14 DECEMBER 2020
RESPONSE OF WALBERSWICK PARISH COUNCIL TO 5TH SIZEWELL C CONSULTATION
From the start of consultations, local communities, including Walberswick, have pointed out the severe logistical, economic and environmental flaws in EDF’s plans for Sizewell C. Each time, EDF has proceeded with its preferred options rather than seriously addressing consultation input. In this unexpected 5th consultation, EDF seems to be again dangling transport options without any indication whether these options are deliverable. It is also unclear why, having dismissed such sea and rail options in earlier rounds, EDF is now suggesting these could be put back on the table. While we would welcome the opportunity to consider any serious alternatives to the current DCO, the proposals in this consultation unfortunately do not meet this test. In particular, none of the proposals related to rail or sea transport are guaranteed and none contain analysis on which to judge whether they would alter the impact on local communities, the environment, coastal processes or the construction timeline for the better or for the worse. There is also nothing in any of the proposals to move forward the timeline of measures to avoid EDF undertaking years of construction without any transportation mitigation measures whatsoever. There are no meaningful changes to address the severe environmental impacts on the natural environment.
Points of particular concern
Rail: In earlier consultations, WPC supported more use of rail. The proposals offered by EDF, however, would depend on considerable changes being accepted by Network Rail including in passenger train timetabling. Even if this were feasible or likely, the possible decade of disruption of the rail movements in Suffolk and beyond, may be untenable. Moreover, the impact of 7 trains at night, without a much stronger commitment by EDF to mitigation measures, would have a devastating impact on all the communities along the rail line.
Sea: In earlier consultations, WPC supported more use of sea transport. However, in the possible options in this consultation for the temporary and/ or permanent beach landing facility, EDF does not provide evidence that the plans are feasible, environmentally sound nor whether they would negatively impact on coastal erosion and coastal communities north and south of the site. Moreover, given that EDF has not made clear where its aggregate would come from, even if sea facilities were built, there would be no guarantee that HGVs would be taken off the road.
Failure to address ‘early years’: These new proposals would not have any impact on reducing road traffic during at least the first two years prior to the completion of any new roads, Park & Rides, rail or sea options. This would see 600 lorries per day, plus workers and those for other Energy Projects in the area using the current A12 and connecting B roads. This is completely untenable and unacceptable. No work must start until transport mitigation is fully constructed.
Sea Defences. EDF proposes to increase the minimum height of the permanent sea defence from 10.2m to 14m and up to 15m with the adaptive option, in order to "provide confidence the defence will be sufficient". But as many others point out – both in this consultation and in the DCO, EDF has not submitted a complete design. We have severe concerns that the sea defence would increase erosion north and south of Sizewell, as the new defence starts 8 metres closer to the shoreline and plans for future adaptations will encroach even further into the beach. Moreover, EDF itself says that they cannot predict impact more than 10 years into the future – a disaster for a project that will not even begin to contribute to carbon neutral until 2040 and will have spent fuel onsite for a hundred years after that and the site would not be decommissioned until 2190. As a coastal community, already suffering from coastal erosion, Walberswick cannot support any proposals that will accelerate coastal erosion and certainly cannot give support to any plans that are not fully developed and provide full environmental impact analysis.
Destruction of AONB, SSSI and impact on Minsmere: EDF is proposing new compensatory fen meadow habitat at Pakenham in West Suffolk. Like the other two compensatory habitats proposed at Benhall and Halesworth, the Pakenham site is miles away and does not adequately compensate for rare fen habitat loss in the Sizewell Marshes SSSI. It does not explain how species like the Marsh Harrier, which was saved from extinction in the UK because of the AONB and Minsmere, will be protected by putting compensatory habitat dozens of miles away. Legally, compensatory habitats that are at least equivalent to those lost must be put in place before construction. We support the view of Suffolk Wildlife Trust that EDF’s plans are nowhere close to mitigating the impact on the environment.
In conclusion, there is nothing offered in this consultation that can alter our objection to the Sizewell C project as it currently stands.