SZC Consultation Responses

The 2nd EDF Consultation ran from 23/11/16 to 03/02/17.

Despite promises to the contrary, EDF chose to run the consultation over the Christmas period just as they did with the 1st consultation 4 years ago. It is easy to be disheartened when ploughing through the 321 pages of the 2nd consultation document, and it is the view of some members of TASC that the document and the whole consultation was designed to sap the will and energy of people who want to engage with it. There is a lot of verbiage and little detail in the document, and whilst we were invited to comment on trivial aspects of the plans there was no option given for us to reject it completely. TASC responded to the consultation and pointed out the issues that were omitted by EDF as we feel it is important to engage with the planning process and to highlight the paucity of information that was given to us by EDF

A link to the EDF 2nd consultation document is here.

Read the response from Together Against Sizewell C (TASC)

Read the response from Joan Girling and Mike Taylor

Read the response from Blackwater Against New Nuclear Group

Read the response from Friends of the Earth

Read the response from Emma Bateman

Read the response from Dr B Horwood

Read the response from B. Hoggar

Read the response from Historic England

2nd Consultation- mains water

In the 321 pages of the 2nd consultation document there is no mention at all about the use of mains water. When I asked a Sizewell “expert” during the stage 2 consultation roadshow, he was unaware that Sizewell C would require 1,600 m3 mains water per day, and thought that I was asking about water that would be used to make tea and flush the toilets. When I explained how much water would be required, he suggested that it was not EDF’s problem as they would just buy the water from the water company and let them work out where it is to come from.

That answer was incorrect:

Sizewell B currently uses around 800 cubic metres of mains water a day, which is 7% of of the total demand of the local catchment area.¹ The twin-reactors of Sizewell C would require at least 1,600 cubic metres of fresh water per day in order to cool various parts of the plant including the primary and secondary circuits of the reactor, which means approximately 20% of the mains water would be taken by the power plant. The East Suffolk Catchment Abstraction Management Strategies (CAMS) covers an area of 1364km2 and includes Felixstowe, Ipswich, Woodbridge, Wickham Market, Stowmarket, Saxmundham, Halesworth, Southwold and Kessingland.²

Households in suffolk are being asked to conserve water because it is recognised that this is one of the driest regions in the country and there is little scope for abstracting more water from local water sources.³

The committee on climate change report “UK Climate Change Risk Assessment 2017” ⁴ cites ‘Flooding and coastal change risks to communities, businesses and infrastructure’ as the biggest threat that comes with climate change the top 6 risks also includes ‘Risk of shortages in the public water supply, and for agriculture, energy generation and industry’

The report goes on to say:

“Climate change is projected to reduce the amount of water in the environment that can be sustainably withdrawn whilst increasing the demand for irrigation during the driest months. At the same time the growing population will create additional demands on already stretched resources in some parts of the country. Even low population growth and modest climate change scenarios suggest severe water supply deficits”⁵

Edf has an obligation under the governments national policy statement for energy to submit an an environmental statement which includes details of how much water in intends to abstract and what impact this will have on existing water resources:

“5.15.3 The ES should in particular describe:

…existing water resources affected by the proposed project and the impacts of the proposed project on water resources, noting any relevant existing abstraction rates, proposed new abstraction rates and proposed changes to abstraction rates (including any impact on or use of mains supplies and reference to Catchment Abstraction Management Strategies)”⁶

EDF is also required to set out their strategy for mains water use in order to comply with The Suffolk Ecology Principles for Sizewell C, which state:

“The anticipated levels of water use and a suitable potable water source for the development must be identified to ensure there is adequate capacity and that this can be achieved in a sustainable manner that will not have an adverse effect upon river flows or wetland sites.”⁷

The impact that Sizewell c will have on the mains water supply was recognised and flagged up during the stage 1 consultation by individuals and in the response from Leiston town council:

“9.5 There are serious issues concerning Leiston-cum-Sizewell Town Council regarding potable water. It is unclear from the information provided what the actual intake of water associated with Sizewell C is going to be, and how much will be needed for the reactors. Leiston-cum-Sizewell Town Council has been informed that, with the intake of Sizewell B, the potable water situation in the area is currently only just in balance.”⁸

Emma Bateman

Consultation Response from TASC supporter

Your response:

It is a sham. This ‘consultation’ offers no real chance for people to create a new possibility for power production in the area. The people of Leiston could all be employed making solar panels, tidal barriers or wind turbines. See the wonderful work being done in Hull www.siemens.co.uk/careers/en/hull-jobs.php

This consultation presupposes that the construction of nuclear power plants is something useful or necessary or responsible in itself. It is not. Go and visit Fukushima or Chernobyl if you are at all in doubt. This consultation is too long and unwieldy and does not offer the chance for people to reject the whole idea. Nuclear power is irresponsible for future generations. It makes very, very, very expensive electricity – you would probably make more power by actually burning money in your power station. Stop this madness and give proper employment that will sustain the people of Leiston for many generations to come – not irradiate them.

