Hinkley Point C Pre-Application Consultation – Stage 2 Stage 1 Consultation Report Foreword
2 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT FOREWORD
EDF Energy is committed to providing reliable low carbon electricity to our customers, of which nuclear generation is a key component. We welcome and support the Government’s decision that new nuclear power has a role to play in the future energy mix. We are committed to developing a new nuclear power station at Hinkley Point. The power station could provide enough electricity for more than 5 million homes. I am pleased to introduce this second formal stage of our public consultation, which significantly builds on the proposals we provided in our Stage 1 consultation on ‘Initial Proposals and Options’ in November 2009. The responses we have received from Stage 1 have greatly contributed to Stage 2 and there is a great deal of material available. We are looking forward to our consultation events, where we can discuss with you how we have addressed comments made as part of the Stage 1 consultation and listen to your views about how the power station could affect you. I am determined that we will do our best to be a good neighbour. We will work with you so that the potential multi-billion pound investment at Hinkley Point delivers excellent opportunities for local people and businesses. We will be pleased to hear your views on our proposals.
Richard Mayson Director of Planning & External Affairs
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 3 STAGE 1 CONSULTATION REPORT
4 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT CONTENTS
1 EXECUTIVE SUMMARY ...... 7 2 INTRODUCTION ...... 8 2.1 Overview of Consultation Process ...... 8 2.2 Policy Background ...... 10 2.3 Related Consultation ...... 15 3 CONSULTATION PROCESS ...... 18 3.1 Introduction ...... 18 3.2 Local Community Consultation ...... 20 3.3 Consultation with Statutory and Non Statutory-Bodies ...... 32 3.4 Next Steps ...... 35 4 RESULTS OF CONSULTATION ...... 39 4.1 Introduction ...... 39 4.2 Overview of Public and Community Responses ...... 39 4.3 Local Community Consultation ...... 40 4.4 Summary of Comments on the Hinkley Point C Development Site ...... 53 4.5 Summary of Comments on Associated Development ...... 68 4.6 Summary of Comments on Broader Community Issues ...... 84 4.7 Summary of Issues Not Directly Related to the Proposals ...... 88 4.8 Summary of Late Responses ...... 89 5 EDF ENERGY RESPONSE TO CONSULTATION ...... 90 5.1 Introduction ...... 90 6 CONCLUSIONS ...... 179
APPENDICES
A.1 Statement Of Community Consultation (November 2009) A.2 Exhibition Boards A.3 Questionnaire A.4 Exhibition Exit Interview Report A.5 Table Of Comments On The Hinkley Point C Development Site A.6 Table Of Comments On Associated Development A.7 Table Of Comments On Broader Community Issues A.8 Table of Issues Not Directly Related to the Proposals A.9 Reference Tracking System
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 5 STAGE 1 CONSULTATION REPORT
6 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 1 EXECUTIVE SUMMARY
1.1.1 EDF Energy1 intends to submit an application for Development Consent for a new nuclear power station at Hinkley Point C to the Infrastructure Planning Commission (IPC) under the Planning Act 2008 (The Act) in winter 2010/2011. 1.1.2 Before submitting its application, the Act requires EDF Energy to consult those who would be directly affected by the proposed development, those living in the vicinity of the land proposed for development, the general public, local authorities and a range of statutory consultees. Given the complexity of its proposals, EDF Energy decided to consult in two stages. 1.1.3 EDF Energy’s Stage 1 consultation on its ‘Initial Proposals and Options’ for Hinkley Point C took place between 16 November 2009 and 18 January 2010. The consultation was due to finish on 11 January 2010 but the deadline was extended by one week because of bad weather in early January. 1.1.4 Statutory consultees and other interested stakeholders (non-statutory bodies) were consulted about EDF Energy’s Stage 1 ‘Initial Proposals and Options’ under section 42 of the Act concurrently with the local community, who were consulted under section 47 of the Act. 1.1.5 The scope of EDF Energy’s consultation covered:
proposals for the main power station development at Hinkley Point C; associated development on the main site and at other locations; impacts on and potential benefits for the local community; and preliminary site works.
1.1.6 This document summarises EDF Energy’s Stage 1 ‘Initial Proposals and Options’ consultation on plans for Hinkley Point C. It explains how EDF Energy consulted, summarises the responses received, provides EDF Energy’s response and outlines key changes made to the proposals in the Stage 2 ‘Preferred Proposals’ documentation. 1.1.7 The extensive consultation undertaken by EDF Energy in relation to its Stage 1 ‘Initial Proposals and Options’ for Hinkley Point C drew a large response from statutory consultees, non statutory bodies and the local community. 1.1.8 EDF Energy has had regard to all the comments received in designing and preparing its Stage 2 ‘Preferred Proposals’ for Hinkley Point C. Significant changes have been made in response to the consultation but, equally, certain key aspects of the proposals remain unaltered. Where changes have not been made to the plans, EDF Energy has explained the reasons for this. 1.1.9 Consultation on EDF Energy’s Stage 2 ‘Preferred Proposals’ will be undertaken between 9 July and 4 October 2010. Statutory consultees and non-statutory bodies will be consulted alongside the local community and the wider general public. A revised SOCC was published on 29 June 2010 and EDF Energy will undertake community consultation in accordance with its provisions.
1 NNB Generation Company Limited (Company number 06937084), part of EDF Energy, is the Company that will lead the new nuclear programme in the UK. For the purpose of this document, NNB Generation Company Limited is referred to as EDF Energy.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 7 STAGE 1 CONSULTATION REPORT
2 INTRODUCTION
2.1 Overview of Consultation Process
a) EDF Energy’s Approach to Consultation 2.1.1 EDF Energy’s consultation process to date and intended process going forward is outlined in Figure 2.1. Beginning in 2008, EDF Energy has had informal engagement with key statutory consultees, other interested parties and the local community, which has informed the preparation of the development proposals at Hinkley Point C. The consultation process has provided EDF Energy with valuable feedback on its proposals, highlighted key issues and options to be considered and has helped with the design of each consultation phase. 2.1.2 Early engagement with stakeholders, defined as Preliminary Consultation in Figure 2.1, began in early 2008. Key milestones included the programme of consultation with key consultees coordinated in support of the Environmental Impact Assessment (EIA) and, in early 2009, to assist the Strategic Siting Assessment (SSA) nomination process. 2.1.3 Pre-application consultation is a legal requirement for Nationally Significant Infrastructure Projects (NSIPs) under the Act. Local community consultation has been carried out in accordance with the published SOCC and under section 47 of the Act. Consultation with statutory and non-statutory bodies has been run concurrently with this and aims to meet the requirements of section 42 of the Act. 2.1.4 EDF Energy has undertaken its pre-application consultation activities in two stages. The first stage of consultation on EDF Energy’s ‘Initial Proposals and Options’ ran between 16 November 2009 and 18 January 2010. The Stage 1 consultation received around 700 individual responses from statutory consultees, local stakeholders and members of the local community. Feedback on these proposals has helped inform a second stage of consultation where more detailed proposals of the development will be presented. During the consultation process local communities and key stakeholders have been kept informed about the proposed development using a variety of consultation methods including through regular newsletters and stakeholder meetings. 2.1.5 As Figure 2.1 illustrates, EDF Energy has reached its Stage 2 consultation. This stage is about EDF Energy’s ‘Preferred Proposals’ for the development of Hinkley Point C. A suite of documents in support of this consultation are available to statutory consultees, other interested parties and the general public. One of these documents is this Stage 1 Consultation Report, which summarises the stakeholder comments received at Stage 1 and outlines EDF Energy’s response. Consultation events, including public exhibitions and stakeholder meetings, will be carried out at Stage 2 on the ‘Preferred Proposals’. 2.1.6 After Stage 2 is complete, revisions may be made to the proposed scheme as necessary in response to consultation and the final consultation report will be prepared alongside the other submission documents. In addition to the formal stages of pre-application consultation, EDF Energy will continue to hold informal discussions with stakeholders as appropriate. Discussions are expected to take place up to the point of the Development Consent Order (DCO) application to the IPC, expected this Winter, and are likely to continue during the formal IPC Examination.
