Submission on Scoping Opinion for SZB Relocation
All suggestions in this Scoping Opinion are irrelevant and premature insofar as until as such time as EDF has achieved its Planning Consent for SZC via PINs and the Secretary of State, it should not attempt to by-pass the Planning Inspectorate with yet another possible Planning Application via the Town and Country Planning Act for what is a major development in the AONB.
The scoping opinion refers to a Nationally Significant Infrastructure project linked to the SZC DCO and as such should be considered and examined by PINS giving the appropriate significance to the AONB designation and the protection it confers.
We find it curious that the relocation is also included in the SZC DCO application. It seems that EDF are hedging all their bets. But it either is or is not a Nationally Significant Infrastructure Project. The majority of respondents to the previous ESC Planning Application clearly see it as a matter for the Planning Inspectorate and something which should be adjudicated on at that level.
No mention is made of the 100+ objections (including one from Leiston-cum-Sizewell Town Council) which were received by East Suffolk Council when the previous Planning Application was submitted in 2019: the absence contradicts the EdF statement that is wishes to be a good neighbour.
The suggestion of using Sizewell A land for some facilities, when, as far as we can ascertain, this has not yet been agreed, assumes a situation which may not be in the best interest of Magnox/NDA. We feel it would have been polite to raise this suggestion with a joint statement from Magnox/NDA. Without such pre-notification, members of the public could be excused for believing that a deal has been struck which is untrue and gives the impression that EdF is being of deliberately deceitful.
The Scoping Opinion includes the felling of the 100-year old Coronation Wood which supports many species. EdF is very aware of the local opinion which considers this as totally unacceptable, a view shared by many members of the public. Such insensitivity to environmental sustainability and awareness of public opinion is not becoming of an organisation which professes to be environmentally aware and which has deliberately ignored the views expressed in many previous letters of objection to what is an act of environmental vandalism.
The opinion gives insufficient consideration to the flora and fauna including all species of bats and badgers which are an intrinsic part of this area and should not be disturbed. This is not an area in which animal husbandry is practiced, and badgers are therefore not a bovine TB threat to cattle. There are no reasons to move them or destroy their setts.
If the EDF Scoping Opinion is translated into a Planning Application, a full up to date EIA must be undertaken to accurately assess the present environmental situation and the consequences of EDF’s plans.
By all means plant 2,500 saplings somewhere on the EdF Estate, but we object that this be carried out at the expense of felling mature woodland and should under no circumstances be carried out on Pill Box Field.
Yet again there is a total lack of understanding of the AONB designation: Pill Box Field consists of acid grassland and as such so it should remain. It is part of the mosaic of what remains of Suffolk Coastal Sandlings and supports many species of grasses, flora, and invertebrates.
The WW2 Pill Box is also a Historic feature of the Sizewell Countryside and was used as a lookout to protect Sizewell Gap Road. There should be no consideration of its removal. Many of the coastal WW2 Pill Boxes have been lost to the sea and this remains an historical architectural feature of the area. It is also a focal point and if surrounded by trees will not be visible.
This Scoping opinion suggests yet again the complete intrusion of a built environment into the AONB by covering large tracts of land in the area with concrete and intrusive buildings. Even with the proposed reduction of height, there will still be an unwelcome, unaccustomed, and constant intrusion of light, noise, and dust pollution. The felling of Coronation Wood means the loss of its sound absorbing quality and that the SZA and B complex will be more visible in the AONB landscape.
Pollutants, petrochemical run off from traffic using the suggested Western Road, will impact the adjacent SSSI. This should be avoided as the delicate balance of the water courses are vital to the many varied species which depend on the levels and quality of the SSSI habitat.
Consequently, TASC believes that:
- a) It is premature to suggest the alteration to the previous Planning Application as there is no guarantee that Sizewell C will ever be built.
- b) Coronation Wood should not be felled
- c) Pill Box Field should be left as acid grassland, and the WW2 Pill Box should be retained as a Historic feature.
- d) The suggested alterations to the buildings will still intrude with light and noise into the AONB and still be a blot on the AONB landscape.
- e) The suggested western access road appears to stop abruptly at the Outage car park: this cannot possibly be so as traffic movements within the site need to be explained before a Planning Application is submitted.
In conclusion, this scoping opinion may lead to a planning application under the Town and Country Planning Act to the local authority. As the suggestions contained in the scoping opinion are included in the DCO application, it would be premature and unacceptable to submit an application to the local planning authority before a final decision is made by the Secretary of State on the Sizewell C DCO.
Joan Girling for and on behalf of TASC
August 22nd, 2020
