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Suffolk Coastal Friends of the Earth guidance about Sizewell C stage 3 consultation

 

 

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SIZEWELL C: GUIDANCE NOTES FOR RESPONDING TO EDF ENERGY’S STAGE 3 CONSULTATION
The numbers below refer to those in the questionnaire.  You will find this online: www.sizewellc.co.uk.  Otherwise ask for one together with the summary document by ringing freephone 0800 197 6102; or EDF Energy’s local office: 01728 833 891.  It’s best to respond to this, but there’s no need to answer all the questions.  The first two questions provide an opportunity to make general comments.  You can make any additions that you wish. 
Post written responses to FREEPOST SZC Consultation (that’s all), or email comments to info@sizewellc.co.uk.  Ask for an acknowledgement.
Keep a copy and send another to: Lisa Chandler, Energy Officer, East Suffolk District Council, East Suffolk House, Station Road, Melton IP12 1RT: lisa.chandler@eastsuffolk.gov.uk.  Another to your MP.
Further information can be obtained from EDF Energy’s office, 48-50 High Street, Leiston IP16 4EW.
Please use your own words!  Deadline 29 March.

1.SIZEWELL C PROPOSALS OVERALL
We object.  FOE are opposed to civil nuclear power because of a) its link with nuclear weapons; b) it produces highly toxic and dangerous waste, some of which will last for 240,000 years – far longer than modern humans have walked this planet.  Impossible to ‘dispose’ of it.
Policy context: Government’s energy policy (NPS-EN1 & 6) of 2011 is already out of date.  No ‘urgent need’ for nuclear.  Lights haven’t gone out.  Renewables cheaper and much faster to install.
Finance: Far too expensive.  Public shouldn’t have to support nuclear through subsidies, guarantees and insurances.  EDF Energy boasts that SZC will be 20% cheaper than Hinkley Point C.  Very unlikely because a much more complex site (building on marsh rather than rock) – real concern they’ll be cutting corners and compromising safety.
2.THE MAIN DEVELOPMENT SITE: OVERALL
Sizewell site only identified by government as ‘potentially’ suitable.  Why it’s entirely unsuitable:
Erosion/climate change: Suffolk coast subject to erosion.  Will get worse with climate change.  New hard defences to protect the power stations will increase risk of flooding to communities either side.  Site is in flood zones 2 and 3.
AONB:  Main development site is entirely within Suffolk Coast & Heaths Area of Outstanding Natural Beauty, designated for beauty of landscape and tranquillity, and which is supposed to have the ‘highest level’ of legal protection.  Wrong place for massive industrial complex.  Permanent access road will divide it in two from east to west.
Wildlife/protected habitats:  Two reactors to be built entirely on Sizewell Marshes Site of Special Scientific Interest.  Precious flower rich fen meadow lost – impossible to recreate or compensate for.  Directly adjacent to world famous Minsmere RSPB bird reserve.  Birds and animals would no longer be able to cross to the marshes for foraging and breeding.  Hunting ground of rare bats.  Home of protected otters and water voles.
Drainage: Hydrological balance in marshes finely balanced.  Either drainage or flooding would damage e.g. scarce plants, population of important invertebrates (food for rare bats) and ground nesting birds.
Tourism: Loss of tranquillity and wildlife habitats would deter tourists.  Stock piles 35m high – eyesore – noise, dust.
Beach: There is vegetated shingle here supporting rare plants, e.g. sea pea and yellow-horned poppy.  It is a County Wildlife Site (CWS) and a Biodiversity Priority Habitat which should be conserved.  Yet it would all be dug up for new sea defences and a beach landing facility.  EDFE says it’ll save seeds and plant them on the defences, but they’re very unlikely to survive on top of rock armouring.
Beach Landing Facility (BLF): would disrupt coastal process and cause erosion on south side (opposite SZC site).  Dredging likely to affect protective off-shore sandbanks.
Death of fish: Many tonnes of fish lost due to cooling water system.  Reduction in food supplies for protected harbour porpoises and sea birds.
Potable water: Competition with tourism and farming in very dry area.  Where will it come from?
3. PEOPLE AND ECONOMY
