Response to the Fourth Stage Consultation of the Proposed
Development of Sizewell C Nuclear Power Station
This response is submitted on behalf of the Minsmere Levels Stakeholders Group (MLSG). Our primary objective is ‘To identify and then represent matters that are of common interest to those living and working in close proximity to the Minsmere Levels as well to others who have a concern for the future of the marshes’
In May 2014 the Secretary of State responded to the company’s Environmental Scoping Report setting out the areas on which much more detailed supporting evidence was required. These were, in the main, ones already raised by MLSG at Stage 1 relating to the impact both during the construction phase and long term on:
• The coast and shoreline to the north and south of the development
• The ground water systems within the Levels and Sizewell Marsh
• The Environmental Scoping Report Opinion (ESRO) required the following:
• Details of the baseline conditions for the main development site and identify land that could be directly or indirectly affected by the proposed development (ESRO 2.77)
• The SoS considers that the ES should not be a series of disparate reports and stresses the importance of considering interrelationships and cumulative effects (ESRO 3.19 and Appendix 3)
• The information should be presented so as to be comprehensible to the specialist and non-specialist alike.
• Any proposed mitigation should be well documented in terms of how it will be identified and then secured (ESRO 3.22) for example habitat mitigation (ESRO 3.44)
• The impacts on Sizewell Marshes and other nearby designated sites should be carefully assessed. (ESRO 3.76)
• Air quality and dust levels should be considered not only on site but also off-site, including along access roads, local footpaths and other PRoW (ESRO 3.78)
• The SoS advises that the inter-relationship between groundwater and surface water be presented clearly (ESRO 3.96)
1. The main area of the construction site is located within an Area of Outstanding Natural Beauty (AONB) and it is surrounded by two Sites of Special Scientific Interest, RAMSAR, a number of Special Protection Area (SPA) and Special Landscape Area (SLA) sites:
• 5.5 hectares of SSSI will be lost forever to the 55 hectare SZC platform development and construction damage to a further 3 hectares of SSSI
• The Aldhurst Site Habitat Creation site, whilst welcome, cannot in anyway be considered as adequate compensation for the ecological losses described above
2. We believe that in consideration of the issues raised by the Secretary of State in the ESRO and the lack of significant Preliminary Environmental Information Report (PEI) in the any of the four consultation stage documents. Our response to Stage 3 requesting a further public consultation was intended to allow the proposal to be better developed and the impacts and consequent mitigations proposed by EDF to be communicated through a much improved PEI to local and national statutory bodies, relevant organisations and the public so a properly considered view can be formed and communicated. We requested that this revised PEI should be a very advanced draft of the Environmental Statement which EDF intends to submit with its application for a Development Consent Order. Unfortunately, the Stage 4 documents, once again concentrates mainly on expanding EDF’s proposals and apart from some additional compensation proposals, does not address our request for more complete PEI.
3. We are disappointed that no further clarification has been given about the design of the hard coastal defence (HCD) and we remain concerned that as coastal erosion continues along this part of the coast, this hard point created by the HCD and beach landing facility (BLF) at the northern extreme of the site will contribute adversely to erosion along the northern flank of the site, in front of the proposed access causeway/culvert where the Leiston Drain flows north through the South Minsmere Levels to the Minsmere Sluice.
4. Issues with the HCD suggests that the site, as currently proposed, is too constrained to host two nuclear reactors. This is supported by the fact that EN-6 envisages single nuclear reactors to have a site size of around 30 hectares and Hinkley Point C operational site size is approximately 45 hectares. In order for SZC to reach a nuclear platform size of 32 hectares;
• Outage, training and visitor facilities for Sizewell B are proposed to be relocated, destroying a mature wood (Coronation Wood) and placing the SZB outage car park on Pillbox Field
• 5.5 hectares of Sizewell Marsh SSSI is to be permanently lost
• The proposal to add four 65-metre-tall pylons were introduced to create a connection between the generators and the National Grid Substation due to the lack of space to run connection cables through underground galleries as proposed in Stage 2 documentation. This proposal has been modified to reduce the height of three of the four pylons by 25% or alternatively introduce 5 pylons all at approximately 49 metres tall. As the pylons are built on the SZC platform itself, unlike the current National Grid pylons, these will dominate the skyline and have a permanent adverse visual impact for the AONB and Heritage Coast
5. This response should be read in conjunction with the Stage 3 response, attached as Annexe 1 to this document. We have modified our responses based on the content of the Stage 4 Consultation but where the responses in our Stage 3 are not repeated or modified here, they remain as our stated position.