8 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT Figure 2.1: Pre-Application Consultation Process – Key Milestones and Dates
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 9 STAGE 1 CONSULTATION REPORT
2.2 Policy Background
a) Planning Act 2008 2.2.1 The Planning Act 2008 requires promoters of NSIPs to consult those living in the vicinity of land proposed for development, the general public, local authorities, affected landowners, and a range of other statutory consultees before submitting an application to the IPC for a DCO. 2.2.2 The IPC has the right to refuse to accept an application, if it believes that pre-application consultation has not been conducted properly by the promoter. The Chair of the IPC, Sir Michael Pitt, has made it clear that one of the IPC’s key priorities is to ensure that all parties focus on the need for effective consultation. 2.2.3 In the ‘Message from the Chair’ on the IPC’s website www.infrastructure.independent.gov.uk, Sir Michael states that: “….we have been clear that applicants must demonstrate that there has been extensive engagement with local communities in shaping their proposals at the pre-application stage. This is not only a means of ensuring that the views of local people are heard but that they are also acted upon. If we believe consultation has been inadequate, an application will not get through the door. Involving local people and the local authority at an early stage will also ensure that the best possible proposal is put forward.” 2.2.4 The key requirements for promoters in relation to pre-application consultation under the Planning Act 2008 are briefly summarised below :
Sections 42-45 require the promoter to consult a wide range of statutory consultees, landowners, occupiers, tenants, lessees, local authorities in which development is proposed, adjoining local authorities and prescribed bodies. At least 28 days must be allowed for this consultation. Section 46 requires the promoter to provide all consultation material to the IPC, prior to commencing consultation under section 42. Section 47 sets out the duty on the promoter to consult the local community including requirements: to draw up a statement on how the consultation with the community will be undertaken; to consult local authorities where development is proposed, for a minimum of 28 days, about this statement; have regard to the responses from the local authorities; publish the statement in a newspaper circulating in the vicinity of the land; and then carry out the consultation as laid out in the statement. Section 48 requires the promoter to widely publicise the proposed application and set a deadline for receipt of responses. Section 49 requires the promoter to have regard to relevant responses to all consultation and publicity undertaken.
b) Guidance on Consultation 2.2.5 EDF Energy taken into account a range of guidance in undertaking its Stage 1 ‘Initial Proposals and Option’s consultation. This includes guidance from:
National Government including, specifically, the Code of Practice on Consultation published by HM Government in July 2008; guidance relating to the Planning Act 2008, particularly Communities and Local Government’s (CLG) Guidance on Pre-Application Consultation published in September 2009 which recommended, amongst other things, that a multi-stage pre-application consultation process should be considered for major developments;
10 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT advice issued by the IPC, Guidance Note 1 on Pre-Application Stages (Chapter 2 of the Planning Act 2008) revised and published in March 2010 that reinforced the recommended multi-stage approach to consultation on major schemes; and policy and guidance from West Somerset Council, Sedgemoor District Council and Somerset County Council.
c) HM Government Code of Practice on Consultation 2.2.6 This Code sets out the approach that the Government takes to formal public consultation. Although the Code does not have legal force, it sets out the Government’s general policy on formal, public, written consultation exercises. The Code sets out seven key consultation criteria summarised below:
consultation should take place at a stage when there is scope to influence the policy outcome; consultation should normally last for at least 12 weeks; consultation documents should be clear about the process, what is being proposed, the scope to influence and the expected impacts and benefits of the proposals; consultation exercises should be accessible to all and clearly targeted at those people it is intended to reach; the burden of consultation should be kept to a minimum; consultation responses should be analysed carefully and clear feedback provided to participants; and those running consultations should seek guidance in how to run an effective consultation exercise.
2.2.7 EDF Energy’s Stage 1 consultation on its ‘Initial Proposals and Options’ for development at Hinkley Point C has broadly followed this guidance. Although the period allowed for consultation was nine rather than 12 weeks, this was only the first stage of EDF Energy’s consultation process and, cumulatively, the time allowed for pre-application consultation on plans for Hinkley Point C will exceed the Government’s guidance. d) CLG Guidance on Pre-Application Consultation 2.2.8 Guidance published by CLG in September 2009 relates specifically to the Planning Act 2008. One of its main purposes is to guide promoters of NSIPs as to how the pre-application requirements of the Act should be fulfilled. The guidance outlines what the Government’s expectations are and suggests a range of approaches for promoters to use. However, it does not specify a particular mandatory approach to pre-application consultation. 2.2.9 The guidance makes it clear that the SOCC that promoters are required to draw up in consultation with the local authorities should set out in detail who is going to be consulted and how. CLG encourages promoters to view the requirement in the Act to consult people living in the ‘vicinity of the land’ broadly, and suggests that the views of people who live, work and otherwise use (e.g. leisure users) the affected areas should be sought. 2.2.10 According to the guidance, a range of methods should be used by promoters to consult communities. It stresses that consultation should not rely on written documents alone and should reflect the fact that those to be consulted may have varying degrees of literacy, do not always have English as their first language, may not have ready access to a computer or have disabilities that make it difficult for them to engage in the process. Engagement with ‘hard to hear’ groups is encouraged.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 11 STAGE 1 CONSULTATION REPORT
2.2.11 The CLG guidance puts forward a number of suggestions for community engagement techniques including: local exhibitions; drop-in sessions; workshops; telephone advice line; citizen panels; meetings with Parish/Town Councils; internet; and local media. 2.2.12 The importance of consultation with statutory consultees and local authorities (under section 42 of the Act) is highlighted in the guidance with an emphasis on early engagement and the provision of relevant supporting technical information to consultees. 2.2.13 In terms of the timing of consultation, promoters are encouraged to consult as early as possible and to consider a phased consultation consisting of two or more stages. This is particularly encouraged for larger projects with long development periods. 2.2.14 Clear guidance is provided about the information that promoters need to supply to technical consultees. For local communities, it recommends that a short document should be produced, written in non-technical language, describing the proposals and outlining the matters on which the views of the local community are sought. It suggests that promoters should make this document available in different formats for those with disabilities if requested. The summary document should also provide details of consultation events, where the full documents can be inspected and give a deadline for a response to the consultation process. 2.2.15 EDF Energy had regard to the CLG guidance in the Stage 1 consultation process. Pre-application consultation will be undertaken over two stages with Stage 1 focusing on EDF Energy’s ‘Initial Proposals and Options’ and Stage 2 concentrating on ‘Preferred Proposals’. Stage 1 consultation has utilised a wide range of engagement techniques, not relied on written documents alone and sought to engage with ‘hard to hear’ groups. A Stage 1 Proposal Summary Document was produced and made widely available to the affected local communities. Further details of EDF Energy’s Stage 1 consultation process are given in Chapter 3 of this document. e) Guidance from the IPC 2.2.16 The IPC has published supplementary guidance on the pre-application stages of the Planning Act 2008. IPC guidance note 1 was published in December 2009 and revised in March 2010. It provides additional advice about consultation with the local community, mainly in relation to the role of the SOCC. 2.2.17 In summary, the IPC guidance says that the SOCC should:
be a concise document to suit local press publishing requirements with, if necessary, a separate document (made available to the public and cross-referenced in the SOCC) setting out in more depth the factors leading to the view taken on consultation catchment, timing and methods to be employed; include a succinct summary of the IPC’s role as examining authority; draw attention to the relevant National Policy Statements; explain the scope for the local community to influence the proposals and highlight the importance of pre-application consultation; provide sufficient detail of the project, referring to positive and negative considerations, and the scale of the proposals. The SOCC should also indicate what additional information will be provided during the consultation process on the scope for land restoration, landscaping and mitigation or compensation for loss of habitat; and give consideration to whether there should be multiple stages of consultation and take account of any major consultation exercises being undertaken in the same area.