Jobs:  Claim of ‘25,000’ highly misleading; actually refers to global roles, i.e. people already working for firms in supply chain.  Construction workers in short supply locally.  Would have to be brought from elsewhere, so most jobs wouldn’t go to locals unless lured away from small firms by better wages.  These firms then at risk – as with SZB.  Low unemployment in Suffolk.  According to EDFE many workers would come direct from Hinkley Point C, many of whom would be from Eastern Europe.  Long-term nuclear jobs highly specialised and local expertise not available.
Social impacts: Large accommodation campus for 2,400+ mostly single male workers next to small village of Eastbridge – would upset social cohesion.  Drugs/prostitutes as with SZB?  Safety of young people at nearby Pro Corda music school?  Code of Conduct may not be effective.
Health: Kikk report from Germany demonstrates a clear link between leukaemia and infants within 5km of their 16 nuclear power stations, so no longer pursuing nuclear power.
4. ACCOMMODATION: OVERALL STRATEGY
‘Home-based workers’: calculated as within 90 mins. of Sizewell.  Who would want to spend 3 hours per day commuting?
Social housing: There is currently a shortage in Suffolk.  Would the ‘housing fund’ help to alleviate this?  Not clear how this would be used.
Tourism: Competition with tourist spaces – long-term effect?  Voluntary register of available places might help.
5. ACCOMMODATION: TEMPORARY CAMPUS & CARAVAN SITE
Campus: Too big, too close to Eastbridge.  As stated at Stage 2, we want to see workers accommodated in the towns, where there is suitable infrastructure, then taken by bus or rail to the site.  Modern block directly adjacent to AONB and in Special Landscape Area (SLA) – setting spoilt.
Danger to wildlife:  Special request to include ‘Care of Wildlife’ in Code of Conduct. (Some workers may not understand that they mustn’t dig up wild flowers, not take birds’ eggs etc.)
Caravan site:  Not opposed in principle as next to Leiston.  However, pitches adjacent to stock piles – health hazard?  Also next to Aldhurst Farm ‘habitat creation’ scheme.  Lighting and noise could deter birds etc. from using the new habitat.
6.  TRANSPORT: MOVEMENT OF MATERIALS
ROAD-LED STRATEGY
We do not support the road-led strategy.  FOE is opposed in principle to the building of more roads: a) Loss of habitats and division of landscape; b) leads to yet more traffic and more greenhouse gas emissions; increase in particulates and low-level ozone a danger to health.
Sizewell Link Road/Theberton bypass:  It’s not fair to shift the lorries from B1122 to someone else’s back door or over farmer’s land.  120ha of good grades 2 and 3 farm land lost with this proposed bypass – unacceptable.
The B1122 is not at capacity, therefore we do not need the ‘legacy’ of the link road.
It will be an invitation for yet more development.
16 currently quiet footpaths would be affected.  Ramblers do not want to cross a noisy fumy road.
Even with well-designed drainage there could still be toxic run-off in extreme weather, or spills.  Concern that this could pollute the small rivers that the road would cross, leading to the Minsmere River and on to Minsmere/Walberswick EU designated habitats and Ramsar.
No proper field surveys yet carried out – too few details supplied about impacts to wildlife and their habitats – and now too little time left to carry these out before intended submission of application in early 2020.
Speed limit of 50mph too fast for wildlife, e.g. barn owls, which would be killed on the road.  Wildlife have not evolved to deal with such speeds.  It should be 40mph absolute maximum.
RAIL-LED STRATEGY
If Secretary of State rules in favour of the project, then we would support a rail-led over a road-led strategy, as lower greenhouse gas emissions at a time when it’s urgent to cut down.
The ‘green’ rail route
Runs too close to Grade 1 listed Leiston Abbey and Pro Corda Music School.  Noise and vibration.  Spoilt setting.  Significant archaeological remains.
Secondary contractor’s compound next to Buckles Wood – ancient woodland, Biodiversity Action Plan (BAP) Priority Habitat with protected wildlife, especially bats.  Noise, dust, lighting very disturbing.  16 trees to be felled – EDF doesn’t say which.  Insufficient detail.
Route would be alongside Fiscal Policy woodland, Kenton Hills and into Goose Hill (main development site), commuting route of bats, some rare (Barbastelle).   All very sensitive ecological areas, with uncommon birds (Hobby, Cross Bill) and butterflies (White Admiral) and dragonflies (Norfolk Hawker).  Reptiles have already been moved.  No up-to-date surveys carried out.