Coast and Shoreline
6. In our Stage 3 response we note that EDF has done some modelling of a breach of coastal defences some 2-300m north of the position of the BLF. However, the model (Figure 2.12.5) does not take account of areas within Flood zones 2 and 3 immediately to the rear of the sacrificial dune (Figure 2.12.2) that would see the initial track of the breach proceed south to the position of the BLF and main HCD and then west along the northern edge of the site to the position of the Causeway/Culvert and the Leiston Drain.
7. We also noted that the existing sacrificial dune at the BLF position (close to the tank traps at the northern mound) is at the lowest point compared to points both north and south and would contribute to any such breach.
8. We note that in the Sizewell B Facilities Relocation planning application, they refer to a breach at the tank traps as being the worst-case planning scenario and proceed to look at the flood risk assessment (FRA) based on this breach point.
9. Given the eroding nature of the coast at this point, it is highly likely that the breach would occur in both places simultaneously. The flood zones that run behind the sacrificial dune to the Leiston Drain combined with HCD at the BLF and new northern edge of the platform would divert the breach inland to meet the Leiston Drain and the proposed Causeway/Culvert which is not armoured. Such a combination could seriously damage the Causeway/Culvert and if it were to become a permanent feature would have dramatic effects on the salinity in the South Minsmere Levels and the efficacy of the Minsmere Sluice. This has not been recognised in the model presented in the Stage 3 PEI or in the FRA that accompanies the SZB Relocation application.
Surface, and Ground Water Management
10. The comments in our Stage 3 Consultation Response remain unchanged.
11. The comments in our Stage 3 Consultation Response remain unchanged.
Spoil, Sand & Gravel Heaps
12. The comments in our Stage 3 Consultation Response remain unchanged
Adequacy of Preliminary Environmental Information Report
13. The inadequacy of the coastal breach modelling to take into account the actual landform as evidenced in the flood map referenced and the FRA from the SZB application, calls into question the impact of the HCD on the northern boundary of the operational platform and the potential for medium and long term adverse impacts on the causeway crossing of the SSSI which are not discussed at all in the PEI.
14. The other comments in this section of our Stage 3 Consultation Response remain unchanged.
15. Our comments in our Stage 3 Consultation Response remain unchanged.
16. We are deeply concerned that EDF have ignored requests from the Secretary of State, the statutory consultees, local parishes, town councils, many of the local NGOs and local interest groups to provide adequate preliminary environmental information regarding the effects of the construction and operation of the Sizewell C power station. The sensitive nature of the local designated sites and AONB is clearly at risk from this proposal and yet, there is little confidence, based on the information so far provided, that EDF is in a position to communicate their plans to protect and manage the project in a manner that is appropriate to the environment within which this project sits.
17. This Stage 4 consultation was a last opportunity (for a second time) for EDF to show that it is aware of the issues and has appropriate plans in place to manage the project based on a deep understanding of the hydrology, habitats, coastal geomorphology and potential for project impacts both locally and the wider area. It is deeply regrettable that this opportunity has been missed once again.
18. Our comments in our Stage 3 Consultation Response remain unchanged.
19. MLSG remains unconvinced that the current proposal makes an adequate case for a two reactor development on the 32 hectare platform as there are significant issues surrounding the HCD and the ability of EDF to manage all the elements into such a confined space.
20. MLSG supports the Environment Agency in their calls in their Stage 3 response for more complete Environmental Impact information in order that they can make an adequate assessment of the proposal
21. MLSG supports the SCDC and SCC in their response regretting that insufficient information has been provided to adequately respond to the consultation and assess whether the proposal provides a sustainable benefit for the community and county as a whole. Unfortunately, this request and lack of response from EDF has been characteristic of all stages of consultation over the past 8 years and it is regrettable that we will have to wait until the Development Consent Order application to get a real view of the impact of this development, even though we can see that the impact to the surrounding designated landscapes and cost will be significant and long lasting.
22. Except for items 55, 60 and 61, our comments in our Stage 3 Consultation Response remain unchanged.