Sizewell Consultation Report
EDF Sizewell C Second Consultation – response from Darsham Parish Council
1. Overall comment
This second consultation is, in practice, the final opportunity for public consultation on EDF's proposals, as the third consultation will effectively form the application to the Planning Inspectorate for planning consent. Following the first consultation, this Council made various comments and our neighbours expressed serious concern about the impacts of EDF's proposals on local communities; these appear to have been largely ignored. In addition there is still a distressing lack of detail, particularly on the Environmental aspects of the proposal, to enable a considered response. This must remain a cause for real public concern.
2. Principle issue for Darsham – Transport related issues
The principle issue directly affecting Darsham is the proposed location of the Northern Park and Ride. We are concerned about the following:
2.1 The location of the entrance and exit.
In the first consultation this was shown near the level crossing. Our response suggested locating it off Willow Marsh Lane. EDF say this is not possible because Willow Marsh Lane has a 60mph speed limit, and the entrance/exit has been moved north of the Garage on the A12. We believe this is still a recipe for traffic chaos, bearing in mind increased frequency of level crossing closure, the proposed 80 bed motel next to the garage, plus existing garage traffic and increased use of the A12. We are also concerned at potential air pollution levels as a result of the build-up of stationary traffic on the A12 in the Yoxford and Darsham areas.
We repeat our suggestion that an entrance /exit should be considered on Willow Marsh Lane, together with imposition of a new speed limit, and suitable traffic management measures, such as a roundabout.
2.2 Impact of lighting on dark sky area.
Darsham and surrounding area is a dark sky area and home to a thriving astronomical society (DASH Astro.). The village has previously voted against the installation of street lighting and retention of our dark sky is important to us. The consultation document speaks about “low impact lighting” but we would like to see much more detail about lighting proposals.
2.3 Legacy car park.
In our response to the first consultation we asked for a small car park as a legacy for local people, which could be built at the start of the construction period: we repeat this request.
2.4 Rat- running down local roads.
It is inevitable that some vehicles will use local roads, and we have particular concerns about The Street and Westleton Road. Preventative measures to address rat-running are not detailed in the document, though the use of automatic number plate recognition (ANPR) was put forward in discussion at local consultation meetings. The main problem with ANPR is that it is retrospective and will only apply to HGVs.
We suggest that a number of compatible measures should be considered in addition to ANPR eg imposition of an appropriate weight limit, width restrictions and appropriate signage.
This problem is also of great concern for Westleton with Sizewell traffic taking the B1125 from the A12 at Blythburgh, and for villages between Stowmarket and Yoxford along the A1120 with Sizewell traffic taking the shortcut from the A14 at Stowmarket. This is a popular tourist route and the tortuous nature of the road already makes it highly unsuitable for HGVs. Special measures are required to prevent Sizewell traffic using this route.
EDF say that if there is a problem on the A12 or B1122 they will direct traffic on to “diversionary routes”. No information has been given on where those routes will be, but it is obvious they will be on adjoining lanes and through adjacent villages causing enormous traffic congestion. So, even if proposals to prevent rat-running are implemented, local villages can look forward to a huge increase in traffic during these diversionary periods.
2.5 Related traffic issues A12
Darsham PC supports proposals for a four village bypass. The consultation document persists in restricting the options for A12 improvements and we urge EDF, together with Suffolk County Council, Suffolk Coastal District Council and the Department of Transport to co-operate to make the most of this opportunity for major long-term improvements to the A12.
2.6 Related traffic issues B1122
However, even if the bypass goes ahead, all this will do is transfer traffic congestion to Yoxford and the A12 junction with the A1120 and B1122. EDF recognise the need for junction improvement at Yoxford, but their proposals appear inadequate given congestion which already occurs at this junction at busy times. EDF propose either a signalised junction or a new roundabout for the A12/ B1122 , which completely ignores the adjacent junction between the A12 and A1120. This is a recipe for traffic chaos. There are major concerns that EDF traffic surveys have not been conducted at busy times eg. holiday weekends, and that increased traffic flows on the A1120 have not been taken into account.