2.2.18 EDF Energy’s original SOCC was published in November 2009, one month before this IPC guidance was issued. The IPC guidance was not therefore taken into account in EDF Energy’s
12 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT published SOCC relating to Stage 1 of its Hinkley Point C consultation, although the published SOCC does largely comply with the IPC guidance. 2.2.19 A revised SOCC has been published (June 2010) to guide EDF Energy’s Stage 2 consultation on its ‘Preferred Proposals’. f) Local Authority Statements of Community Involvement 2.2.20 Both West Somerset Council and Sedgemoor District Council have adopted Statements of Community Involvement (SCIs) that provide some advice about how developers should undertake pre-application consultation in relation to major projects. Somerset County Council adopted an SCI as part of its Minerals and Waste Development Framework in November 2006. 2.2.21 West Somerset Council’s SCI was adopted in November 2007. It positively encourages developers to undertake pre-application consultation arguing that this should provide a faster route for decision making, save money for the developer and the Council and provide the local community with a level of ownership of the project. The developer should take the lead role in the consultation and the pre-application period is identified as the key stage in which to consult. 2.2.22 The SCI establishes a ‘Consultation Matrix’ which recommends the level of consultation that the developer should undertake depending on the scale and significance of the application. It makes it clear that while the guidance on planning application consultation is not prescriptive for developers, and not all the consultation methods identified in the matrix need to be undertaken, discussion between the Council and the developer should help to decide the appropriate form of consultation. 2.2.23 West Somerset Council’s ‘Consultation Matrix’ specifically identifies applications for power stations as ‘Tier Level 1’ applications that should be subject to wider community involvement. West Somerset Council lists the following potential methods for the developer to use to engage with stakeholders and the local community:
public meetings; public exhibitions; citizen panels; website; local architectural or design panel; Parish Councils; media; surgeries; Enquiry by Design and/or Planning for Real; Planning Aid; consultation panel; development briefs; and workshops.
2.2.24 The SCI recommends that the results of the pre-application consultation should be reported in the form of a consultation summary along with the planning application. The summary should provide details of the consultation undertaken, allowing the Council to understand with whom, how and when the consultation took place and show that the local community and stakeholders’ views have been taken into account. 2.2.25 Sedgemoor District Council’s SCI was adopted in April 2007. Much of the material and advice for developers is similar to, or consistent with, that set out in West Somerset’s SCI.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 13 STAGE 1 CONSULTATION REPORT
2.2.26 The Sedgemoor SCI is clear about the need for developer-led pre-application consultation for significant development proposals. Level 1 applications are defined as those that require an Environmental Impact Assessment or a Transport Assessment. The SCI also has a Consultation Matrix that suggests the following consultation techniques for Level 1 applications:
public meetings; public exhibitions; development briefs; workshops; Enquiry by Design; Planning for Real; Town and Parish Councils; media website; and Planning Aid.
2.2.27 The SCI advises that the level of consultation for each individual proposal should be discussed between the Council and the applicant and makes specific reference to the need for developers to use a mix of consultation techniques and ensure there are opportunities for hard to hear groups to participate in the process. Applicants are advised to prepare a statement with their applications dealing with how the community has been involved in the proposals, summarising the consultation responses and providing a list of all respondents to the pre-submission consultations. 2.2.28 In addition to its SCI, Sedgemoor District Council has also adopted its own Consultation Policy. While this policy applies to the Council in terms of its own actions, rather than specifically to developers, it is worth noting some of the key policies in it, which also reflect the Government’s own Code of Practice on Consultation. These include:
consultation should take place when there is scope to influence decisions; it should normally last for at least 12 weeks; consultation documents should be clear about the process, what is being proposed, the scope to influence matters and the expected costs and benefits; the process should be accessible to those people it is intended to reach; and responses should be analysed carefully and feedback provided to participants.
2.2.29 In contrast with West Somerset and Sedgemoor District Councils, Somerset County Council’s SCI is less prescriptive. It encourages developers to consult the local community and stakeholders early in the process so that issues can be raised and addressed. A report on the results of pre-application community consultation is also suggested as part of the planning application process. 2.2.30 EDF Energy Stage 1 consultation on its ‘Initial Proposals and Options’ for development at Hinkley Point C has taken into account the consultation advice produced by the three relevant Somerset local authorities. This is particularly relevant to the local community consultation that EDF Energy is required to undertake under section 47 of the Act. The vast majority of the consultation techniques suggested by West Somerset and Sedgemoor District Councils have been deployed, and account has been taken of the need to engage with hard to hear groups and to report back on the outcome of the consultation process. The consultation methodolgy and programme adopted by EDF Energy was discussed and formally consulted upon at length with the three Somerset local authorities in the context of the SOCC .
14 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 2.3 Related Consultation
a) EDF and British Energy Preliminary Consultation on Hinkley Point 2.3.1 Prior to the acquisition of British Energy by EDF in January 2009, both companies consulted separately, but largely concurrently, on preliminary proposals for new nuclear development at Hinkley Point. EDF consulted about the principle of developing a new nuclear power station on land it controlled to the west of the existing Hinkley Point power stations, while British Energy consulted on the same subject matter in relation to its Hinkley Point C site situated adjacent to the existing A station. 2.3.2 Both consultations took place during the autumn of 2008 in the context of:
the Government’s SSA nomination process for potential sites for new nuclear development; and the EIA scoping consultation for new nuclear development at Hinkley Point.
