Darsham Parish Council's Submission to Planning Inspectorate with reference to EDF's DCO for Sizewell C and D

 

April 2021

Darsham Parish Council's final submission to the Examing Authority

  1. Introduction and scope of submission.

While Darsham Parish Council (DPC) shares the wider concerns about the impacts of EDF's proposals on  transport, environment and tourism with the majority of local Parish Councils, and supports the views  of the Environment Agency and national and local conservation groups, our submission concentrates on the siting and impacts of the Northern Park and Ride (NPR) which is located within the Parish Council boundary.

  1. Consultation responses.

The concerns listed below have been detailed in our responses to each of the four consultation stages carried out by EDF. It is fair to say that these detailed concerns, which are shared with other local parishes, have been largely ignored. As such, the term “consultation” is a complete misnomer. However, a team from EDF held a Zoom meeting with representatives from DPC in February 2021. Remarks from that meeting are incorporated below. 

  1. Traffic flow and congestion (1)

It should be noted that the traffic flow data survey carried out by the applicant is suspect, in that it was taken mid-day, mid-week during “lockdown” when road volume was minimal.  Clearly this was not representative, understating both the realistic volumes and vehicle mixes.

EDF have consistently underestimated traffic flows on the A12.  The A12 is a single carriageway road in this part of Suffolk and extremely busy with tourist traffic for large parts of the year.  As such any road works or traffic accident is likely to cause major congestion. This was vividly demonstrated in summer 2020, with increased traffic volumes due to the COVID-19 pandemic and a considerable increase in tourism “staycations”. On two occasions, (one accident, one road repair) slow-moving traffic has tailed back five miles to Saxmundham. In addition, slow moving agricultural vehicles often cause long tailbacks.

  1. Traffic flow and congestion (2)

EDF project 1,140 private car, 700 minibus and 700 HGV movements each day.  The proposed construction of roundabouts at the NPR junction at Willow Marsh Lane and at the B1122 junction in Yoxford, will cause congestion on this whole section of the A12.  Darsham has increased in size by 30% in the last few years. The proposed development of a further 120 houses accessing the A12 near the Westleton Road, an 80-bedroom motel adjacent to the Jet Garage, 170 holiday lodges on the grounds of High Lodge, and the proposed increase in train numbers and level crossing closures will greatly exacerbate this congestion. 

EDF do not accept our assertion that their traffic estimates are understated, a concern shared with Suffolk CC, nor do they accept that the NPR will lead to the gridlock that we anticipate.

  1. Level crossing closures

The level crossing is closed overnight for routine maintenance at regular intervals, with traffic diverted down The Street through Darsham village. EDF have chosen to ignore this and not responded to our requests for alternative proposals or mitigation arrangements.

  1. Dark skies

Darsham is a dedicated dark sky village and home to the Darsham and Surrounding Villages Astronomical Society (DASH – Astro).  EDF propose low level lighting in the NPR, but mandatory Trunk road lighting on the NPR roundabout will destroy this amenity.

  1. Rat-running & fly parking

DPC have expressed concerns about rat- running down The Street during traffic congestion on the A12 or during level crossing closures. EDF say they will install ANPR cameras to detect and subsequently ban HGVs, but have made no proposals to control LGVs and private cars. As evidenced at Hinckley C, residents have had to endure fly parking of epidemic proportions.

  1. Noise and pollution

DPC have serious concerns about traffic noise, vibration and pollution* (NOx, CO2 and particulates) as a result of congestion from increased traffic movements from the NPR, HGVs on route to Sizewell, all in addition to existing A12 traffic.

EDF have dismissed these concerns.

  1. Legacy provisions

There are no proposals for pedestrian access to and from Darsham Station and the NPR. Pedestrians will have to walk along the A12 whilst at night there is no low level footpath lighting planned. There are no legacy provisions for improved carparking at Darsham Station which was specifically requested by DPC.

We understand from EDF that future restoration of the NPR site may preclude these provisions.