R. Pyke

EDF stage 2 consultation response – Mrs. M Horwood

I write with much concern about the plans to construct two enormous Nuclear Power Stations in our neighbourhood

It is dangerous and irresponsible to create a toxic mix that as yet there is no solution to dealing with it. How do I explain this to my grandchildren.
it is clear that the coast in our area of Suffolk is eroding faster than anticipated. It erodes more in some areas than others but if you were to walk at Cove Hithe or Thorpeness both only a few kilometers either side of the Sizewell plant you would see how the erosion defies the statistics we have been presented with.
The impact on nature will be disastrous. The precious SSSI land, the Sanderlings and the edges of the reedbeds will all suffer from from the construction work, noise and disruption. So many of us moved to this area of Suffolk because of its natural beauty and stillness.
Constructing campus accommodation for single workers ( over 2000!)will not provide any helpful social infrastucture for Leiston or local towns. Nor will it help future housing. People of Leiston remember the drunken Friday nights after payday . And now the police station is not open and local medical aid less available. I used to live in Eastbridge and work in Leiston and was well aware of this social problem.

I could continue with concerns but I am sure that you will consider these points in detail before deciding to forge ahead with such an unacceptable plan just because it has cost so much already.

Yours truly

Mrs M. Horwood.

Response to EDF Stage 2 Consultation for Sizewell C- A. West

1. Sizewell C proposals – overall

This is a totally inappropriate project . The site is far too small for the proposed build and the land take has increased since it was first made public. Even more land take is proposed, under compulsory order if necessary, and the inevitable destruction of valuable internationally recognised wildlife sites is unacceptable.

Concrete will cover an area twice the size of Leiston, most of which is an AONB (Area of Outstanding Natural Beauty) and SSSI (Site of Special Scientific Interest) and on the Heritage Coast.

To encroach so closely to the small villages of Theberton and Eastbridge and to RSPB Minsmere should not even be contemplated.

Peoples lives will be hell and tourism will be curtailed because traffic will increase so much that visitors will not want to come to what will be an industrialised environment.

This is also a very vulnerable coast, as was seen with the threat of extensive flooding on Friday 13th January. I could not believe it when I asked about flood risk to the site at one of the Consultation exhibitions I was told that it was “ok” because “ it would become a peninsular”. Well I don’t think this is a very good response and if this is EDF’s attitude then this is very worrying. In fact if the site needs so much protection from flooding in the way of rocks and concrete it proves it is the wrong site for such a dangerous power station. We have to live with ’B’ but we should not be building any more here.

2. Environment

No attempts at mitigating the loss of such a wonderful wildlife rich area will justify the destruction of this unique site. It is an extremely sensitive area. Part of the proposed ’platform’ covers the north eastern part of the SSSI, an area rich in rare fauna and flora which will be destroyed and lost forever. Aldhurst Farm is not, as shown in Fig 7.8, a SSSI habitat and probably never will be.

The site is adjacent to Minsmere, of national and international fame and a RAMSAR site, close to Walberswick SPA (Special Protection Area) of European importance. The shoreline itself in front of the site is vegetated shingle, a CWS (County Wildlife Site) with rare and uncommon plants and nesting terns and offshore is the Outer Thames Area Special Protection Area. This whole part of Suffolk is full of protected areas which makes it a totally unsuitable place for such a massive and destructive building project.

Mitigation will not be acceptable as ancient sites holding rare flora and fauna cannot be replicated. Once it is gone, it is gone forever.

3. Site Access Road

The proposed road will cut right through the AONB form east to west creating a barrier for wildlife. Animals can move freely over the whole area at the moment and the road will cut through their habitats causing them to be displaced or prevented from foraging or even killed. Many animals such as otters, deer and badgers roam over a wide range and they will be affected by 12 years + of noise, light, ground disturbance and pollution along with the enormous number of humans and machines. A large number of trees are proposed to be felled resulting in yet more loss of habitat.