2.3.3 At the joint request of West Somerset and Sedgemoor District Councils, EDF and British Energy agreed to co-ordinate their consultation activities and events, and tried to ensure that a consistent message was delivered to the general public to avoid confusion. However, at the time of implementation, EDF and British Energy remained separate and competing companies and their respective consultation programmes were therefore branded separately. 2.3.4 EDF’s initial consultation programme for Hinkley Point included:
four public exhibitions held in Bridgwater, Burnham-on-Sea, Stogursey and Williton; project newsletters distributed over a 15 mile radius around Hinkley Point; project questionnaires for the public to complete either on-line or at the exhibitions; an email facility through the website www.edfconsultation.info; a Freepost address for correspondence; a freephone project hotline for enquiries and comments; and statutory consultation including various meetings and liaison groups.
2.3.5 British Energy’s programme included five public meetings in Nether Stowey, Cannington, Bridgwater, Combwich and Stogursey to discuss their plans for a new power station on their Hinkley Point C site. Full details of its consultation programme were provided on the Company’s website (www.british-energy.com) and a Public Engagement Report was produce that outlined the key issues raised at the consultation events. 2.3.6 Full details of EDF’s consultation methodology, programme, the views received from the public and stakeholders and the Company’s response to these were set out in a Public Consultation Statement (PCS) entitled ‘EDF: Plans for New Nuclear Development at Hinkley Point’, published in January 2009. 2.3.7 The PCS formed part of the documentation submitted to the Government when EDF Energy (following acquisition of British Energy) formally nominated Hinkley Point C into the Government’s Strategic Siting Assessment for new nuclear power development in March 2009. It was also submitted to the three relevant Somerset local authorities, circulated widely to stakeholders and community groups that had commented during the consultation process and published on EDF Energy’s project website (www.edfconsultation.info). b) The Government’s Draft Nuclear National Policy Statement 2.3.8 The Government published its Draft Nuclear National Policy Statement for Nuclear Power Generation (EN-6) (draft Nuclear NPS) early in November 2009. The draft Nuclear NPS is part of
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 15 STAGE 1 CONSULTATION REPORT
a number of technology-specific draft National Policy Statements that, together with the Draft Overarching National Policy Statement for Energy (EN-1), clearly set out the Government’s ambitions for the delivery of major new low carbon energy infrastructure, including new nuclear power stations, by 2025. The draft Nuclear NPS lists a number of sites as being potentially suitable for the development of new nuclear power stations by 2025, including EDF Energy’s land at Hinkley Point C, and invites views on whether these sites should be identified for this purpose. 2.3.9 Public consultation on the draft Nuclear NPS closed on 22 February 2010. As part of the consultation process, the Department of Energy & Climate Change (DECC) organised a number of national and local events to publicise the draft Nuclear NPS, enable questioning of officials responsible for preparing it and provide opportunities for people to make their views known. 2.3.10 Two specific consultation events were held by DECC in the vicinity of Hinkley Point. These were at Bridgwater on 19 to 21 November 2009, shortly after publication of the draft Nuclear NPS, and a supplementary meeting at Stogursey, close to the site, on 27 January 2010. EDF Energy had no direct involvement in these events, although representatives of the Company were present at them and DECC was supplied with copies of EDF Energy’s own Stage 1 public consultation materials so these could be made available to the public attending their events. 2.3.11 EDF Energy published its Stage 1 ‘Initial Proposals and Options’ documentation shortly after publication of the draft Nuclear NPS. The EDF Energy consultation therefore took place against the background of a draft national policy suggesting that Hinkley Point is potentially suitable for new nuclear development. All EDF Energy’s Stage 1 consultation events were timed to take place after DECC’s own local consultation event on the draft Nuclear NPS near Hinkley Point, although a supplementary consultation event subsequently arranged by DECC in Stogursey in late January did take place after the close of EDF Energy’s Stage 1 consultation. 2.3.12 The timing of publication of EDF Energy’s proposals and the sequencing of the consultation events was important in helping to explain to stakeholders and the local community the difference between the Government’s consultation on the need for nuclear power stations and the principle of whether or not Hinkley Point is suitable for new nuclear development and EDF Energy’s consultation on proposals for how such development could take place. 2.3.13 The new coalition Government has confirmed that it will complete the drafting of the Nuclear NPS and put it before Parliament. c) National Grid – Hinkley Point C Connection Project 2.3.14 In parallel with EDF Energy’s Stage 1 consultation process, National Grid undertook the first phase of its consultation on its plans to provide a new high voltage overhead line between Bridgwater and Seabank near Avonmouth, together with more minor upgrading of overhead lines in the vicinity of Hinkley Point. 2.3.15 This proposed infrastructure is required to connect the nuclear power station at Hinkley Point C, and other planned electricity generation projects in the South West of England, to the National Grid high voltage electricity transmission system. As with EDF Energy, National Grid’s consultation is being undertaken prior to the submission by National Grid of a separate DCO application to the IPC or any subsequent body. 2.3.16 Stage 1 of National Grid’s consultation on two broad overhead line route corridors started on 12 October 2009 and closed on 22 January 2010. The consultation period was extended from the original 12 weeks by a further two weeks at the beginning of January 2010. This period of consultation has subsequently been extended until the 23 July 2010 to allow National Grid to provide further information and receive additional feedback on its proposals.
16 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 2.3.17 National Grid and EDF Energy are separate companies consulting on different but related issues. However, in order to minimise any public confusion about these related consultations, EDF Energy and National Grid decided to co-ordinate some of their consultation events. 2.3.18 Given the linear nature of National Grid’s proposals, their consultation covered many local communities between Bridgwater and Avonmouth that are not directly affected by EDF Energy’s plans at Hinkley Point C. The geographic overlap between EDF Energy’s and National Grid’s consultations is largely confined to communities between Bridgwater and Hinkley Point in the area where National Grid’s proposals predominantly involve upgrading existing overhead lines rather than the provision of new overhead lines. 2.3.19 Co-ordination between the two consultation exercises took place where there was geographic overlap between the projects. In practice this meant that EDF Energy and National Grid held a joint public exhibition on their respective plans in Stogursey on 2 December 2009 at which National Grid provided two of its own exhibition boards for public display. 2.3.20 EDF Energy believes that the co-ordination with National Grid was important in helping the public to understand the links between the two projects and who was consulting on what issues. d) Other Local Consultations 2.3.21 EDF Energy was made aware of a number of other relevant consultations taking place around the same time as its own Stage 1 consultation on ‘Initial Proposals and Options’ for Hinkley Point C. 2.3.22 These related consultation were identified in EDF Energy’s SOCC and included:
Sedgemoor District Council’s consultation on its Local Development Framework, Core Strategy Preferred Options. Public consultation started at the end of September 2009 and closed shortly before Christmas 2009, so there was overlap with EDF Energy’s Stage 1 consultation process; Somerset County Council’s consultation on its Minerals and Waste Development Framework, Core Strategy Preferred Options that closed in November 2009; and the North Devon and Somerset Coastal Advisory Group, supported by the EA, held public consultation on the draft North Devon and Somerset Shoreline Management Plan from 9 October 2009 through to 8 January 2010. Consultation events in the vicinity of Hinkley Point took place during October 2009.
