3
Cabinet received report ES/0155 by
the Deputy Leader and Cabinet Member with responsibility for Economic
Development who reported that EDF Energy was proposing to build a new
nuclear power station at Sizewell. Following the Stage 3 consultation at
the beginning of the year, which was discussed at Cabinet on 11 March 2019, a
fourth round of consultation on specific elements of the proposal had been
launched.
The report before Cabinet set out a
summary of the draft response to EDF Energy’s Stage 4 consultation, with the
full draft response in the appendix. It was proposed that Suffolk County
Council and East Suffolk Council, both statutory consultees in the process,
submit a joint response to the consultation, as they had done in the three
previous consultation stages. It was considered that such a joint
response would give greater weight to the views of the two councils.
It was expected that EDF Energy would
formally submit an application for development consent early in 2020 that
would be determined by the Secretary of State for Business, Energy and
Industrial Strategy (BEIS) following examination by the Planning Inspectorate.
The primary purpose of the report
before Cabinet was to explain the key changes in the proposals compared to
Stage 3 and propose a stance on the topic areas. The report also updated on the
progress that the councils had made putting the case for Suffolk to
Government. A particular issue within this was the cumulative impact of
all the planning issues arising from all the national infrastructure projects
in East Suffolk and the representations the Councils would make to Government.
The report also considered the next
steps for the councils and it included consideration of a consultation by
BEIS, on the “Regulated Asset Base” funding model which was proposed to be used
for Sizewell C.
The councils’ report was prepared after
a community consultation event with the parish councils on 26 July 2019 and,
alongside representations from local residents, drew upon their advice and
local understanding. The councils had also discussed the issues raised by EDF
Energy with other statutory consultees. The councils were referencing
existing work and understanding arising from membership of the New
Nuclear Local Authority Group (NNLAG), this included reference to the draft
version of a longitudinal study funded by NNLAG regarding impacts of Hinkley
Point C which was in its final stages but not yet published.
Evidence to support the
recommendations was set out in the main body of the report with further
technical detail contained in the Appendix.
Cabinet was advised that Suffolk County
Council was taking a similar report with the same response attached to its
Cabinet meeting on the 24 September 2019.
The
Deputy Leader and Cabinet Member with responsibility for Economic Development
stated that he welcomed the stage 4 consultation and the opportunity to
comment. He was, however, disappointed that the opportunity
had not been taken by EDF Energy to clarify and fully evidence more of the issues
raised by the councils at Stage 3, and previous, leaving the councils
unable to come to an evidence-based view on so many matters. Amongst many
other issues the councils were particularly disappointed that the issues
referenced within paragraph 8.59 had not been addressed.
The Deputy Leader and Cabinet Member
with responsibility for Economic Development and the Head of Planning and
Coastal Management summarised the contents of the report, stating that East
Suffolk had hosted nuclear power at Sizewell since Sizewell A, which was
commissioned in 1966. Sizewell B was the UK’s only commercial pressurised
water reactor and was commissioned in 1995. It was still generating
now, it was anticipated that its lifetime would be extended by 20 years, taking
its forecasted decommissioning date to 2055. Sizewell A currently had 170
staff on site and managed the Bradwell B site which was now in its
care and maintenance programme. Sizewell B currently had 544 members of
staff and around 250 contracting partners, it added approximately £20m to
the local economy which doubled during an outage. Sizewell C (two
reactors) was forecast to have 900 operational posts, it was expected to put at
least £100m a year into the regional economy during construction and £40m
a year during each of its 60 years of operation.
In respect of key areas for
consideration related to the main elements of change, it was reported that
there was an alternative freight management option – integrated strategy; there
was an alternative approach for traffic management through Wickham Market (no
details yet); there was a new option for a rail-head at land east of Eastlands
Industrial Estate; the Sizewell Link Road would possibly be removed
post-construction; flood mitigation areas; ecological mitigation areas; 7900
plus 600 workers proposed (no longer sensitivity testing); and red line changes
across the project’s main development site and associated development
sites.
Cabinet was advised of the three
transport options proposed – rail-led, integrated, and road-led. The main
issue of concern for East Suffolk Council was the rail line, there being
significant concerns regarding noise and vibration.
Cabinet was advised that another
element of concern was pylons, there were currently two options, option 1 – four
pylons, three reduced in height by 25%, and option 2 – five pylons, all reduced
in height by 25%. Neither were attractive to the
councils.
Cabinet was further advised of
other additions since the Stage 3 consultation, there were two compensation
areas to mitigate loss of floodplain at the SSSI crossing; up to three
potential Marsh Harrier mitigation areas; and proposed Fen meadow mitigation
(loss of SSSI).