  1. Geology, drainage and flood risk   (Additional Report now added)

New research information has revealed that there could be drainage and flood risk problems associated with the NPR.  EDF have proposed a storage basin with overflow to existing watercourses running under the railway. The underlying geology prevents natural drainage within the site and is likely to lead to existing water courses being overwhelmed in heavy rain.

EDF do not appear to acknowledge the potential flood risk to the railway (due to run-off from the NPR)

  1. Traffic constriction

Likely traffic flows associated with the NPR and direct Sizewell traffic, in addition to existing A12 traffic will lead to serious congestion exacerbated by the construction of two roundabouts, local development and particularly, increased level crossing closures. The resulting noise, vibration, air pollution and rat-running and fly parking on side roads will seriously erode local residents' quality of life.

These concerns have either been ignored or dismissed by EDF and no mitigation measures proposed.

  1. Summary

Taken as a whole, Darsham Parish Council conclude that siting the NPR north of Darsham Station on a single carriageway section of the A12 adjacent to a level crossing is a serious mistake. (The Southern Park and Ride is located off a dual carriageway).  If the NPR proceeds as currently proposed, it will have a serious impact on the quality of life of the residents of this Parish and, in the absence of any mitigation measures,  their right to the quiet enjoyment of their village and surrounding environment.

Darsham Parish Council

(CP & MS)

 

Additional Report – NPR Geology, Drainage & Flood risk

The Darsham Park & Ride as you will know is wedged between the A12 north of the station and the railway line north of Darsham.   In the following paragraphs I lead you through the details and where the details are flawed due to an error in the Flood Risk Assessment for the site.  I hope it is all self-explanatory and is in such detail that you hopefully understand the issue when the matter is probed by the Planning Inspectorate examiners at a later date.        

Book 6 Environmental Statement section 7.4 Volume 3 has documents related to ground conditions at the site in Chapter 11. At paragraph 11.4.7 page 19 it summarises the findings from Appendix 11A which contains what is called the Phase 1 Desk Study report - that is a collation of the published knowledge of ground conditions.  Reference is made therein and in paragraph 11.4.7 below to BGS - this is the British Geological Survey that maps the geology/groundwater in the UK, has an archive of borehole data and collates and undertakes research. 

Paragraph 11.4.7 states 

Available BGS records indicate that the site is largely underlain by superficial diamicton (boulder clay) deposits of the Lowestoft Formation, which comprise an extensive sheet of poorly-sorted matrix-supported chalky till as well as outwash sands and gravels, silts and clays. A thin strip of land adjacent to the western site boundary is shown to comprise Head (windblown) deposits, comprising clay, silt, sand and gravel deposits.

In more layman terms the bulk of ground (referred to as Lowestoft Till)  can be expected to comprise of material laid down under the ice sheet that covered the area in Glacial times. The predominant material in these deposits is clay.  There are sometimes isolated boulders and occasional sand and gravel, the latter sometimes as a layer of material but these are usually limited in extent.  Clay has a very low ability to let water drain through it to underlying layers i.e. it has a very low permeability. 

The other deposit referred to is Head which, as stated, is a mix of materials but it will be thin and lie upon the Lowestoft Till. With the expected presence of clays and silts in the Head it is also likely to have a low permeability. 

The ground underneath the site is thus expected to have very limited capacity to transfer water to much deep underlying, more permeable ground. 

Bizarrely, the ground conditions are referred to in the Flood Risk Assessment (FRA) for the Northern Car Park, Book 5 Volume 5.3 paragraph 5.5.2, are different as it states as follows

 As the site is located on a bedrock formed of sand and a superficial deposit consisting of sand and gravel, the ground conditions have infiltration drainage potential. 

I have highlighted the disparity with the details in the document referred to earlier.  In my view the FRA is fundamentally flawed by this erroneous statement and this has led to a design that is inappropriate.