2.3.23 EDF Energy’s Stage 1 consultation events were arranged to avoid any obvious clashes with these related consultations and, in particular, events taking place in the vicinity of Hinkley Point.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 17 STAGE 1 CONSULTATION REPORT
3 CONSULTATION PROCESS
3.1 Introduction
3.1.1 The Stage 1 consultation was about EDF Energy’s site-specific plans for Hinkley Point C and directly related associated development including, for example: proposed highway improvements; campuses providing accommodation and facilities for workers; potential park and ride sites; and freight handling facilities. 3.1.2 The consultation covered all of the issues required by the Act and its supporting regulations and guidance. EDF Energy was seeking the views of the local community and key stakeholders on the following:
proposals for the main power station development at Hinkley Point C; associated development to support the construction and operation of the power station; dealing with the impacts on, and potential benefits for, the local community; and preliminary site works.
3.1.3 EDF Energy was seeking public and stakeholder comment on its ‘Initial Proposals and Options’, including views on ways of ensuring that the local community makes the most of the social and economic benefits from the development of new nuclear power at Hinkley Point C if consent is given. 3.1.4 The consultation also invited views on related community benefits, for example support for local infrastructure such as schools, medical and social facilities, and how these benefits might be channelled to the affected areas. 3.1.5 The principle of whether or not there should be a new nuclear power station at Hinkley Point and health and safety issues were outside the scope of this consultation process. Sites potentially suitable for new nuclear power stations are identified in the Government’s draft Nuclear NPS and include Hinkley Point. 3.1.6 The safety and security of the type of reactor that EDF Energy is proposing to build at Hinkley Point C will be considered under a separate approval process – the GDA and the nuclear site licensing process. The Health and Safety Executive (HSE) and EA are undertaking the GDA jointly. 3.1.7 EDF Energy’s pre-application consultation programme is being undertaken in two stages:
Stage 1: Consult on ‘Initial Proposals and Options’, which set out EDF Energy’s broad plans for the new nuclear power station and associated development, identifying options on which EDF Energy was seeking views. Stage 2: Having considered the response to the consultation on ‘Initial Proposals and Options’, EDF Energy has published its ‘Preferred Proposals’ for consideration.
3.1.8 A period of time has been included at the end of each stage of the consultation process to consider the responses received before moving on to the next stage of the process. 3.1.9 EDF Energy is required, under section 47 of the Act, to consult people living in the vicinity of the land proposed for development, both at Hinkley Point and other land off-site that may be required for associated development.
18 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 3.1.10 In order to fulfil this duty, EDF Energy consulted with the local community in three broad geographic zones around Hinkley Point C. These public consultation zones are defined approximately as follows:
inner zone: within approximately a 5-mile radius of Hinkley Point C including the West Somerset parishes of Holford, Kilve, Stogursey and Stringston, and within Sedgemoor District the parishes of Cannington, Fiddington, Nether Stowey, Otterhampton and Stockland Bristol; middle zone: encompassed by Burnham-on-Sea in the north, the M5 to the east (including Puriton), south of Bridgwater and along the Quantock Hills AONB as far as Williton and Watchet; and outer zone: stretching around Taunton to the south, Minehead to the west, Weston-super- Mare to the north and to the west of the M5.
3.1.11 The most intensive public consultation was within the inner zone in the area immediately surrounding Hinkley Point C, with slightly less intensive consultation in the middle zone encompassing Bridgwater, and predominantly stakeholder events further away in the outer zone covering Taunton, Minehead and Weston-super-Mare. 3.1.12 Where associated development was located outside the inner zone, EDF Energy held public exhibitions in the vicinity of these sites. 3.1.13 In line with published government guidance, EDF Energy took a broad view of the requirements to consult under section 47 of the Act and consulted with:
Parish and Town Councils, particularly within the inner and middle consultation zones defined above; hard to hear groups including those in wards identified as having very high levels of deprivation, young people (via local educational establishments) and key ethnic minorities highlighted by the local authorities; organisations representing the business community, local tourism industry and visitors to the area; and other relevant community groups or organisations with an interest in its plans.
3.1.14 EDF Energy was also required to consult the following under section 42 of the Act:
statutory consultees as specified in regulations, including regional stakeholders such as the South West Strategic Leaders’ Board, the South West Regional Development Agency (SWRDA) and South West Councils (SWC); the three relevant local authorities – West Somerset Council, Sedgemoor District Council and Somerset County Council – within whose boundaries the development proposals fall; all neighbouring local authorities that share a boundary with these three local authorities including Exmoor National Park Authority; and owners, lessees, tenants and occupiers of land within the areas EDF Energy proposes to develop.
3.1.15 EDF Energy also consulted with:
Other key stakeholders including the Somerset Strategic Partnership and Local Strategic Partnerships, the existing Hinkley Point Site Stakeholder Group (SSG), business groups, including IntoSomerset, and environmental groups; and
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 19 STAGE 1 CONSULTATION REPORT
Bristol City Council, South Gloucestershire Council and the Vale of Glamorgan Council; local authorities who do not have adjacent boundaries but who may be indirectly affected by the proposals.
3.1.16 EDF Energy held a range of consultation events and used a variety of communication techniques to ensure that the local community and stakeholders had an opportunity to comment on ‘Initial Proposals and Options’ for Hinkley Point C. It also worked closely with the relevant local authorities and other organisations, such as Planning Aid South West, to identify and engage with hard to hear groups using techniques that did not rely solely on written document.
