and complex tome. Yet it lacks a key ingredient – ie a clear indication, both visual and narrative, of the ‘connectivity’ of the various elements of the build in relation to each other, and in relation to the various land areas, which mostly enjoy local, national or international protection. Such presentations would have helped to demonstrate more clearly to respondents the cumulative impacts of the proposals, and the scale of the build. In general, the parts of the build are treated separately, and we are left to calculate the collective impact. There is no index, making it very difficult to navigate, and even challenged EDF staff at their touring exhibitions! Maps and diagrams in the print version are difficult, sometimes impossible to read where the colours are muddy, colour gradations too subtle, legends and annotation so small as to be illegible (even with a hand lens). As at Stage 1, labelling on maps is not always complete – eg Eastbridge, in the front line of the development and only a few hundred metres from the campus site, is not marked on the accommodation option maps! Again, we raised this issue at Stage 1. There is a frustrating and worrying lack of detailed information on many aspects, making informed responses difficult, sometimes impossible. All too often there is vague reference to further research to be done, and to minimising and mitigating impacts, with no clue as to the nature of those measures. We would urge EDF to provide far more information as it becomes available, for example on transport and the environment, on coastal impacts, on health and community impact assessments, and on tourism, rather than wait until Stage 3 or beyond, when once again we will have too little time to respond properly. 19
For Stage 3, we ask EDF to give respondents much more time to get to grips with the documents, time to seek others’ advice if necessary, and to avoid holiday times. Summary document and Questionnaire – Whilst we welcome EDF’s open invitation to add comments to each question, some of the options presented do not offer significant choices, they constrain respondents to do no more than fine-tune EDF’s plan . For example, on accommodation, the options relate to details of layout either side of the Eastbridge Road; we have lost alternative locations shown at Stage 1, and there are no new choices given. EDF has clung to its original preferred option. The CGI tool used by EDF in its touring exhibition could have been useful but felt more like a gimmick. By its nature it is difficult to make this a helpful tool for the general public, tending to be too reassuring as landscapes were not sufficiently realistic, eg a popular walk down to the sea in reality runs over open marsh and meadow but the CGI route was through deciduous woods. The spoil heap, at up to 35m, was shown as a low-lying neat lozenge, whereas in reality this will be an uneven, unstable mountain of loose rubble, at peak the equivalent of a 12-storey block. A 3D model of the site during construction, as well as once the build was complete and the site reinstated, would have been helpful. Maps showing the extent of specific environmentally protected areas (SPA, AONB etc) would have helped respondents to understand the potential impact of the development and gone a little way to convince them that EDF is aware of the very special characteristics of this area. We wonder what Natural England’s response to the proposals are, given that its remit is to ‘secure a healthy natural environment for people to enjoy, where wildlife is protected and England’s traditional landscapes are safeguarded for future generations.’ (See Natural England’s National Character Profile for Suffolk Coast and Heaths at www.gov.uk/naturalengland.)
CONCLUSION TEAGS is dismayed that EDF has apparently paid so little heed to the concerns of this and neighbouring parishes voiced at and since Stage 1. We welcome this further stage of consultation but fear the issues we raise may once again fall on deaf ears. We are encouraged by the robust responses being put forward by important environmental bodies such as RSPB, AONB and Suffolk Preservation Society, and by Suffolk Coastal District Council, Suffolk County Council, Parish Councils and others. We hope that, finally, EDF will pay due and proper attention to the results of this consultation and will react by amending their construction proposals. Only in this way can the developer show that this is a genuine consultation, that it respects the needs of the host communities – the people who will experience the worst impacts of the construction period for its commercial benefit – and respects the very special, highly protected but fragile environment in which the build will take place. Given the lack of detail and uncertainties on environmental/ecological impacts (highlighted in our response and by others) we question whether it is possible that there may be insurmountable problems that could prevent the build going ahead. Overall, despite its length, the Stage 2 Document offers insufficient detail on key aspects such as transport, environmental impact, community and health impacts, making it often difficult to make informed comment. There are frequent vague references to ‘appropriate mitigation’, to minimising the impacts, but with little detail given, such promises are not reassuring. The gaps, we are told, will be filled at Stage 3, yet in the meantime EDF’s plans will no doubt continue to be firmed up. It is hard to believe that EDF could be persuaded to make fundamental changes to its plans, after Stage 3. We therefore urge EDF to urgently explore ways to fully address the issues we raise in this report, and to keep this community fully informed of progress in this regard, as and when more information becomes available and before Stage 3. We recognise that this Stage 2 is an additional stage, and we have worked hard to respond in a thoughtful and useful way, but with little sign so far of EDF meeting its responsibilities to this community and given so little depth of content to work with, it has often felt a very frustrating process. Cc The Planning Inspectorate Dr Therese Coffey MP Cllr Colin Noble, Suffolk County Council Cllr Ray Herring, Suffolk Coastal District Council