Despite the very obvious limitations on the ground's ability to drain surface water down to underlying more permeable ground the erroneous FRA statement has led EDF to propose the extensive car park and roads will have surface water draining into a pit dug on the site, referred to as infiltration basin on the plans - see below for where the plan is*) which is meant to allow the water to soak away into the natural ground. They have also incorporated open U or V shaped trenches called swales also designed to act as a soakaway feature. As all the features are in low permeability soils. In all probability this design will not be able to cope with the rapid flows of water into it from the car park and roads when a major storm occurs.  

*The most useful plan showing this can be seen in Book 2 Plans, Volume 6 Northern Park and Ride - plans for approval page 4 of 7.

The site falls in level towards the railway and from the plans there is an agricultural ditch  that current collects any rainfall runoff which drains under the railway north of the station (see the thick blue lines on the plan - green where it passes under the railway in a brick culvert).  Any overflow from the car park drainage features will naturally go to that existing feature.  The ditch is, I suspect, not capable of accepting any significant increase in flows and there is no detail on the culvert. It may be the culvert that restricts the ability of the existing ditch to take more flow. If not, then the capacity of the culvert under the A12 south of the station may be critical - an area with historical flood issues - see page 16 of the Flood Risk Assessment for the Northern Park and Ride  

EDF's FRA in a later part of paragraph 5.5.2 to the quote above says 

However, there is the possibility the infiltration rates may not be suitable to discharge all the surface water to ground and that some surface water may need to be discharged to the local watercourse network.

Nothing like backing two horses.  In the set of Not for Approval plans in  Book 2 Plans, Volume 6 Northern Park and Ride page 4 of 25 you will see very thin blue lines connecting many of the swales and the infiltration basin to the existing agricultural drain/ minor watercourse with the words on the plan 'Outfall to Existing Ditch'.  Naughty; why are these details not in the Plans for Approval?  From reading the FRA I suspect EDF have not assessed the ability of the existing ditch/culverts to cope with any additional flows as the flaw in the earlier quote above from paragraph 5.5.2 made EDF only see that as a very low probability requirement and only requiring a limited flow into the ditch. 

 

Cllr Robin Sanders, Woodbridge.

Member of the Geological Society of London

Member of the Institution of Mining, Metallurgy and Mineral

Chartered Member of the Institution of Highways and Transportation

 

 

 

 

September 2020

  1. Introduction and scope of submission.

While Darsham Parish Council (DPC) shares the wider concerns about the impacts of EDF's proposals on  transport, environment and tourism with the majority of local Parish Councils, and supports the views  of the Environment Agency and national and local conservation groups, our submission concentrates on the siting and impacts of the Northern Park and Ride (NPR) which is located within the Parish Council boundary.

 

  1. Consultation responses.

The concerns listed below have been detailed in our responses to each of the four consultation stages carried out by EDF. It is fair to say that these concerns, which are shared with other local parishes, have been largely ignored. As such, the term “consultation” is a complete misnomer.

 

  1. Traffic flow and congestion (1)

EDF have consistently underestimated traffic flows on the A12.  The A12 is a single carriageway road in this part of Suffolk. As such any road works or traffic accident is likely to cause major congestion. This has been vividly demonstrated this summer, with increased traffic volumes due to the COVID-19 pandemic and a considerable increase in tourism “staycations”. On two occasions, (one accident, one road repair) slow-moving traffic has tailed back five miles to Saxmundham.

 

  1. Traffic flow and congestion (2)

EDF project 1,140 private car, 700 minibus and 700 HGV movements each day.  The proposed construction of roundabouts at the NPR junction at Willow Marsh Lane and at the B1122 junction in Yoxford, will cause congestion on this whole section of the A12.  Darsham has increased in size by 30% in the last few years. The proposed development of a further 120 houses accessing the A12 near the Westleton Road, an 80-bedroom motel adjacent to the Jet Garage, and the proposed increase in train numbers and level crossing closures will exacerbate this congestion.