3.2 Local Community Consultation
a) Statement of Community Consultation 3.2.1 The SOCC, which explained in general terms how EDF Energy would undertake public consultation before submitting an application for development consent for new nuclear development at Hinkley Point C to the IPC, was published on 9 November 2009 (see Appendix A.1). 3.2.2 The local media was notified and the SOCC was sent directly to approximately 1,000 local stakeholders and community groups on EDF Energy’s database (electronically where email addresses were available and by post for those without) and put onto the project website. The full SOCC was also published in the Somerset County Gazette on 12 November 2009. 3.2.3 The process of preparing the SOCC began in May 2009 when EDF Energy met with the three local authorities (West Somerset Council, Sedgemoor District Council and Somerset County Council) to discuss the pre-application consultation strategy, including the scope of consultation, geographic areas and communication tools. 3.2.4 The first draft of the SOCC was sent to the three local authorities on 8 June 2009 and was followed by a discussion meeting on 16 June. Planning Aid South West was also consulted. However, there were a number of significant developments affecting EDF Energy’s plans for Hinkley Point following that initial consultation in July 2009. 3.2.5 At the beginning of September 2009, CLG published guidance on pre-application consultation under the Act. The guidance contained the following advice in Paragraph 74: “To manage this tension between consulting early, but nonetheless where proposals are firm enough to enable consultees to comment, promoters are encouraged to consider an iterative, phased consultation consisting of two (or more) stages, especially for large projects with long development periods. For example, promoters might wish to consider undertaking an early consultation at a stage where options are still being considered, followed by a further, possibly shorter consultation on a preferred option to inform the public of its choice and to gather their views on that option.” 3.2.6 Various supporting regulations to the Act were also published. In addition, the technical and investigative work undertaken by EDF Energy, particularly in relation to associated development works, took longer and proved more complex than at first thought. 3.2.7 As a result, EDF Energy decided to move to a two-stage consultation process with initial consultation on ‘Initial Proposals and Options’ later in 2009, followed by consultation on its ‘Preferred Proposals’. 3.2.8 The move to the two-stage approach was also consistent with the comments received during the consultation on the draft SOCC. However, EDF Energy wanted to make sure that the three
20 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT local authorities and Planning Aid South West had a further opportunity to comment on the revised SOCC in light of the significant changes proposed. As such, a further 28 days was provided to review, comment and respond on its content as required by section 47 of the Act. 3.2.9 A letter was sent to EDF Energy enclosing the joint officer response on behalf of Somerset County Council, West Somerset Council and Sedgemoor District Council to the amended SOCC, together with additional comments from Planning Aid South West on 6 November 2009. 3.2.10 EDF Energy considered these comments carefully as it finalised the SOCC and continued to engage with the three local authorities and other stakeholders on its consultation programme. 3.2.11 EDF Energy decided that, in view of new guidance made available after the SOCC was published, it would prepare a further SOCC to revise and update the original SOCC and to provide a framework for the second stage of consultation. Details of the revised SOCC were consulted on and published in advance of the ‘Preferred Proposals’ consultation. b) Publicity for Stage 1 Consultation 3.2.12 In order to give local residents and stakeholders the opportunity to participate in the consultation for its Stage 1 ‘Initial Proposals and Options’, EDF Energy used a variety of tools to explain its proposals and publicise its consultation events, see Figures 3.1 to 3.4 for examples. c) Newsletters: 3.2.13 EDF Energy produces a regular newsletter (A4, four sided. See Figure 3.1) on the progress of its proposals for Hinkley Point C as part of its commitment to keep local people and stakeholders informed. The November 2009 issue of the EDF Energy Hinkley Point newsletter provided details of all the public exhibitions. 3.2.14 Copies were distributed to:
approximately 3,500 households within the inner zone and Cannington by post; approximately 1,020 stakeholders (including those in the middle and outer zones) by post; over 32,500 through newspaper solus distribution to those in the middle zone; all libraries in Somerset; West Somerset, Sedgemoor and Somerset Council offices; and Tourist Information offices in Bridgwater, Burnham-on-Sea, Axbridge and Minehead.
3.2.15 Copies of the newsletter were also available at meetings, exhibitions and in EDF Energy’s Bridgwater office, as well as being available to download from the project website.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 21 STAGE 1 CONSULTATION REPORT
Figure 3.1: Front Page of November 2009 Newsletter
d) Proposal Summary Document 3.2.16 EDF Energy produced a summary of its ‘Initial Proposals and Options’ as part of its formal Stage 1 consultation, which also provided details of the consultation process and exhibitions. Figure 3.2: Front Page of Proposal Summary Document
22 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 3.2.17 It was distributed to:
approximately 100 residents in Shurton and Burton by hand; approximately 1,020 stakeholders (including those in the middle and outer zones as well as the wider region) by post; all libraries in Somerset; West Somerset, Sedgemoor and Somerset Council offices; Tourist Information offices in Bridgwater, Burnham-on-Sea, Axbridge and Minehead; and they were also available at meetings, exhibitions and in EDF Energy’s Bridgwater office.
3.2.18 The Proposal Summary Document was also available to download from the project website, with approximately 1,250 downloads recorded from November 2009 to June 2010. e) Press releases 3.2.19 On 15 November 2009, the local media was notified about the consultation and given details of the public exhibitions. Articles with details of the consultation appeared in local and regional newspapers including Western Daily Press, Bristol Evening Post, Somerset County Gazette, Western Morning News, West Somerset Free Press and Burnham and Highbridge News. f) Advertisements 3.2.20 Advertisements providing details of the time, dates and venues of the public exhibitions were placed in the Bridgwater Mercury, Somerset County Gazette, Bridgwater Times, West Somerset Free Press and Burnham and Highbridge News in the week commencing 23 November 2009, see Figure 3.3. Figure 3.3: Example of Advert (not to scale)
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 23 STAGE 1 CONSULTATION REPORT
g) Website 3.2.21 EDF Energy established a project-specific website, which included details of Stage 1 ‘Initial Proposals and Options’ and how to participate in the consultation www.edfconsultation.info/hinkleypoint, see Figure 3.4. Figure 3.4: Hinkley Point Consultation Website Home Page
h) Planning Aid South West meetings 3.2.22 EDF Energy also attended Planning Aid South West’s events in Burnham-on-Sea, Bridgwater and Stogursey at the beginning of November 2009 to explain the consultation process and how local people could find out more information and comment on the proposals for Hinkley Point C. i) Public Exhibitions 3.2.23 Eight public exhibitions were arranged at different locations within the inner and middle zones of consultation at different times to provide anyone interested with a range of opportunities to attend. Figure 3.5 shows EDF Energy staff at the Cannington exhibition held in November 2009. Figure 3.5: Photograph from Cannington Exhibition (28 November 2009)
3.2.24 An independent market research company, MSS was also commissioned to conduct exit interviews with a random sample of people leaving the public exhibitions to find out what they thought of the consultation process. 3.2.25 Initial feedback from MSS’s research was generally positive but revealed some dissatisfaction from those attending the Cannington exhibition on 28 November 2009, who felt the venue was too crowded and, therefore, that they were not able to see all the exhibition material or discuss the proposals with a members of EDF Energy’s project team. This helped formulate the decision
24 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT to provide an additional exhibition in Cannington Village Hall from 10am to 7pm on Tuesday, 5 January 2010. Appendix A.4 provides details of the exit interviews. 3.2.26 An exhibition for workers at Hinkley Point A and B stations was also planned from 3.30pm to 6pm on Wednesday 6 January 2010. However, this had to be rearranged due to adverse weather conditions and took place on Thursday 28 January 2010 in the Hinkley Point B Induction and Training Centre. Table 3.1: Attendance at Public Exhibitions
Approximate Time Date Venue Attendance
10am – 4pm Saturday 28 Cannington Village Hall 402 November 2009
2pm – 8pm Wednesday 2 Stogursey Village Hall 138 December 2009
2pm – 8pm Thursday 3 Otterhampton Village Hall 78 December 2009
10am – 4pm Saturday 5 Danesfield School, Williton 283 December 2009
11am – 7pm Monday 7 December North Petherton Community Centre 47 2009
2pm – 8pm Wednesday 9 The Exchange, Express Park, 37 December 2009 Bridgwater
2pm – 8pm Friday 11 December Princess Theatre, Burnham-on-Sea 33 2009
12pm – 6pm Monday 14 EDF Energy’s Bridgwater office 42 December 2009
10am – 7pm Tuesday 5 January Cannington Village Hall 101 2010
3.30pm – 6pm Thursday 28 January Hinkley Point B Training Room 47 2010
3.2.27 Over 1,200 people attended the public exhibitions for EDF Energy’s ‘Initial Proposals and Options’, which included:
exhibition boards; a model of the proposed power station at Hinkley Point C – permanent development; a DVD showing the construction of a European Pressurised Reactor; copies of the Stage 1 Proposal Summary Document and other written materials; and a questionnaire – to be filled in online, on a laptop at the exhibition or as a hard copy to be left at the exhibiton or posted back to the Freepost address.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 25 STAGE 1 CONSULTATION REPORT
j) Exhibition boards 3.2.28 The exhibition boards (see Figure 3.6), which were on permanent display in the Bridgwater office from 14 December 2009 until the end of the Stage 1 consultation period, provided the following information:
Introduction: Why nuclear? Why Hinkley Point? Related consultations; This Consultation: details about what EDF Energy is consulting on and a draft timeline for pre-application consultation and submission of the DCO application to the IPC; Hinkley Point C Power Station: the power station, technology and waste management, construction, landscape and wildlife after construction, and footpaths; Associated Development: location of the search areas, Cannington bypass options initial assessment, strategy for workers accommodation, park and ride, freight handling facilities, Combwich Wharf, road improvements and other works; In the Community: community benefits, jobs, training and legacy from associated development; Preliminary Works: temporary jetty, sea wall and on-site preparation work; and Making your Views Known: ways in which to respond to EDF Energy’s consultation and the draft timeline for the Government’s and National Grid’s consultations.