Passing loop and track crossover
Improvements to East Suffolk line welcome, but at stage 2 we asked for the passing loop to be just south of Wickham Market station, where there used to be a double track and which would cause minimal environmental disturbance.  Instead, EDFE has chosen a site in a Special Landscape Area, close to the River Deben and on unploughed grazing marsh, where there are many ditches.  Grazing marsh a Biodiversity Action Plan habitat and should be enhanced and preserved.  No field surveys carried out, yet there must be water voles and other protected animals here. 
Reptiles use track sides for basking, particularly in rural locations, yet no plans to translocate them to a safer area.  Far too few details supplied – difficulty of commenting.
7. TRANSPORT: SIZEWELL HALT OR NEW RAIL SIDING
New rail siding would cause less disturbance to residents of King George’s Avenue and be more efficient for loading of freight.
8. BUCKLESWOOD ROAD
We oppose closure of this road (option 1).  A footbridge over the new ‘green’ railway line would be no use to the disabled.  Emergency services would have a longer route – safety compromised.  Businesses affected, especially Buckleswood Nurseries and Cakes & Ale caravan site. 
Option 2 (new level crossing) better.
9. TRANSPORT: LEVEL CROSSINGS
We support upgrades to the Saxmundham to Leiston line and safer level crossings.  We’d also like this line to be available to passengers and left as a legacy.
10. TRANSPORT: LEVEL CROSSINGS (RAIL-LED)
Network Rail’s role unclear.  Why are they not upgrading the level crossings and bridges on the East Suffolk line anyway?
Footpath closures:  Far too many and most diversions too long.  EDFE need to consult with local communities.  These paths part of our history and heritage.  Is this just the cheapest option for upgrading the East Suffolk line?
11. TRANSPORT: ROAD-LED STRATEGY, FREIGHT MANAGEMENT FACILITY
We’re against the road-led strategy, and this facility therefore unnecessary if rail-led.
Innocence Farm proposals: a nightmare for residents of rural village of Kirton.  Land farmed under wildlife friendly Entry and Higher Level Stewardship schemes.  Would be replaced with concrete and polluting lorries.  Adjacent to common land with footpaths – walkers deterred from using these.
12. TRANSPORT: PARK & RIDE
NORTHERN PARK & RIDE, DARSHAM
Local businesses: Moat Hall directly adjacent to proposals, currently a quiet retreat.  Total loss of business and quality of life for owner.  Same applies to B & B at White House Farm.  Can’t sell houses.
Wildlife:  Owls and bats resident in Little Nursery woodland on west side use proposed site, currently fields and hedges, for foraging and commuting.  These lost to concrete.
Farmland: Under wildlife friendly Entry Level Stewardship scheme.  Loss of wild flowers and invertebrates.  What compensation offered?
Pedestrians & cyclists: People walking/cycling from Darsham village to train station put at risk by extra traffic on A12.  Pavement needed.
Contamination: Despite SuDs drainage, contaminated run-off could get into Minsmere River from tributary and on into designated sites.
SOUTHERN PART & RIDE: WICKHAM MARKET
Both options for Wickham Market town totally unrealistic.
Option 1: Residents do not wish to lose their parking spaces in front of their houses in order to keep the main street clear for SZC traffic.  Why should they have to leave their vehicles in an inconvenient car park?
Option 2: Unworkable.  Proposed route via Valley Road and Easton Road totally unsuitable, even with upgrades, due to very narrow, weight-restricted bridge (Glevering Bridge), which is listed and cannot be altered.  In part in flood zone 3.  Dogs’ home on Easton Road – increased danger to regular dog walkers – pavement needed.
13: TRANSPORT: A12 TWO-VILLAGE BYPASS
Impacts on protected wildlife and habitats so severe we can’t support this.
Timing: Unclear how this would fit in with the councils’ plans for a four-village bypass. If this went ahead then EDFE would give equivalent money for two of the villages.  Councils’ request for government finance turned down.  Will re-apply but finance uncertain.  EDFE want to put their application in to Planning Inspectorate early 2020.  Time running out.
Loss of yet more habitats: Very sensitive ecologically and Special Landscape Area across River Alde, which would have to be bridged.  Two years since Stage 2, but still no field surveys carried out.  Negative impacts on great crested newts, otters, water voles and bats, all protected.  Loss of grazing marsh along river totally unacceptable – a BAP Priority Habitat to be conserved and enhanced.  Ditches rich in plants and invertebrates.  Breeding waders (Snipe, Lapwing, Curlew) and winter visitors (Whooper & Bewick Swans) depend on marsh.
Fragmentation: caused by new road to landscape and natural habitats.  Communities of animals divided and commuting routes of bats severed.
Speed: 50 mph much too fast.  Wildlife would be killed on road.  40mph absolute maximum.
Woodland lost/disturbed:  Foxburrow Wood an ancient woodland (BAP Priority Habitat) with high ecological value – bats, owls.  Protected badgers here at risk from traffic.
Landscape/heritage: Setting of Little Glemham Hall, Grade I listed, and Parkland, Grade II listed, negatively affected, also Grade II listed Farnham Manor.

14: TRANSPORT: ROAD IMPROVEMENTS
We support any improvements that improve safety.  Concern that so many new roundabouts would increase driver frustration.
15. CONSULTATION PROCESS
Disappointment that so little progress has been made since Stage 2, two years ago.  Still a chronic lack of detail and many field surveys still not carried out.  Too little time left to complete these (only one year before application goes in).  Difficult to make informed responses. 
Staff at exhibitions not always able to answer our questions as relevant expert not present.  All very unsatisfactory. 
The many problems can only be sorted out by not having SZC at all.

 

 

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