1. That East Suffolk Council responds to the EDF Energy Stage 4 consultation, and that it continues engagement with Government and key partners as set out below. This set of recommendations is aligned to a report being taken to Suffolk County Council’s Cabinet on 24 September 2019.
2. That it be agreed that the response set out in detail in the Appendix and summarised below will be submitted jointly, following its agreement by Suffolk County Council on 24 September 2019.
3. That EDF Energy be informed that, in line with the position agreed at the Cabinet Meeting on the 11 March 2019, the Stage 3 representation submitted by Suffolk County Council and (then) Suffolk Coastal District Council, and the response submitted by Waveney District Council remains valid with additional comments raised in the response in the Appendix.
4. That this Council welcome EDF Energy carrying out a Stage 4 public consultation and the opportunity to comment on revised / updated aspects of its proposals. However, it is disappointed that EDF Energy has not taken this opportunity to respond to key elements of concern raised in our Stage 3 response as detailed in paragraph 8.59 of the report.
5. Based on the new information put forward in the Stage 4 Consultation, this Council wishes EDF Energy to particularly address the following points:
a) As highlighted in the joint Stage 3 response, this Council expects EDF Energy to use a deliverable sustainable transport strategy to transport materials to/from the site. Unless there is strong appropriate evidence and justification, deviation away from a sustainable transport strategy should be considered to be unacceptable and this Council continues to expect maximising the use of marine- and rail- based transport to transport materials to / from the site. This Council is disappointed that Stage 4 suggests that the lack of progress on the rail-led strategy is now jeopardising delivery of this option.
b) Based on the above, this Council expects EDF Energy and other stakeholders including Network Rail to prioritise pursuing the rail-led strategy and confirms that we will support EDF Energy where required in pursuing a rail-led strategy above alternative road-led options. This Council expects EDF Energy to provide proportional mitigation to address its impacts at locations where their traffic is exacerbating a capacity or road safety concern, most prominently at the A12 in Woodbridge, but also other locations to the North of Woodbridge.
c) This Council expresses its continued opposition to four new tall pylons to the development site, which would have considerable detrimental impact on the AONB, and the options presented at Stage 4 do not appear to significantly reduce this impact;
d) This Council is pleased to see revisions to the layout of the Land east of Eastlands Industrial Estate (LEEIE) but expresses concern about the continued lack of detail in particular in relation to surface water drainage solutions for the site.
e) This Council welcomes the additional ecological mitigation and compensation areas, for Fen Meadow and Marsh Harriers, but is concerned that the feasibility of these sites cannot be evidenced and overall ecological mitigation and compensation for the whole Sizewell C DCO remains insufficient.
f) This Council welcomes the identification of flood compensation areas but will rely on the Environment Agency to provide expert advice as to their suitability, size and locations. Further detail is required for this Council to comment on the environmental impacts of these options.
g) At Stage 3, this Council was content with EDF Energy’s explanation for their selection of the route of the Sizewell C Link Road. We did not consider there was any value in removing the Link Road post-construction, we recognise the legacy benefit of a Sizewell Link Road in providing a direct HGV link to the existing Sizewell A and B sites as well as the proposed Sizewell C station.
h) This Council welcomes the commitments made for project and economic benefits of the programme including the Community Fund, but requiresfurther work related to the increase workforce number of 8,500 and its impact and required mitigation on local housing and tourism accommodation, workforce displacement, health and other socio-economic issues.
6. That the Head of Planning & Coastal Management in consultation with the Deputy Leader and Cabinet Member with responsibility for Economic Development be authorised to make any amendments to the draft response as agreed with the appropriate representatives of this Council.
7. That this Council engages with EDF Energy and Network Rail, and where appropriate the Department for Transport, to identify and remove barriers to delivery of the improvements to the East Suffolk Line and hence timely implementation of the rail-led strategy, whether this is through the DCO process or Transport Works Act Order.
8. That Cabinet notes the continued work with Government, namely Ministry for Housing, Communities and Local Government (MHCLG) and BEIS with regards to cumulative impacts in East Suffolk of the numerous energy related projects existing and forthcoming.