As for the causeway over the remaining part of the SSSI which is left after the platform has been built, this is not a question that ordinary members of the public should be asked – we are not all engineers. As I disagree with the canalising of the river and the destruction of very rare wet woodland, which is a Biodiversity Action Plan Priority Habitat, I have to disagree with the whole concept.

4. Managing construction materials.

How can you even consider digging huge quarries, or “borrow pits” as you like to call them, right next to the villages of Theberton and Eastbridge? The noise, dust and pollution will be unbearable. They would also be close to Minsmere, Walberswick Heaths and Marshes Special Protection Area and Ash Wood causing enormous disturbance to wildlife.

5. Accommodation

The huge influx of, mostly young male, workers into this small rural area of Suffolk will present huge difficulties to the local communities. It is proposed that the majority of them will live in the accommodation blocks next to Theberton and Eastbridge. Although we have been told that all of their needs will be satisfied on the site I cannot believe that, in their free time, they will not choose to roam around Leiston, or further afield in their cars, looking for excitement and female company.

When Sizewell B was being constructed Leiston became like a Wild West town with drugs, booze and prostitutes. There were even mini brothels being run in nearby villages, I am informed. I cannot believe that EDF will be able to stop this happening again despite their promises.

The area chosen for the accommodation blocks is unsuitable. Whichever option you look at the road to Eastbridge will be incorporated into the campus. This road is one of the main routes to Minsmere and, if it is closed, visitors from the south will be forced to travel through tiny back lanes to get there or take a long detour through the village of Westleton.

Three, four or five storey blocks on this site would be totally out of scale and inappropriate in what would normally be a very tranquil place. The number of cars to be parked on the site reiterates my point that the workforce will not stay on site all the time but will use their cars to travel for entertainment.

7. Transport : overall

There is no mention in the document of which ports are likely to be used so we have no idea of where most road traffic will come from.

The jetty has not been shown in elevation so we have no idea how high it will be or what it will look like.

The proposed “green” rail route cuts right through the AONB and farmland and ecologically sensitive areas, as does the proposed “access road” from the B1122. These are both too close to Leiston Abbey and the Pro Corda Music School.

The increase in road traffic across a wide area of the county will be enormous on an already inadequate road system. Alongside tourist traffic there are already HGV’s crossing the county from Felixstowe, white vans and commercial vehicles as well as local people travelling to work by car. The addition of extra vehicles wending their way to the Park and Ride facilities via minor roads and country lanes will cause horrendous problems not only to the people living alongside these routes but those trying to go about their daily business – taking children to school or going shopping. Many hold-ups and traffic jams will occur.

We also have to think about the events held in this part of the county. Snape Maltings already attracts thousands of visitors each year and that is due to be expanded. The annual music and arts festival “Latitude” near Southwold is planning to grow in size and that already attracts thousands of visitors.

These are two venues that are an established part of this county’s culture and this huge industrial project will ruin peoples enjoyment because travelling to them will be a nightmare. Visitors who now holiday in the area for its peace and beauty will find quieter places to go, thus ruining a vibrant tourist industry.

9 Transport : Sea

The proposed jetty to receive heavy materials by sea has not been shown in enough detail for ordinary people to form an opinion.

How do we know what effects this will have on the sea bed during its construction, its use and if and when it is dismantled. What size ships would be using it? Not enough information.

10 Transport : Park and Ride

The actual Park and Ride facilities are gobbling up even more farmland. They will be operating 24/7 and the noise, fumes and light pollution will be horrendous for those living nearby, especially at Darsham. With so many trips planned for buses to and from the construction site day and night the area will become unbearable. Properties are already blighted and unsaleable around these sites. People should not be made to suffer this. No amount of compensation will make it alright.

11 & 12 Transport : Road Improvements

All the bypasses suggested at Farnham are ecologically damaging, except Option 2 which would not satisfy the residents on the bend and includes knocking down a Grade 2 building.

At Yoxford you admit that traffic will increase by 722% during the peak construction period. This is unacceptable.

Theberton can expect and increase of 542% during this period. This is also unacceptable.

It beggars belief that you would expect anybody using these roads or living on them or near them to accept these increases and shows utter disregard for the people of Suffolk.

Cycling : You suggest that your workers might prefer to cycle to the Park and Ride facilities or to the construction site. Well, unless the routes are completely off road, good luck to them. They will be taking their lives in their hands along with visitors and locals who cycle. With the increase in traffic cycling will be out of the question.