Other minor changes included
confirmation of offsite sports facilities at Leiston Sports Centre / Alde
Valley Academy; minor changes to red line at the main site (ie at the entrance
roundabout, which included Round House; minor changes to the red line at
AD sites (link road, 2VBP, park and ride sites, freight management facility,
junctions) to reflect further design work including water management; and the
Yoxford Road roundabout, move by 20 metres, which EDF Energy suggested would allow
offline construction.
In respect of social and economic,
mitigating impacts, there were references to embedded environmental principles
and mitigation for the project; project benefits including minimum 1000
apprentices, work with Suffolk colleges and businesses, aim to meet nuclear
sector target of 40% female workforce; reference to a Community Fund to promote
the economic, social and environmental well-being of communities; and property
support, work with local potentially affected residents to explore alternatives
to statutory blight claims.
Cabinet was advised that there were
several things missing from the consultation: There was no reference to
changes to development on Goose Hill, a key concern for the councils at Stage
3; response to network highway issues raised by the councils at Stage 3, ie
Woodbridge contribution and other junctions ie Bredfield; response to
consultees comments on public rights of way level crossing closures in rail-led
option; details of construction programme and delivery of associated sites;
removal of a marine-led strategy; no response to concerns regarding
coastal processes, beach landing facility, SSSI Crossing, and Northern Mound;
plus other issues as referred to in paragraphs 354 to 376 within the
report.
Cabinet was apprised of areas of
difference between the East Suffolk report and the Suffolk County Council
report; the recommendation was very similar between the two councils, but the
response differed in two sections: The Sizewell Link Road: East
Suffolk Council considered that should a road-led strategy be considered above
a marine or rail-led strategy that the route demonstrated for the Link
Road was potentially acceptable subject to further detailed studies and
assessments. Also, in respect of retention of the Sizewell Link
Road post-construction, East Suffolk Council continued to not support proposals
to remove a Sizewell Link road and recognise the benefits of a separate
HGV route to serve the existing A and B stations as well as the new C
station.
The Cabinet Member with
responsibility for Customer Services and Operational Partnerships referred to
the rail and road options, with extended hours for HGVs, possibly 24 hours a
day; he requested further information in respect of this. The Head of
Planning and Coastal Management explained that, at this time, nothing had
been agreed in respect of overnight generation; significant discussions
was required and dialogue was taking place with EDF Energy.
The Cabinet Member with
responsibility for the Environment stated his concerns regarding
insufficient mitigation; he asked if there would be an
analysis to ensure that this was strengthened. The Head
of Planning and Coastal Management responded, stating that
officers would be working diligently on this and the Deputy Leader and
Cabinet Member with responsibility for Economic Development added that
consultants would be utilised as necessary.
The Cabinet Member with responsibility
for Planning and Coastal Management stated that the report made it clear that
what was planned for coastal defences was not certain; he was concerned
regarding this. The Head of Planning and Coastal Management, in response,
stated that there was a lot of ongoing dialogue, in particular trying to
understand what EDF Energy's proposals were; officers had not yet had sight of
all of the proposed details in relation to coastal processes. There were outstanding concerns related
to the position of the station platform and there were potential amenity
impacts with the future predicted loss of beach. These issues were raised during the
stage 3 consultation. All matters would be addressed as part of
EDF’s application for development consent. The Head of
Planning and Coastal Management, in conclusion, stated that officers were
working diligently on this matter.
Councillor Haworth-Culf stated that
she could not find a reference to coach movements within the
report. This, she stated, alongside HGV movements, was an important
issue. She asked for confirmation of the proposed numbers, on a
daily basis, together with mitigation information. The Head of
Planning and Coastal Management stated that coach movements were included
in the transport assessments; his understanding was, he stated, that
there would be 400 movements a day, 200 in and 200 out. It was explained
that this was not part of the current consultation because nothing had
changed since previous iterations.
Councillor Bond asked, in the light of
the lack of information, if it was felt that the joint proposed
response was sufficient to protect the area, bearing in mind rising sea levels
and the impact, ie health, wellbeing and tourism, that would be felt by
everyone in the area. The Head of Planning and Coastal
Management stated that it was believed that the response was adequate. He
added that Cabinet should bear in mind that this was a process
undertaken by EDF Energy, the Council was just a consultee in the process.
It was, he stated, incumbent upon EDF Energy, in their application
in 2020, to include all the information so that the Secretary of State
could make a reasoned decision. The Head of Planning and
Coastal Management added that if the application was submitted without
that information, that would be the appropriate time for the
Council, if it so wished, to make comments in relation to
that.
Councillor Haworth-Culf referred to the
many East Suffolk Council policies that referred to the importance of
tourism for the district; she asked for an assurance that these
policies would be reviewed and, where appropriate, be updated to reflect
what would happen with Sizewell. The Head of Planning and Coastal
Management stated that tourism was indeed a key factor and the Council would need
to assess the impact on this. The Head of Planning and
Coastal Management referred to the National Policy Statement and
said that this was written in a way that made it clear that there were
eight sites nominated across England and Wales and there was
the presumption that they would be delivered to provide energy in the
country. That was the context against which the Council should assess the
local impact, in the best and most positive way.