 

  1. Level crossing closures

The level crossing is closed overnight for routine maintenance at regular intervals, with traffic diverted down The Street through Darsham village. EDF have chosen to ignore this and not responded to our requests for alternative proposals or mitigation arrangements.

 

  1. Dark skies

Darsham is a dedicated dark sky village and home to the Darsham and Surrounding Villages Astronomical Society (DASH – Astro).  EDF propose low level lighting in the NPR, but mandatory Trunk road lighting on the NPR roundabout will destroy this amenity.

 

  1. Rat-running

DPC have expressed concerns about rat- running down The Street during traffic congestion on the A12 or during level crossing closures. EDF say they will install ANPR cameras to detect and subsequently ban HGVs, but have made no proposals to control LGVs and private cars.

 

  1. Noise and pollution

DPC have serious concerns about traffic noise, vibration and pollution (NOx, CO2 and particulates) as a result of congestion from increased traffic movements from the NPR, HGVs on route to Sizewell, all in addition to existing A12 traffic. Research has shown that air pollution caused “horrendous brain, heart and lung ill-health” Gases like nitrogen dioxide and tiny particles, known as particulate matter or PM, can reach deep into the body with the danger of causing lasting damage.  EDF have dismissed these concerns.

 

  1. Legacy provisions

There are no proposals for pedestrian access to and from Darsham Station and the NPR. Pedestrians will have to walk along the A12. There are no legacy provisions for improved carparking at Darsham Station which was specifically requested by DPC.

 

  1. Geology, drainage and flood risk

New research information has revealed that there could be drainage and flood risk problems associated with the NPR.  EDF have proposed a storage basin with overflow to existing watercourses running under the railway. The underlying geology prevents natural drainage within the site and is likely to lead to existing water courses being overwhelmed in heavy rain.

 

  1. Traffic constriction

Likely traffic flows associated with the NPR and direct Sizewell traffic, in addition to existing A12 traffic will lead to serious congestion exacerbated by the construction of two roundabouts, local development and particularly, increased level crossing closures. The resulting noise, vibration, air pollution and rat-running on side roads will seriously erode local residents' quality of life. These concerns have either been ignored or dismissed by EDF and no mitigation measures proposed.

 

  1. Relief road

EDF has consistently refused to consider proposals for a relief road direct to Sizewell from the A12 at Benhall which would minimise the impacts of traffic on the local population, provide a lasting legacy for both the power station and the local area and may well obviate the need for both Park and Rides.

 

  1. Summary

Taken as a whole, Darsham Parish Council conclude that siting the NPR north of Darsham Station on a single carriageway section of the A12 adjacent to a level crossing is a serious mistake. (The Southern Park and Ride is located off a dual carriageway)

Darsham Parish Council

(CP & MS)

August 2020.

 

SUMMARY

This Parish Council does not believe that the Sizewell C development will have any benefits for the Suffolk Coast and Heaths  AONB and surrounding area. On the contrary, we believe that the current  proposals in the stage 3 consultation and ten year plus construction period will have a profound impact on our environment, communities and way of life, without the benefit of any lasting legacy for future generations.  However, if the development does eventually go ahead, we make the following detailed comments and suggestions which we urge EDF to absorb and adopt to help mitigate the adverse impacts which we  list below:

ISSUES

Transport and related environmental issues are the primary concern of this Parish Council.