13 People and Economy

Tourism is an enormous part of this regions economy. If this project is allowed to go ahead tourism will be killed off. People come here for the peace and tranquillity of the countryside and the wildlife that this attracts. The effect of the industrialisation of a huge area of internationally recognised natural countryside that has been fought for over decades will be enormously detrimental. Visitors will simply go elsewhere.

The jobs promised are not all high paid long term jobs. Many skilled workers may be transferred from France when the project there is eventually finished. Local companies looking to recruit staff will not be able to compete with the higher wages offered by EDF and workers will leave to work there with consequences for local businesses.

14 Consultation process

I was very disappointed that the consultation period included the pre-Christmas period when most peoples attention was on other things. I understand that this was also the case for the first consultation and I feel this is insulting to the general public.

The consultation documents are poor. Much information is left out and there is not a lot more in them than in the first consultation. The maps are very poor and far too small to give proper detail. The keys to the maps in the summary document are illegible.

Audrey West

Stage 3 Consultation Responses

Read the response from SZC Liaison Group-S.A.G.E. Monitoring

Read the response from Friends of the Earth Sizewell C

TASC Response to EDFE Stage 3 Consultation for Sizewell C.

Waveney Green Party Response to Stage 3 Consultation

RSPB response to Stage 3 Consultation

Suffolk Wildlife Trust response to Stage 3

Minsmere Levels Group response to Stage 3

Environment Agency response to Stage 3

Suffolk Preservation Society response to Stage 3

Suffolk AONB response to Stage 3

EDF SIZEWELL C 3RD CONSULTATION- Chris Wilson

Please find below my response to your 3rd consultation in relation to your proposals to build Sizewell C(SZC). I have generally followed the headings as set out in your consultation response but, after my introduction, I have initially provided my comments on the consultation itself as these set the framework for my responses.

INTRODUCTION

I have known the Sizewell area for over 50 years and love the area for its scenic beauty and for the tranquillity offered by the coastline and rich mosaic of landscapes making up the Suffolk Coast & Heaths AONB (AONB ) and East Suffolk (ES) generally and have spent countless hours exploring this area and enjoying the richness of the flora and fauna that have made this place home over millennia. I am therefore appreciative of the impact that construction of SZC and its vast infrastructure will have on the people and environment of ES.

The EDF literature states there is an urgent need for new nuclear reactors. This statement is based on outdated government policy formed over a decade ago and since that time there has been considerable technological advancements and cost reductions in areas such as improved storage of electricity and production from low carbon renewable sources . As stated by the National Infrastructure commission in late 2018, there is no need to pursue government’s civil nuclear ambitions. There is certainly no urgency and I can only think that EDF’s stated urgency is borne purely out of their own commercial considerations.

THE CONSULTATION

a) I thought that an infrastructure project like SZC should have a Statement of Community Consultation. However, I could only find one for stage 2 so believe this consultation is flawed.

b) Due to the scale of this development and the wide ranging impact it will have on the area between Ipswich and Lowestoft

(probably even further south on the A12 assuming most of the HGV traffic will come from that direction) the limited number of exhibitions held by EDF for stage 3 mean that the area of consultation is totally inadequate.

c) If EDF truly wanted to consult with the public they should have:-

(i) delayed the exhibitions by a week or two to allow some time for the public to consider published information so as to be able to engage more fully at the exhibitions,

(ii) arranged some public meetings so there could have been true public engagement, as opposed to the public being spoon-fed the information EDF want to impart

(iii) arranged more exhibitions for evenings and weekends to enable those at work/college during the day to engage

A cynic might conclude that c)(i)-(iii) were planned to prevent full engagement with the public.

d) With regard to the exhibitions and information supplied:-

(i) the A4 sized brochure contained keys to some maps that are too small to read so made understanding those diagrams impossible,

(ii) there was clearly a lack of knowledge demonstrated by some of the EDF representatives at exhibitions eg being asked how much drinking water would SZC consume during operation to be told that SZC only used sea water and categorically no drinking water would be used!

(iii) maps show no grid lines so were very hard to understand

(iv) the attitude demonstrated by some EDF representatives at exhibitions fell below my expectations eg one, when the difficulty of reading some keys in the EDF brochure was put to him, accused the speaker of “having an agenda” and then just turning his back

(v) this consultation has taken place at the same time as one for Sizewell B, another for the wind farm substations as well as the local district plan so I think that many have not been able to devote sufficient time to reviewing all aspects of the Sizewell C project

(vi) the 1st & 2nd consultations were Marine-led but this has now changed with little more than a passing reference to it being on environmental grounds. There needs to be an in-depth analysis comparing the impacts of a marine-led project compared to the road and rail-led options. As there is so little supporting information on the new road proposed from the A12 in terms of its environmental and societal impacts there should be a further consultation for the residents of ES to consider this option. How can we comment when there is so little information to comment on?