3.2.29 A copy of the exhibition boards was also available to download from the project website from 14 December 2009 and can be viewed in Appendix A.2 of this Report. Figure 3.6: Example of Exhibition Board
k) Questionnaire 3.2.30 In order to better understand local views on the Stage 1 ‘Initial Proposals and Options’, EDF Energy asked those attending the exhibitions and logging onto the website to complete a questionnaire.
26 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 3.2.31 The questionnaire was divided into key areas based on key consultation questions set out in the Stage 1 Proposal Summary Document including landscape, rights of way, transport, accommodation, training, business opportunities and community benefits. The questionnaire also included a section on the proposed preliminary works at Hinkley Point C. 3.2.32 The questionnaire allowed for quantitative and qualitative responses. People were able to fill in the whole questionnaire or respond to just the issues of interest to them. There was also a comments box at the end of the questionnaire to allow people to express views on anything they felt had not been fully covered in the questionnaire. A blank copy of the questionnaire is available to view in Appendix A.3. 3.2.33 In order to ensure a transparent system of consultation, a tracking system was developed to enable those who submitted comments in their questionnaire to see that the issues they raised were recorded, considered and responded to by EDF Energy. A unique reference was automatically generated and emailed to those who completed the questionnaire online. Those who completed a hard copy and did not have an email address, but wanted to be able to track their comments, were sent their reference number by post. l) Market Research Results 3.2.34 A summary of the conclusions from the exit interviews carried out at the public exhibitions is provided below and the full report can be found in Appendix A.4:
the quantitative exit interview research, conducted at the public exhibitions amongst a cross-section of visitors, shows a positive reaction overall to the consultation process and communication; many people were initially made aware of the consultation process via newsletter/ home mailing or local press article; there were some apparent significant differences in media impact in different venues; there were very high ratings of the information at the exhibition being easy to follow, with the information boards/panels most likely to be viewed and all visitors rated them as very or quite useful; printed paper materials were well rated by those who viewed them, although just over a quarter had not yet formed an opinion about them at the time they were interviewed; the scale model was also well rated overall; and the computer film was viewed by about half the visitors and was well rated; not being interested or not having enough time were the main reasons for not viewing one or more of the information areas/items; although only 1 in 5 completed a questionnaire at an exhibition, the majority of those interviewed said they would complete one at some point in the near future; almost all visitors spoke with an EDF Energy staff member and the rating of staff helpfulness was very high; and nearly three quarters of visitors said that as a result of their visit to the exhibition they were now better informed about the proposals than before their visit.
m) Stakeholder and Public Meetings 3.2.35 In addition to public exhibitions, EDF Energy held meetings and gave presentations to a number of key community groups, many of which were attended by members of the public, see Table 3.2. 3.2.36 There were 18 meetings held during the formal Stage 1 consultation period from 16 November 2009 to 18 January 2010, which were attended by approximately 600 people.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 27 STAGE 1 CONSULTATION REPORT
Table 3.2: Details of Stakeholder and Public Meetings
Approximate Date Stakeholders Attendance
24 November 2009 Kilve Parish Council 6
24 November 2009 Watchet, Williton and Quantocks Area Panel 20
27 November 2009 Councillors from West Somerset Council, Sedgemoor 10 District Council and Somerset County Council
1 December 2009 Cannington Parish Council 10
3 December 2009 Otterhampton Parish Council 30
5 December 2009 Williton Village Hall Steering Committee 3
7 December 2009 Burnham-on-Sea and Highbridge Town Council 37
8 December 2009 Stogursey Parish Council 40
8 December 2009 Quantocks Parish Cluster 15
14 December 2009 Nether Stowey Parish Council 30
15 December 2009 Minehead and District Chamber of Trade and 15 Commerce
16 December 2009 Stogursey Parish Council 30
22 December 2009 Sampford Brett Parish Council 40
4 January 2010 Williton Parish Council 100
4 January 2010 Bridgwater Town Council 10
8 January 2010 Shurton and Burton residents site visit 40
14 January 2010 Nether Stowey Parish Council 70
27 January 2010 Stockland Bristol Parish Council 75
3.2.37 EDF Energy also held meetings with key stakeholder groups outside the Stage 1 consultation period (both before and after) as part of its ongoing commitment to liaise and consult with local communities. n) Community Forum 3.2.38 A community forum was established to provide a mechanism for regular discussion between EDF Energy, representatives of the local community and other key stakeholders on the development of new nuclear power at Hinkley Point during the planning and construction process, as well as general matters relating to EDF Energy’s interests in the area.
28 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT Figure 3.7: Community Forum Meeting in Session
3.2.39 The EDF Energy Hinkley Point Community Forum:
allows EDF Energy to keep the local community and key stakeholders informed of relevant issues throughout the planning and construction period; enables community representatives and other relevant stakeholders to ask EDF Energy questions and raise issues of concern; and helps EDF Energy to understand the concerns of the local community and stakeholders, and thereby help minimise the impacts and maximise the benefits of new nuclear development at Hinkley Point.
3.2.40 Membership of the Community Forum is flexible and expected to evolve over time to ensure the community is properly represented at all times. The membership consists of representatives of the local community and relevant stakeholder organisations with an interest in development at Hinkley Point, together with relevant statutory agencies and local authorities. The agendas and minutes are available to view on the EDF Energy consultation website. 3.2.41 The Community Forum discussed the ‘Initial Proposals and Options’ at its meeting on 12 November 2009. Subsequent meeting were held on 10 December 2009, 25 February 2010 and 20 May 2010 to report back on the results of the Stage 1 consultation and provide details on the Stage 2 ‘Preferred Proposals’ consultation. o) EDF Energy’s Bridgwater Office 3.2.42 EDF Energy opened an office in Bridgwater in April 2009. The office is used as a base for EDF Energy staff working on the plans for nuclear new build at Hinkley Point and has been designed to act as a contact point for the local community. The Stage 1 exhibition panels and model were put on display in the office from 14 December 2009 to 18 January 2010. 3.2.43 Members of the EDF Energy project team were on hand to discuss the proposals and hard copies of the questionnaire were available to fill in and leave at the office, drop off later or send by post to the Freepost address. 3.2.44 The EDF Energy office in Bridgwater was also open and staffed week days from 9am to 5pm (excluding Bank Holidays) so that local people could drop in or call to discuss the proposals.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 29 STAGE 1 CONSULTATION REPORT
p) Consultation Website 3.2.45 EDF Energy used its project website to provide information on the Stage 1 ‘Initial Proposals and Options’, details of the public consultation and the opportunity to respond electronically by filling in a questionnaire online. Information available on the website for this phase of the consultation included:
site information; ‘Initial Proposals and Options’ – full and summary documents; public consultation – SOCC, Proposals Summary Document, newsletters, Community Forum agendas and minutes, exhibition boards; and newsroom – press releases and newsletters.