  1. Following the abandonment of the marine-led strategy, the consultation document appears to suggest that a road-led strategy is inevitable. We urge EDF to begin negotiations with network Rail as a matter of urgency to develop the rail-led strategy aimed at  minimising HGV and other traffic on the local road network.
  1. We agree with Suffolk County Council that the traffic modelling prepared by EDF underestimates traffic flows on the A12, and that further mitigation measures are required for several potential pinch points caused by the potential increase in HGV and other Sizewell traffic. Measures for the junctions of the A144, The Street, the Park and Ride and A1120 with the A12 and impacts on adjoining property owners are of particular concern to this Council.
  1. We note that the capacity of the Park and Ride north of Darsham station has been increased from 1000 to 1200 spaces. Despite the proposal to construct an exit/entrance near Willow Marsh Lane with a new roundabout, we believe this will only add to traffic congestion on the section of the A12 from Blythburgh to Yoxford.  Sizewell traffic joining the A12 from the A144 and A145, the Jet garage, proposed motel, Darsham station and level crossing plus a new roundabout  at the junction of the B1122 and A12 in Yoxford, will all contribute to this congestion on an already busy single carriageway road.
  1. There are no proposals to prevent rat-running by LGVs and private cars on minor roads in and around our Parish. The Street is of particular concern, as is the B1125 from Blythburgh to Theberton through Westleton. This is likely to be a particularly acute problem during the first two years of the construction period before the Park and Ride and new relief road are fully operational.
  1. There is no pedestrian access shown from the Park and Ride to Darsham station, so any Sizewell personnel or visitors arriving by train will have to walk up the A12. Further, there are no legacy provisions in regard to improved car parking facilities at Darsham station; this is a seriously missed opportunity.
  1. The level crossing at Darsham Station is closed overnight and at weekends for routine maintenance at periodic intervals. A12 traffic is diverted down the Street and via Westleton, though some vehicles use Low Road as a short cut. At present traffic flows between 8pm and 6am are relatively light; however, If Sizewell C traffic runs for 24hours this will create unacceptable traffic movements and noise levels on these minor roads during level crossing closures. The same applies to the level crossing on the B1122 east of Yoxford during the first two years of construction before a relief road is constructed. This has not been considered by EDF. Sizewell traffic movements during overnight level crossing closures will have to be curtailed unless other diversionary routes can be identified.
  1. There are serious concerns about the impact of potential A12 traffic gridlock on public transport. Route 521 from Halesworth to Aldeburgh via Darsham uses the A144, A12 and the Street. It is a vital service for those without vehicular transport and it is questionable whether buses will be able to maintain a timetable given likely traffic congestion on this section of the A12.
  1. Darsham currently has a “dark sky” policy which is valued by local residents. Even proposed low-level lighting in the Park and Ride, combined with increased traffic flows at night, (the Park and Ride will operate for 24 hours) will compromise this policy.
  1. As well as light pollution, there are serious concerns about noise pollution during the construction period and from increased traffic movements;  there is no reference in the consultation to the risk from NOx and diesel particulate pollution from 1000+ cars in the Park and Ride plus traffic congestion on the A12 itself.
  1. The construction period for Sizewell C is estimated at 10 – 12 years. Given the problems experienced by EDF at Flamanville in France and Olkuloto in Finland, this could be considered an optimistic estimate. We believe the combination of traffic congestion, light, noise and air pollution will seriously impact the quality of life of the residents of Darsham and surrounding area for more than 10 years; we would like to know how EDF propose to mitigate  for these impacts and/or compensate residents both here and in surrounding affected Parishes.

 

Wider Transport impacts

  1. EDF state that 85% of HGV traffic bound for Sizewell will come from the South.  There are serious concerns about the structural capacity of the Orwell Bridge, and the impact of closures during high winds. Closures create mayhem on the road system in Ipswich and surrounding areas.
  1. There is likely to be serious congestion at the roundabouts on the A12 around Woodbridge and Suffolk CC (as the roads authority) has stated that mitigation proposals will be required here.
  1. We welcome the EDF proposal to construct a two-village by-pass on the A12 around Stratford St Mary and Farnham. We would urge The Dept. of Transport and Suffolk County Council to partner a four-village by-pass, although this will simply transfer traffic congestion on to the single track section of the A12 north of Saxmundham.  The EDF proposal for a new relief road leaving the A12 at a roundabout south of Yoxford, by-passing the villages of Middleton Moor and Theberton, is at least an admission that a relief road is required, but there is little support for this route from Suffolk CC and any of the affected villages, on the basis that it does not go direct to Sizewell and has no legacy value.  
  1. EDF have refused to consider adoption of the W (D2) relief road leaving the A12 at Benhall direct to Sizewell, that we and other parishes proposed at stage 2. This would solve the problem of congestion between Saxmundham and Yoxford, and provide a lasting legacy for the area. Suffolk CC has urged EDF to re-consider this route, and we and other local Parishes strongly support this recommendation.
  1. Scottish Power is proposing to build a new substation at Friston as the grid connection to the new generation of wind farms being constructed off the Suffolk Coast. This is a separate planning application which contains no traffic modelling. Adoption of the W relief route could also service this development. In the interests of minimising traffic impacts on local communities we urge some urgent joined-up thinking between EDF and Scottish Power.