(vii) at EDF’s mini exhibition held at The Dolphin, Thorpeness I asked a question (could they advise how deep the rock armour of the coastal sea defences would be as I was concerned that it was not deep enough so rising sea levels and coastal processes could undermine this protection) to an EDF representative. The person I spoke to said that they did not have the answer, took my email address and promised a reply within 7 days. Over four weeks later I am still waiting for an answer. I can only wonder how many questions have not been answered, that being on top of my doubts as to how much misinformation has been imparted to the public.

OVERALL SZC PROPOSALS

a) as mentioned above, I believe the need for new nuclear is based on an outdated premise. Since the current government energy policy was established over 10years ago technology has moved on considerably. Electricity from renewables is cheaper, cleaner, lower carbon than nuclear and quicker to deploy, something that was considered improbable by the policy makers. Demand for electricity has fallen in the last 10 years even though our population has grown and the economy has expanded, this being totally contrary to the statements underpinning current policy. As nuclear is inflexible in terms of meeting fluctuating demand it will hinder not help keeping energy costs down in the future.

b) Sizewell was nominated as a “potential” site when the current EN6 was implemented and will not meet the requirement to be built by 2025. All the sites listed were only there as there were existing nuclear power plants (NPP) already there. This, in itself, is not sufficient to justify that any new NPP has to be at Sizewell and our awareness of climate change predictions and the impact on sea level rise and coastal processes means that Sizewell, being in flood zones 2 and 3, should be removed from any list of potential sites.

c) Sizewell is located on an eroding coastline within the AONB surrounded by a largely rural community and landscape. As such it does not have the infrastructure to support such a massive construction project and in order to enable SZC to go ahead roads, railway lines, beach landing facilities etc will need to be constructed. This will be an intolerable burden on the residents, businesses and the environment of ES both during the 10/12 year build period and will detrimentally change the area permanently.

d) Sizewell is surrounded by rural roads, bridleways, trails and footpaths with many having historic value and includes the Heritage Coast path which is to form part a national coast path. These are used by residents as well as the many thousands of tourists that visit this area. The 10/12 year disruption during the build period together with permanent closures and alterations are not acceptable and will severely impact the vibrant tourism industry and impair the enjoyment of locals and visitors alike.

e) SZC will be partly built on the 105 hectare Sizewell Marshes SSSI losing 6 hectares permanently and 3 hectares temporarily (but seeing how EDF operate, could end up being permanent). With a permanent elevated roadway going over the SSSI, I have concerns as the impact of light, noise, air and run off from road pollution which are not dealt with in the consultancy documentation. I am also concerned that the road though the SSSI will change the hydrology which is so important to the very future existence and support to the flora and fauna of this special site so I worry that the entire SSSI will be permanently degraded by this project. I can see nothing in the 3rd consultation documents to allay my concerns.

f) The SZC site will border the iconic RSPB Minsmere nature reserve which, as well as being a major economic benefit to the area, has numerous national and international designations demonstrating its importance to biodiversity and the natural world. I have seen nothing in the 3rd consultation documentation that would alleviate my concerns that:-

(i) 10/12 years of light, noise, water and air pollution during construction will have a major negative impact on Minsmere’s iconic wildlife during those years and in the years following,

(ii) it will cause visitor numbers to steeply decline impacting the RSPB and the tourism industry

(iii) it will affect the hydrology of the site which will permanently degrade the natural environment and therefore the species Minsmere supports

(iv) the coastal squeeze that will occur if EDF are allowed to bring the bund wall seawards will inevitably exacerbate flood risk and erosion north (affecting Minsmere) and south of Sizewell

g) SZC will be built in the AONB, a designated area supposedly protected under s.85 Countryside and Rights of Way Act 2000 (CROW) and the National Planning Policy Framework (NPPF). Para 172 NPPF says, amongst other things, that:-

– major development should only be allowed in exceptional circumstances and where it is in the public interest

– scale of development should be limited

I believe that it is clear that SZC and its attendant infrastructure will be a major development with a 32 hectare reactor site and a further area that must be approaching 200 hectares for further development within the AONB (plus even more just outside the AONB). As all the country’s electricity needs can be met from renewable sources, storage, demand management, smart technology and demand reduction backed up by flexible gas plants, SZC is not needed. The scale of the entire development is massive and given the environmental destruction that comes with it together with the disruption to the lives of Suffolk residents and businesses, it is not in the public interest.