The problem is that EDF continue to promote the use of the B1122 for all Sizewell traffic. EDF say there will be up to 900 HGV, 700 LGV movements a day between 06.00 and midnight, plus buses, workers cars and existing increasing traffic, creating noise, pollution and vibration impacts on the communities at Yoxford, Middleton Moor, Theberton and Eastbridge.
2.7 Sizewell Relief Road
A new Sizewell Relief Link road such as the D2 route, originally proposed for Sizewell B, would solve all these problems.
The D2 route leaves the A12 at Benhall, and runs direct to Sizewell. EDF are not currently considering this option on grounds of cost. (Approx £60 million compared to £30 millon for their proposed improvements to the B1122 route.) The D2 route impacts on a small fraction of households as compared to the much wider impacts of the B1122 route.
Since EDF estimate that 85% of the HGV traffic bound for Sizewell will come from the south, construction of the D2 option would alleviate pressure on the A12 between Saxmundham and Yoxford, the junction with the A1120 at Yoxford, and preserve the quality of life for those living in the vicinity of the B1122 between Yoxford and Leiston for the entire 12 years of the construction period. We think this option needs serious consideration.
2.8 Implications for Darsham
If the D2 route were to be adopted it would call into question the location of the proposed northern park and ride near Darsham Station: a new location west of the A12 near Saxmundham would make considerably more sense.
3. Temporary accommodation proposals for workforce
Current EDF proposals are for a temporary encampment for 2400 workers near Eastbridge. The impact on this tiny village are hard to imagine. Darsham agrees with all our neighbouring villages that both the location and size of the worker camp are unacceptable. At Hinkley Point the worker accommodation has been split over three separate sites, including one at Bridgewater, 10 miles away. While accepting that some temporary accommodation will be required, it would seem much more sensible, and cost-effective, to build some permanent accommodation on the outskirts of Leiston and closer to Sizewell itself. Take for example the Olympic Park at Stratford, where athlete's accommodation has been transformed into both open market and affordable housing. This option would fulfill the need for more homes in the area in the next decade and provide a long term housing legacy for Leiston and the Suffolk Coastal area. EDF show in Stage 2 a workers caravan park close to Leiston - why cannot this be permanent accommodation including a training facility for young people? We would urge discussion with appropriate Councils to consider this option.
4. Community issues
4.1 The impact on local services, schools and medical facilities does not appear to have been addressed in the consultation. These facilities are already under significant pressure from existing housing developments in Saxmundham and surrounding villages. This aspect requires detailed proposals from EDF in conjunction with the appropriate councils and agencies.
4.2 The impact on the community as a whole, on their daily life in the widest sense, but particularly on workforce behaviour and policing has not been addressed at all. This omission needs to be rectified.
5. Construction issues and impact on tourism
EDF estimate that spoil heaps up to 35m in height (height of the Orwell Bridge) will be created over the first two years of the construction phase. Their visual impact is likely to seriously impact
visitor numbers at both RSPB Minsmere, Dunwich Heath (NT) and the surrounding parts of the AONB that attract thousands of visitors to the area and support much of our local economy. While this may be partially offset by business created by Sizewell, further studies are required, together with proposals for compensating businesses adversely affected by the development.
5. Environmental issues
The Sizwell construction site sits in the middle of an AONB and is surrounded by areas of the highest conservation designation. It is therefore absolutely vital that the likely environmental impacts are thoroughly and vigorously investigated. To quote the National Trust:
“Proposals for Sizewell C need to be an 'environmental exemplar' supported by a robust Environmental Impact Assessment”
The second consultation document does not demonstrate that level of confidence, and is lacking in any detail on a number of issues of serious concern:
- the impact of the proposed jetty construction on offshore currents and coastal erosion
- proposals for flood defence measures given rising sea levels and risks of tsunami
- proposals for borrow pits (quarries) to locate poor material from the construction site and likely polluting run-off into the Minsmere levels
- provision for surface water run-off in periods of intense rainfall, due to climate change
Although EDF say that studies with appropriate agencies are ”ongoing” there are no details in the consultation document and it is absolutely essential that these are completed and independently assessed for their adequacy before final consent for the development is given.
Darsham Parish Council
17th January 2017