TASC concerns regarding EA permitting of transfer of water abstraction licences (7/35/3/GS0075 & 7/35/03/*S/0047) from Mortier Farms to NNB GenCo.
TASC wish to bring to the attention of the Environment Agency its serious concerns related to the above planned permitting.
Preamble. This request to vary licences in our opinion raises a number of environmental, moral and ethical issues related to the use of potable water, a precious and increasingly scarce resource, particularly in East Suffolk, an area recognised for its high drought potential. The transfer of such volumes of water in this dry area from agricultural to industrial usage requires a thorough study of the implications for society and for existing consumers in the county.
Reason
Transfer from the Agricultural sub-contractor AW Mortier to NNB Genco of the two above mentioned licences.
- It is unclear if NNB Generation Company (SZC) are the owner of the land on which the abstraction sites are located since they are situated on land originally purchased by the current owners of Sizewell B and any predecessor companies.
History
One original licence 7/35/03/*S/0047 was issued in 1967 and reissued in 1999 for a reservoir fed by underground strata and a watercourse from land roughly co-terminus with the SSSI Sizewell belts and Marshes. The other licence 7/35/3/GS/75 for extraction from River Minsmere New Cut was originally licenced in 1992 and reissued in 1998 for use on land at Upper Abbey Farm and Lower Abbey Farm. Both are in Leiston-cum Sizewell Parish. Both were for spray irrigation.
Concerns
While the existing licences permit extraction annually from April to October inclusive in the case of the River Minsmere and May to October inclusive in the case of the Sizewell Belts SSSI, identifying an hourly, daily and annual maximum, the transfer notices request a change to year-round abstraction. The EA have confirmed there is no change to the total extracted amounts: With regards your query concerning the quantities on the licences, I can confirm these will remain unchanged”.
- It must therefore be made clear that the annual extraction limit referred to in the transfer licences for each site must not be altered. Taking the 2 two permits together gives an annual limit of 80,400 cu metres or 220 cu metres per day, amounts which are substantially less than the early demand for the site given in the Atkins document (link below), of around 500 cu metres per day from 2024 and clearly dramatically short of the site demand for the main construction.
- The current water is specified for use as spray irrigation over the areas specified on each licence.
- These licenced areas do not include the actual SZC nuclear platform. An early part of the project will be to construct a 2km curtain wall which seals off these EA licenced sites from the SZC site, meaning that groundwater could not be replenished by any abstracted water used on the site of the nuclear platform, unlike the existing spray irrigation. Curtain wall trials are to be conducted under ESC planning consent DC/22/0078/FUL and are not yet started and in themselves risk the quality of the groundwater as regards the SSSI abstraction.
SSSI
Suffolk Wildlife Trust (SWT) are now aware of the intention to change the licence for land for which they have had responsibility and will contact Natural England to discuss the implications.
Quality of water and health.
The developer proposes to use abstracted water for construction including wheel washing, dust suppression and process water.
- This represents a clear change of use and for a purpose which may need to be justified i.e. construction of a Nuclear Power Plant as opposed to agricultural cropping. Sizewell C has yet to be issued with a number of operating and construction permits and currently faces a significant funding shortfall.
- The water quality from the proposed sources may not be suitable for spraying (dust suppression) on a construction site as it may contain harmful substances e.g. arsenic, lead etc which may be harmful to health under COSHH. EN010012-001896-SZC_Bk6_ES_V2_Ch18_Appx18A_Phase_2_Geo-environmental_Interpretative_Report_Part_1_of_11.pdf (planninginspectorate.gov.uk)
- Wheel washing normally uses specially constructed facilities which may be able to recycle water but will create a waste stream through filtration. If recycled water is not used for replenishing groundwater, there needs to be an assessment of the potential environmental impact.
- It is unclear what process water is to be used for.
River quality.
The water quality in the Minsmere river is already unknown but must not be allowed to deteriorate. It has been noted that, during the summer, water lilies were dying off at Eastbridge. Attempts to make contact with Internal drainage board who are responsible for the water course elicited no response.
The 2021 RIFE report (Radioactivity in Food and the Environment https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1114928/RIFE-27-Radioactivity-in-food-and-the-environment-2021.pdf indicates the potential for a sediment hotspot of Caesium 137 off Minsmere sluice up to 10 times higher than normal. We are concerned that the spraying of water from this river source could result in harm to health or the environment from aerosol spray, a subject Prof. Tim Deere Jones has already raised as a realistic concern.
The scrape at RSPB Minsmere had dried out earlier in 2022. It is at this stage not clear why this occurred.
Additional exposure/corruption of the flow of the river Minsmere/Yox may have occurred at Yoxford’s Cockfield Hall by creation of lakes and previously at Sibton Park.
The new wetland habitat in the vicinity of Minsmere to be created under ESC planning consent DC/22/2273/FUL must not compromise or be compromised by this abstraction.
The EA will need to have an adequate (even real time) monitoring of this abstraction source in view of its importance to the surrounding environment.
To Conclude. We do not consider the transfer of licences to be justified and would respectfully request that a thorough investigation is made into the ethics and impacts which may arise from this permit change.
If you wish to respond to the above licences, please do.
Environment Agency (by email only) PSC-WaterResources@environment-agency.gov.uk
cc East Suffolk Council Planning Office Bethany.Rance@eastsuffolk.gov.uk energyprojects@eastsuffolk.gov.uk
Therese Coffey MP