The Leader stated that the
Council needed to be realistic and pragmatic in its approach and that
that would involve commitment and compromise; it also needed to be honest with
the public. He stated that the report before Cabinet was a culmination of
many hours of work by officers and he gave thanks for that.
The Assistant Cabinet Member with
responsibility for Transport stated that she did not think the roads in
Suffolk could cope; in her view they were not big enough, and this was a
concern for her.
The Cabinet Member with
responsibility for Customer Services and Operational Partnerships stated that,
in his view, the Council was faced with a double edged sword; Sizewell C
offered huge economic benefits to the area. It was, he said, a slightly
worrying proposal that was put to the government in 2018 about funding a four
villages bypass. This August, statistically, had been the busiest time
for road capacity on the A12, more than ever recorded, so, mitigation was
needed in respect of the road network. Sizewell C was, Councillor Burroughes stated, a huge
opportunity for the district’s tourist economy; he stated that, in fact, people
had been going to Hinkley to view the construction. There were
many benefits to having Sizewell C but, clearly, that would come with
disadvantages. The benefits must outweigh the disadvantages.
Councillor Burroughes added that it was critical that Suffolk County
Council and East Suffolk Council worked together. Councillor
Burroughes, in conclusion, stated that he was happy to support the
recommendations within the report, pending clarification of the
issues outstanding; he hoped that officers wold press EDF Energy to obtain the answers
that were needed.
The Cabinet Member with responsibility
for the Environment stated that he was mindful that East Suffolk Council would
achieve the best deal possible for its residents. The environment was not
just trees and grasses, it was also about buildings and infrastructure
work. Councillor Mallinder stated that the Council needed to be
mindful of what the UK was trying to achieve in trying to be carbon
neutral. A diverse portfolio of energy was needed and nuclear had
to be part of that. However, Councillor Mallinder stated that he had
reservations regarding the proposals and he felt that mitigation needed
working on.
Councillor Mallinder stated that
he was concerned regarding the accommodation for workers; he did not
understand why EDF Energy was not proposing a futureistic way of living, a zero
carbon footprint, electric bikes, cycle routes, and electric cars. Councillor Mallinder stated that transport was also a
concern for him; priority should be marine first and roads last. In
conclusion, Councillor Mallinder stated that he wanted something, for East
Suffolk, in return for Sizewell C; he wanted to see more investment by national
government in helping East Suffolk deal with these big issues. That said,
Councillor Mallinder stated, East Suffolk would need to be careful not to take
this project at any cost. Councillor Mallinder stated that today should
be protected in order to ensure tomorrows were secured.
Councillor Haworth-Culf thanked all
members of the public who had responded to the consultation; she added that
the devil was in the detail and she felt that sufficient
detail had not been received. Councillor Haworth-Culf stated
that it must be ensured that, when more detail was received, it be
communicated out to those who had responded. She added that
the benefits of Sizewell C must outweigh the negatives; there would be a
huge impact on the area and East Suffolk Council must represent the
views of the public.
Councillor Smith-Lyte stated that
she echoed the views of many of her colleagues; she said that if Sizewell C was
allowed to go ahead the tourists would stop coming to the area; she
referred to Sizewell C being hugely expensive and stated that, by the time
that it was built, the technology would be redundant. Councillor
Smith-Lyte stated that mitigation should not keep endlessly
happening and she also said that wildlife were territorial and needed
space.
The Leader stated that Members must
remember that they were there to consider the Council’s response to the
consultation; it was not within the Council’s power to say yes or no to
Sizewell. He believed that the draft response was sensible,
realistic and balanced in its approach, but he acknowledged that a lot
more detail was needed. In conclusion, the Leader stated the
importance of achieving the best deal possible.
The Deputy Leader referred
to the earlier comments in respect of whether the Council was being
robust enough in its response; he believed that it was, and referred to a
balanced, evidenced based approach. He believed that the Council needed
to be fair and take this approach; he believed that if the Council asked for
too much the Planning Inspectorate would disregard its comments.
The Deputy Leader gave thanks to Geoff
Holdcroft, who had been a former chairman of NNLAG; he also thanked colleagues
from Suffolk County Council for working together on a joint response and he
gave thanks to officers for their work.
In conclusion, the Deputy Leader
reported that an Equality Impact Assessment had not been undertaken as
East Suffolk Council was responding to the planning proposals of EDG
Energy Energy. As such, EDF was required to satisfy the EqIA requirements.
RESOLVED
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 requires further 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.