On 30 September SPS submitted our relevant representation to the Inspector to register as an interested party and summarise our serious concerns regarding the scheme:
Significant Adverse Impacts on the Special Qualities of the Area of Outstanding Natural Beauty
SPS objects to the Sizewell C development as currently proposed due to the harm this will cause to the special qualities of the Suffolk Coast and Heaths Area of Outstanding Beauty (AONB). SPS considers that EDF have failed to pay due regard to the statutory purposes of conserving the natural beauty of the AONB.
- We do not accept EDF’s assertion that the landscape and visual effects would only occur over localised sections of the AONB and Heritage Coast, but will impact on the integrity of the entire designation.
- The construction phase impacts on the AONB have been underestimated as the designated landscape will be severed in two for a minimum of 12 years.
- We do not accept the assessment of the effects during operation on the AONB as not significant.
- Despite embedded mitigation, significant adverse effects will remain for the designated landscape and will result in harm to the special qualities of tranquility, scenic beauty, cultural heritage, relative wildness and dark skies that fundamentally go to the heart of the designation. SPS considers that the site is insufficiently large to accommodate the proposals demonstrated by its encroachment into the designated landscape. In particular this includes the permanent developments including the causeway, access road, outage car park and pylon line which will cause an unacceptable level of development into the AONB. Embedded mitigation is not possible given the site’s physical constraints.
- The workers’ accommodation campus at Eastbridge will cause an unacceptable level of development in the deeply rural landscape which will harm the setting of the AONB.
Significant Adverse Impacts on the historic environment and setting of heritage assets
SPS objects to the level of harm to the historic landscape character and setting of heritage assets resulting from the main development, together with the associated works which fall outside of the AONB including: the accommodation campus; the Two Villages Bypass, the Green Route railway line, the Sizewell link road, the Yoxford junction alterations and the Southern park and ride.
- SPS considers that the impacts on the setting of many heritage assets that have been identified in the Environmental Statement underestimates the level of harm that will occur. Furthermore, the adverse impacts to the setting of heritage assets located along the wider access routes during the construction phase have not been adequately assessed.
- The proposed access routes will change the rural setting of many heritage assets, introducing extreme visual and physical change, through the addition of urbanising and highly engineered features (such as the bunding at Leiston Abbey measuring between 1.8m and 2.4m in height, topped by security fencing), with associated noise and traffic movement, resulting in the erosion or loss of historic field patterns and the characteristics of a farmed landscape. In particular the setting of Leiston Abbey, Theberton Hall, Glemham Hall, Farnham Hall, St Mary’s Parish Church, Farnham, Cockfield Hall and Moat Farm, Theberton.
Need for adequate compensation for the historic natural and built environment
- SPS objects to the inadequate mitigation/compensation set out in the draft S106 and calls for a proportionate environmental fund to mitigate and compensate for permanent large-scale heritage and landscape harm.
- The applicant’s Sustainability Appraisal states that the setting of 90 heritage assets will be affected, yet the compensation is limited to two sites, Leiston Abbey, and Upper Abbey farm which is in the ownership of EDF.
- The harm to the historic environment should be properly and adequately compensated through a Community Impact Fund which includes restoration of heritage assets and their settings in the form of landscape restoration/enhancements.
SPS would like to highlight that the Government’s response to its recent consultation on siting of nuclear facilities (Consultation On The Siting Criteria And Process For A New National Policy Statement For Nuclear Power With Single Reactor Capacity Over 1 Gigawatt Beyond 2025, July 2018) stated a clear outstanding requirement on EDF to demonstrate how the Sizewell site will conform to new, more stringent site selection criteria before being accepted as a suitable site. SPS considers that this is a significant omission which should be addressed before a project of this magnitude proceeds.