The AONB is a designated protected site because of its natural beauty and special qualities which include:-

(i) the quality of the landscape it being made from a diverse mosaic of heaths, marshes, farmland, woodland, unspoilt beaches and coastal fringes,

(ii) its scenic qualities which are enhanced by the open nature of the countryside, its largely unspoilt nature and the ability to see for great distances from natural vantage points,

(iii) its relative wildness

(iv) its tranquillity and relatively dark skies

(v) the flora and fauna that has made this area home over millenia

SZC will seriously degrade all these features as it will:-

-divide the AONB in two with the new access road

– create light, noise and air pollution during the 10/12 years of construction and then during the 60 years of operation and potential further 100 years for storage of radioactive waste on site

-will create an elevated roadway over the SSSI which will be visible from a great distance and which will likely pollute the marshes below

-will industrialise and urbanise the AONB and will therefore change the very nature of that area. Just because Sizewell A and B are already there, it can not justify creep of further development into the AONB.

-create an eyesore visible from a great distance due to: the height of the SZC reactor platform (being higher than SZB); installing pylons potentially 65 metres high; the great height of the cooling chimneys; the generator halls at the seaward side of the complex imposing on the coastal views from inland as well as the Heritage Coast path.

-cause the loss of nationally and internationally important natural habitats and therefore the flora and fauna that it supports. As the area is so unique no amount of mitigation could recreate the type habitat that will be damaged.

h) SZC during its lifetime will create a legacy of radioactive waste that, in radiological terms, will equate to 80% of the entire inventory of radioactive waste already produced by civil NPPs historically. Not only is there no scientifically proven safe method for storing existing radioactive waste, the waste that would be produced by SZC would be more problematic. I believe that it is immoral to build SZC, leaving future generations, that will have gained no benefit from the electricity produced, with the problematic legacy of having to look after and protect from improper use (terrorists), egress into the environment, and, possibly, meet the financial liabilities for the toxic waste.

i) I understand that the spent fuel rods will be stored on site for at least 100 years but are likely to be there longer. There have been recent warnings from the IPCC and the meteorological office about climate change and possibilities with regard to changes in weather and sea level rise. Given that the SZC site is in flood zones 2 and 3 on an already eroding flood-prone coast, there is no way that two new reactors should be operating from the site, let alone storing highly toxic radioactive waste for an additional 100 years or more. EDF’s documentation does not provide any analysis for expectations of sea level rise and risks from storm surges for the entire duration that the site will be occupied.

j) The SZC documents make no reference to the amount of drinking water that will be consumed during the construction of the NPP and its infrastructure nor the amount that will be used each year during its operational period. I have seen estimates that SZC will consume between 1.5m to 2.0million litres per day when operational. ES is already one of the driest parts of the country and with anticipated additional demand from new housing in the area, combined with the forecast higher summer temperatures/ lower summer rainfall it is likely that there will be a major impact of water shortages. Are the residents, farmers and businesses of ES going to suffer because of SZC? Given that EDF have repeatedly said that SZC will be a replica of Hinkley Point C NPP they must know from the Generic Design Assessment anticipated drinking water consumption. Why has this detail not been included in the 3rd consultation documents for the public to consider?

k) The impact on fish stocks and other marine life does not appear to have been fully considered in this documentation. Newspaper reports about Hinkley Point C (same as SZC) suggest that 2.5billion gallons of sea will be sucked in to the cooling pipes each day which is four times the volume used by the existing Hinkley Point B NPP which is estimated to kill up to 2 tonnes of fish per day. I feel that the negative impact SZC will have on fish stocks and other marine life could be catastrophic with an adverse knock on effect on the livelihoods of the local fishermen and the bird and marine species that depend on the sea for their food. With regard to the marine environment I believe that there needs to be a robust assessment of the environmental impact of returning 2.5 billion gallons of heated sea water to the coastal waters each day.