 

Wider social and community impacts

  1. Despite considerable local opposition, EDF are persisting with plans to locate a 2,400 worker encampment at Eastbridge. Suggestions from the County, District and Parish Councils at stage 2 for alternative sites and the creation of a legacy of affordable housing in neighbouring towns (as is the case at Hinckley Point) have been ignored by EDF.  There is no information on provision of services (water supply), to what is effectively a new town.  Along with these other respondents we urge EDF to re-consider the proposal to locate the worker campus at Eastbridge.
  1. The presence of a total workforce of some 7,000 in the Leiston area will have considerable social and economic impacts on local services, schools, policing, NHS and the housing market.  Many of these services are already under considerable strain. 
  1.  EDF will build an in-house medical facility, but have stated they will rely on NHS services in an emergency.  This area of Suffolk aleady has one of the longest ambulance response times in the County, which are likely to be extended by traffic congestion.  There does not appear to be any emergency planning or viable contingency plan, for example evacuation procedures, in the event of a major incident.
  1.  At Hinckley Point, rents in that sector of the housing market have increased by 18%. Any similar increase would have a dramatic impact on the rental sector in this area, and many local residents will be priced out of the market. It is also likely that many second and holiday homes will be rented out to Sizewell workers;  where these properties have multiple occupants, fly-parking on local roads will become an additional nuisance.  Removing properties from the tourism sector will adversely affect the whole sector (see below). Demand on local trades people from the Sizewell project will also drive up their cost and make it extremely difficult for  local residents to get construction, maintenance and repairs carried out.

 

Environment and Tourism

  1. Apart from the impact of noise, light and vehicle emission pollution, there are concerns about the impact of climate change, sea level rise  and surface water flooding  over the 60 year life of the project. There are specific concerns about the impact on RSPB Minsmere, an internationally important nature conservation site, as well as impacts on Sizewell Marshes, a Site of Special Scientific Interest. These concerns are spelt out in detail in the County Council response.
  1. There are also concerns about the visual impact of the site, particularly the need for new pylons, not mentioned at stage 2. The height of these pylons has not been specified. The height of spoil heaps necessary during the construction phase are also of concern, though, viewed from Dunwich Heath, the major visual impact will be created by the huge 32ha operational site as a whole. The impact of all this on visitor numbers to Minsmere and Dunwich Heath are very difficult to quantify.
  1. There are further concerns about the wider impact on tourism throughout the AONB. EDF state that the development will create a one-off £100m investment boost to the Suffolk economy. Our research shows that the annual income from the Suffolk Coasts and Heaths AONB is worth £210m and employs 6,000 people (source: Destination Research on behalf of AONBs 2018).
  1. Suffolk County Council have stated that to have their support, the benefits of the Sizewell C development to Suffolk as a whole must outweigh the detrimental impacts. The negative impacts of the Sizewell C proposals on tourism are difficult to estimate, and the size of their proposed tourism fund has yet to be quantified; however, bearing in mind all the other negative impacts of this proposal on the environment and local communities spelt out in this response, Darsham Parish Council has no doubt that EDF's current proposals for Sizewell C in the stage 3 consultation will have no positive benefits whatsoever either for this Parish or for the Suffolk Coast AONB as a whole.

 

 

Darsham Parish Council  12th March 2019