BACKGROUND – Appendix 1 TEAGS and Theberton and Eastbridge Parish Council held a joint public meeting on January 7 to discuss the Stage 2 documents. More than 200 people attended, from this small parish (population 240) and neighbouring parishes. There was overwhelming agreement that the construction proposals by EDF as they stand would place an intolerable burden on residents, on the many tourists, and on the special environment, that could not be adequately mitigated without a fundamental rethink on issues such as the location of the campus, and the use of the B1122 for all SZC traffic. A sample of comments from the audience give an indication of the strength of local feeling. EDF must address these concerns and not ride roughshod over the communities that will be in the front line of the construction chaos. (Speaker from Yoxford) - I am concerned with traffic implications. EDF plan to have a roundabout at the B1122 junction with the A12 but have they considered the junction at the A1120? (Theberton) I am worried about the amount of traffic on the B1122. Residents can hardly get out of their drives, cannot cycle or walk any more, we are becoming prisoners in our own homes. The two proposed zebra crossings are in the wrong … Most village children live in Doughty Wylie Close therefore the crossing needs to be nearer to there. (Theberton) I am deeply concerned as there has been no environmental impact assessment for during the lifetime of the build and decommissioning. There is just ‘mitigation’ throughout the report. Greenpeace say [this country’s] air pollution limits have been breached, we have used up our entire quota in the first week of 2017. The environmental impact [of SZC] has just been swept aside. (Darsham) The focus [by local authorities] is on the four villages by-pass and support for it. This transfers traffic problems up to Yoxford. The answer is to try to make sure the relief road D2 is built - it will solve problems. (Middleton) We are chewing round the edges of the problem, the only way to mitigate is to say this area is not suitable for this construction. The infrastructure is not adequate. This is a peace and quiet area where you can bike and walk. People don’t come here for light and noise pollution and [900 HGVs] a day. People moved here for quality of life and this project threatens that. (Yoxford) - I am reminded of 1989 after Sizewell B, a lot of people round here, around 1,500 (?) signed cards against Sizewell C. A lot of people did not want another build because they knew what would happen. (Yoxford) - People living near busy roads have a significantly increased risk of dementia. The people living along the [B1122] route will be subject to health problems. There will be a 722% increase in traffic in Yoxford. This figure is tucked away but it will make the biggest difference to us. 22
(Theberton) Zebra crossings in the village also mean beacons and street lights either side. Do we want street lights in the village? Also, the 20-30metre spoil heaps. The prevailing wind will mean dust and sand is blown across Eastbridge and if there is heavy rain how will they keep it in place and ensure it is not washed down through the village? (Eastbridge) The accommodation is for 2,400 people.The equivalent of putting a town in a rural area with a nature reserve. It is inappropriate and 10 years is not temporary … Give this county a new opportunity of housing, leave a legacy for us. Spread the load around various towns and give back to the community for our use. (Theberton) I feel threatened by the campus which is dumped on an area which is an AONB and a SSSI. … Why should we have the joy of living here spoiled by them encroaching us? We should interrogate them about their evacuation procedures, also for the campus. There is no mention in the document for that. (Middleton) I am concerned as I ride horses across the B1122 and it is dangerous for horse riders and cyclists. What will be considered for the rat-runs all around the area? (Westleton) If there will be 2,400 workers on the campus then there will be a call on the doctors. There is a shortage of doctors in the country. EDF will probably have nurses but they cannot cope with medical emergencies. (Theberton) We struggle for hospital places and the three hospitals have been on red alert as there are no beds… will EDF increase the funding to cope? (Eastbridge) The accommodation campus will shut Eastbridge to tourism. The lanes cannot cope with the traffic. We rely on tourism and this development will have a massive adverse effect on Eastbridge. It will shut the Eels Foot Inn for tourism. (Yoxford) EDF are making no efforts to monitor their workers in Leiston. EDF feels that it is not their problem. Police services have been cut back.. The STD clinic in Leiston has been slimmed down. (Eastbridge)We need to fight for this special place... noise, dust, pollution - why would tourists come? (Halesworth) I am surprised there has been no mention about the spent fuel which will be stored indefinitely… This is not attractive to tourism or nature. (Middleton) Have they factored the SZB outages into the peak number of cars on the road during the construction of SZC? 23
Appendix 2 â€“ the environmental impact This board is one of a number produced by TEAGS for its touring exhibition held in a number of parishes during the consultation period. Note in particular here, the aerial view over Minsmere Reserve. The SZC site would be to the south of this area. It would have been most helpful if the Stage 2 Document had included a similar, annotated view over the development site and its environs, allowing respondents to understand the connectivity between the build and the protected areas.
Appendix 3 â€“ the case for a relief road This board, one of a number produced by TEAGS for its touring exhibition held in a number of parishes during the consultation period, shows a possible route (known as the D2) for a relief road from the A12 to the SZC site.