l) Whilst not a planning issue, I also want to mention EDF’s claims that new nuclear is low carbon. When you consider the whole lifecycle from uranium mining, milling and fabrication, through construction, operation, decommissioning and then the unknown carbon footprint of storage for thousands of years, then it is hardly low carbon. The upfront carbon footprint (and production of other greenhouse gases) prior to start of nuclear generation is particularly relevant given the IPCC’s warning in 2018 that we have at most 12 years to vastly reduce our carbon footprint. This would be the build period and time that SZC’s uranium fuel would be prepared. This would seriously hinder, not help, the UK meet its climate targets.

m) Government, through the Dept. for Business Energy and Industrial Strategy (BEIS), is going to great lengths to subsidise nuclear power station construction through the adaption of the Regulated Asset Base method of financing. In a market driven economy it is wrong to make one element in a competitive market artificially cheaper. Also, it is totally wrong to force the risk of a new nuclear venture on to the UK taxpayers and/or electricity consumers (you only have to look at the experience in USA to see the level of risk).

MAIN DEVELOPMENT SITE

a) EDF’s Jim Crawford has advised that the development site for the construction of the two nuclear reactors is 32 hectares. The proposed new EN6 siting criteria for new nuclear states that each reactor should have 30 hectares per reactor. Clearly 32 hectares is insufficient for safe construction and operation of two reactors with all the attendant ancillary structures. This is borne out by the packed picture for the proposed SZC site with everything crammed in and pylon wires installed over the nuclear site. I hold that the SZC site is only sufficient size for one reactor.

I worry that, due to the site being too small, EDF will subsequently try to expand the site further into the AONB and SSSI. EDF are already trying to implement development creep into the AONB and SSSI with the relocation of Sizewell B buildings and construction of a new car park for SZB outage workers in the AONB. EDF’s disregard for these designated areas is evidenced by the proposals for the SZC car park and elevated road across the SSSI.

b) I am concerned about the proximity of an operational nuclear power station, SZB, so close to the SZC site. I would assume that the SZC development will require substantial cranes and involve significant vibration from earthworks. I see these as a risk to the SZB workers and as a physical risk to the SZB reactors. This then identifies a further potential problem if there were an emergency event at SZB. This could be at time when there were a 1,000 outage workers at SZB, over 5,000 at SZC and tens of thousands of tourists at peak times. What plans have been put in place to deal with an emergency event during SZC’s construction?

c) Whilst these elements were not included in the model displayed at the EDF exhibitions, I am concerned that the cramped site means that the pylons on site, along with the chimneys, will be a prominent eyesore spoiling the scenic appearance within the AONB from miles around.

d)When the reactor site is excavated there will be a need to remove the water which will be highly acidic. This must not be allowed to be pumped into the existing water courses nor into the North Sea. EDF need to say what they will do with this water.

e) The documents do not disclose the amounts of peat, clay and other materials that will be excavated from the site. It is anticipated that this will be a vast amount of material which will be an environmental hazard itself with the risks of contamination of the AONB being exacerbated by transportation from the site. The dumping of this, and the digging of borrow pits, in the AONB is totally unacceptable.

f) Construction will involve unspecified amounts of materials, including millions of tons of concrete, being transported to the site. The documents do not disclose how this will be done without contamination of the soil and waterways within the AONB and SSSI.

PEOPLE AND ECONOMY

EDF have made much of the jobs that will be created by SZC. No doubt there will be some jobs for locals but EDF have stated that they want to move their experienced workers from Hinkley C. As ES does not have an unemployment problem I can foresee that any local skilled workers employed at SZC will be at the expense of local businesses who will then find it hard to recruit. The area also has a thriving tourist industry which has grown organically over the years. This sustainable industry will be greatly compromised by the all the congestion, building work, influx of thousands of outside workers which will inevitably lead to a large reduction in tourist numbers. This will not just be a problem for the 10/12 years of construction but for a decade or so afterwards. Some local businesses might gain from the construction of SZC but I recall the boom and bust experienced when SZB was built. Leiston became a place that was not pleasant to visit in the years when SZB was being built. Any controls that EDF might like to put on its workers are unlikely to prevent the unpleasantness being repeated with SZC. The disruption to the lives of residents, businesses and farms in the region and the long term negative impact on the tourist industry more than outweigh any short term benefit resulting from SZC.

Apprenticeships are always to be welcomed but as nuclear is in terminal decline, these should be in sustainable businesses looking to the future. I would also add that there will be plenty of jobs going forward in dealing with the decommissioning of nuclear power stations.

ACCOMMODATION

As stated above, the massive influx of outside workers will have a great negative impact on locals and a lot of existing businesses. As there is proposed to be a double up of road/rail workers plus SZC workers it would be far more sensible all round if all the infrastructure was constructed before work on the SZC site was started.

