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EDF Energy’s Sizewell C Stage 2 consultation.

The following response is on behalf of the 165 members and supporters of Suffolk Coastal Friends of the Earth.

1. What are your overall views on the proposals?

Climate change: Bearing in mind the very long time frame until SZC would be finally decommissioned (c. 2180), and considering that nuclear waste may have to be stored at Sizewell indefinitely while a deep store is unforthcoming, the developer has not presented fully worked-out scenarios concerning the increasing vulnerability of the nuclear power stations as sea levels rise and storms increase. As all local people know only too well, this coastline is one of the most rapidly eroding anywhere in the world.

Moreover, while storm surges are acknowledged under 7.5.36 of the Consultation Document along with ‘significant erosion’, no calculation has been put forward of their likely increasing frequency nor specific details of impacts and how these would be managed. It is completely inadequate to say ‘appropriate contingency planning arrangements would be developed in advance of these works, including appropriate monitoring and mitigation measures’. Our members are left wondering: what contingency plans, what kind of monitoring and what sort of mitigation measures? We are not convinced that SZC would be safe under the changing conditions.

The Marine Management Organisation (MMO) acknowledges that nuclear power stations are particularly at risk from sea level rise, which ‘can result in more flooding, coastal erosion and the inundation of coastal regions…. It reduces the return period for extreme water levels and threatens existing coastal ecosystems…This is a particular concern for coastal infrastructure (e.g. nuclear power stations with life cycles that could exceed 100 years)’ (MMO, March 2016). The Consultation Document does not identify the high-risk scenarios within the long term time frame.

The Sizewell and Dunwich Banks: The developer continues to maintain that SZC would be protected by the offshore Sizewell Bank. Suffolk Coastal Friends of the Earth dispute this. Recent scientific papers demonstrate that the two banks, which were formerly joined together, have more recently been parting, leaving a ‘col’ between them through which large waves can penetrate under storm conditions, causing erosion to the shore. This is exacerbated by the fact that the two banks have lowered in height. (See in particular Pye & Blott, 2006) EDF Energy needs to acknowledge these changes and the likely impacts over the long term.

2. Main development site: Environment

 

 

Mitigation offered

The new habitat at Aldhurst Farm is being offered by way of compensation, but this is an artificially constructed habitat that will never compensate for what would be lost, particularly wet woodland and fen meadow. The habitat is too close to human habitation, unsuitable for ground-nesting birds which would be disturbed by walkers. There is no guarantee that it would ever receive an SSSI designation, which can only be conferred by Natural England.

3. New access road and SSSI crossing

 

4. Managing construction materials/borrow pits and stock piles

None of these options is acceptable.

5/6. Your views on the accommodation strategy

The campus

Use of tourist accommodation

Purchase of houses

This is likely to push up prices, already very high throughout Suffolk. There is an urgent need locally for low-cost housing. An influx of permanent workers and their families will make stepping on to the housing ladder even more difficult for local people.

 

7. Transport, overall strategy

8. Rail

How would the additional trains fit within the overall network? This is not explained.

Option 1, temporary rail extension (Green route)

Option 2, new rail terminal, E. of Eastlands Industrial Estate

9. Sea transport

Options 1 and 2, temporary wide or narrow jetties

Option 3, beach landing facility

10. Transport, park & rides

South, Wickham Market

North, Darsham

11. Road improvements to A12

12. Road improvements, Yoxford, B1122

13. People & economy

14. Consultation process

Conclusion

Overall, the destruction and damage to our special landscapes, designated habitats and protected species would be so severe that members of Suffolk Coastal Friends of the Earth are unable to support any aspects of these proposals.

We would particularly like to point out that the site must be tested against the other nominated sites within the National Policy Statement EN6. This is set out at paragraph 2.4.4:

‘Given the very limited number of sites identified as potentially suitable for the deployment of new nuclear power stations before the end of 2025, the Government considers that all eight are required to be listed in this NPS. This is to allow sufficient flexibility to meet the urgent need for new nuclear power stations (see Part 3 of EN-1) whilst enabling the IPC to refuse consent should it consider it appropriate to do so.’

Clearly, the Sizewell site should be tested against the other potential sites. It would not be difficult to show how unsuitable it is. The planning application should be refused.

Rachel Fulcher, Coordinator

REFERENCES

Marine Management Organisation, March 2016: Potential spatial effects of climate change in the South and East Marine Plan Areas.

Pye,K & Blott, SJ, 2006: Coastal processes and morphological change in the Dunwich-Sizewell area, Suffolk, UK.

Category: Stage 2 Consultation Responses