TEMPORARY CAMPUS AND CARAVAN SITE

I understand and agree that the campus would need to be as close as possible to SZC to reduce daily traffic. Because it will have a negative impact on the AONB, there is no suitable location for it.

I consider that 400 caravans so close to Leiston will cause unacceptable levels of noise and disruption to local residents.

TRANSPORT

As EDF have not advised of the quantities of materials or the direction of travel of these it is difficult to assess and comment on the advised levels of HGV journeys. However, what is clear is that there will be massive volumes of traffic, not just HGVs but also workers, white vans, etc. This will be an intolerable burden on the locals. Whilst supposed mitigation for this disruption is more roads, roundabouts etc I am totally opposed to burdening the area with more tarmac and concrete than it needs long term. My opinion is that SZC should not be built at all, but if it is, then existing roads should be used-after all SZB was built using the existing roads. If it takes longer to build then that is ok as there is no urgent need for the electricity that would be produced.

EDF have dismissed a marine-led project, but I think that this needs to be reassessed and a full environmental impact comparison be carried out between the different options. Based on the 1st, 2nd and 3rd consultations, I think that the marine-led one seems preferable, rail-led 2nd and road-led totally unacceptable.

With a rail-led strategy, the railway line should terminate before reaching the AONB and should be temporary and be removed as soon as bulk deliveries are complete.

With the road-led strategy, the new road proposed from the A12 appears to have had no great thought put into its route and seems like a last minute afterthought. The impact on farms and residents is unacceptable and the environmental impact is totally unknown. If it is decided that the road-led strategy is the only way to build SZC then it should not be built at all.

A12 TWO VILLAGE BYPASS

a) Having travelled on this stretch of road hundreds of times, there is no real traffic problem. I appreciate that there is a pinch point on the Farnham bend that could affect wide loads. This could be dealt with by:-

(i) having wide loads accompanied so that their movement round the bend can be controlled,

(ii) purchasing the properties on the corner and demolishing them to enable the road to be widened,

(iii) diverting car traffic off of the A12 at Woodbridge to travel to the coast via the A1152 and B1069.

b) There is no Environmental Impact Assessment for the proposed bypass. However, you only need to look at an ordnance survey map to see that a large area of open countryside would be lost. For what?- an unnecessary road for an unnecessary NPP.

CONCLUSION

My conclusion is that SZC: is not needed; will cause untold environmental damage; will industrialise a large part of the Heritage Coast; will have a severe and negative impact on the lives and fortunes of many Suffolk residents, farms and other businesses; will hinder, not help, with climate change; will create large amounts of high-burn radioactive waste for which there is no proven safe way to store and which will be stored on the sinking, eroding, at risk from sea level rise East Coast for over a hundred years; will damage the thriving East Suffolk tourism industry; will damage the integrity of the AONB with visual, noise and light pollution; will negatively impact RSPB Minsmere nature reserve and other special places important for their flora and fauna; will degrade the marine environment; will have negative aspects that far outweigh any positives; will cause major disruption due to road changes.

Yours faithfully,

Christopher Wilson, Suffolk

Nuclear Power: Systemic Risk And Climate Change

Summary

Humanity faces a large number of challenges in future decades including increasing population leading to increased competition for dwindling resources and climate change. These challenges could lead to ‘collapse of civilisation’ i.e. the complex system of exchange of good and raw materials, energy, food and water would be susceptible to shocks or many even collapse altogether.

The nuclear industry is unique in the danger it poses from systemic shocks or collapse. Without of power supply, fresh water and human expertise it creates the risk of reactor core meltdown and/or a spent fuel fire which could release massive amounts of radioactivity with catastrophic results.

Although the consultation document has taken into account a possible scenario of a 3.2m sea level rise (SLR):

2.12.63. The main platform would be at a level of 7.3m AOD, which is similar to the 1 in 1000 annual probability extreme still water levels in the year 2110 for the worst credible H++ climate change scenario (3.2m SLR, including land motion). The H++ scenario identified in UKCP09 is beyond the likely range, but within physical plausibility. The main platform would therefore be safe and resilient for its whole operational life against the worst credible climate change predictions.¹

only the direct risk from the sea level rise in the vicinity of the power plant has been taken into account. However, it is necessary² to take into account indirect risks from such a sea level rise and associated climate change factors outline in the H++ scenario.

The full response to the consultation can be found here.