3.2.46 As can be seen from Figure 3.8, the number of hits to the website went up significantly at the start of the consultation period in November 2009 and interest has remained in the site following people’s increased awareness of the proposals for Hinkley Point C and the associated development. Figure 3.8: Graph Showing Activity on EDF Energy’s Consultation Website
1600
1400
1200
1000
800
600
400
200
0 Apr- May- Jun- Jul- Aug- Sep- Oct- Nov- Dec- Jan- Feb- Mar- Apr- May- 09 09 09 09 09 09 09 09 09 10 10 10 10 10
Unique visitors Home page views Public consultatio n views
q) ‘Hard to Hear’ Groups 3.2.47 Sydenham Neighbourhood Planning Group: Before the official consultation period began, EDF Energy met with the Sydenham Neighbourhood Planning Group (19 October 2009), which represents one of the most deprived wards in the county, to discuss the Hinkley Point C proposals. Two representatives from Planning Aid South West, three members of the Planning Group and a Somerset County councillor (who is also a Bridgwater Town councillor) attended the meeting. 3.2.48 A presentation was given covering the future consultation in the local area and the Community Energy Saving Programme. The Sydenham Neighbourhood Planning Group posed questions and raised points about EDF Energy’s ‘Initial Proposals and Options’.
30 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 3.2.49 Youth Workshop: As part of its ongoing commitment to consult with future generations living and working in the area, EDF Energy held a workshop at Bridgwater College, Cannington on its ‘Initial Proposals and Options’ on 20 October 2009. 3.2.50 Forty-four students from the college attended the event. A presentation was given by EDF Energy to explain the proposals for nuclear new build at Hinkley Point. The key issues raised by the students include site surveys, construction period, employment, low carbon energy generation, the decommissioning of Hinkley Point A, the project timeline and the consultation process. r) Methods of Responding to the Consultation 3.2.51 In order to ensure everyone interested in commenting on EDF Energy’s ‘Initial Proposals and Options’ had the opportunity to do so, there were several methods available to respond to the consultation. These included:
questionnaires, which could be completed online or returned as hard copies; [email protected] email address for people who did not want to fill in a questionnaire; a freephone number (0800 169 6507) widely advertised at the exhibition, on newsletters and on the project website for anyone wanting to speak to EDF Energy about their views; a Freepost address (FREEPOST CONSULTATION RESPONSE) for those wanting to take away their questionnaire and post it back, or wanting to write a letter; and staff at the Bridgwater office who were able to take receipt of comments in person, via phone, post or hand.
s) Section 48 Requirements 3.2.52 The consultation undertaken by EDF Energy on its ‘Initial Proposals and Options’ concentrated on section 42 (local planning authorities and statutory consultees) and section 47 consultees (the local community as defined in the SOCC including local organisations, special interest groups, Parish Councils and Town Councils). 3.2.53 Section 48 consultees (the wider general public) were not directly targeted but had at Stage 1 access to details of the consultation through the project website as well as local and regional media coverage. People living outside the 15 miles radius of the site sent in approximately 40 questionnaires and letters. Their comments have been incorporated within this report and are largely reflective of the issues raised by section 42 and 47 consultees. 3.2.54 The wider general public will be consulted as part of the Stage 2 ‘Preferred Proposals’ consultation. This consultation with the wider general public outside the affected local communities will be advertised through the national media. t) Lessons Learnt 3.2.55 The main conclusions drawn from a detailed analysis of the Stage 1 consultation are as follows:
the age and gender of those attending EDF Energy’s public exhibitions did not accurately reflect the makeup of West Somerset and Sedgemoor Districts’ population. There was an above-average representation of older people and men at the public exhibitions and an under-representation of young people, those aged under 45 and women; attendance at public exhibitions in Bridgwater was lower than near the site, at Cannington and in Williton. This is despite the fact that the population of Bridgwater is far larger and there are both direct and indirect impacts on the town resulting from the main and associated development;
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 31 STAGE 1 CONSULTATION REPORT
confirming the point above, responses to the EDF Energy questionnaire show a higher number of returns from areas in the vicinity of the site, Cannington and Williton than from Bridgwater; and EDF Energy’s newsletter proved to be the most popular way for local people to find out about the consultation programme. The evidence from the questionnaire responses and exhibition attendance suggests that postal delivery of the newsletter to all households in the vicinity of development areas helped to maximise local engagement.
3.2.56 In response to this analysis, EDF Energy has enhanced its programme of engagement with ‘hard to hear’ groups. Considerable progress has been made in engaging with students and children of school age through a series of workshops at Bridgwater College, West Somerset Community College and Danesfield School. Further activities in relation to ‘hard to hear’ groups will be undertaken during the Stage 2 consultation process.
3.3 Consultation with Statutory and Non Statutory-Bodies
a) Scope of Consultation 3.3.1 Statutory stakeholders and other interested bodies (referred to as non-statutory bodies) were consulted under section 42 of the Act on EDF Energy’s development proposals for Hinkley Point C as part of the Stage 1 consultation, which ran between 16 November 2009 for an extended period to 18 January 2010. This formed the first of a two-stage pre-application consultation process. Consultation with the local community, under section 47 of the Act was undertaken concurrently with consultation under section 42. Consultation with the wider general public under section 48 will be undertaken as part of Stage 2. 3.3.2 Although Stage 1 consultation provided a formal route for statutory and non-statutory bodies and the local community to provide comments, the process of engagement, as to be expected, is considered to be iterative and ongoing. 3.3.3 Statutory Consultees: Stage 1 consultation offered the opportunity for early engagement with statutory stakeholders on the development proposals in order to gain the benefit of technical input and information gathering at an early stage. For the Hinkley Point C Stage 1 consultation, statutory consultees can be defined as:
those prescribed bodies in Schedule 1 of The Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009 such as the EA, Natural England, Countryside Council for Wales, the relevant Parish Council and the relevant police authority; each relevant local authority defined as the county and district council in which the application land is situated and any county and district councils whose boundaries adjoin those councils; and each person who is an owner, lessee, tenant or occupier of land, persons interested in the land or with the power to sell/convey or release it – hereafter referred to collectively as ‘landowners’ for the purposes of this Report.
3.3.4 In addition, EDF Energy also consulted with Bristol City Council, South Gloucestershire Council and the Vale of Glamorgan Council, who although they do not share a boundary with a local authority in which the application land is situated, may be indirectly affected by the proposals due to their geographical location. 3.3.5 Non-Statutory Consultees: The broader definition of ‘non-statutory bodies’ is directed by guidance which discusses the importance of engaging with other relevant stakeholders who
32 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT may hold technical or important information on the proposals including those specific to a sector, i.e. the nuclear industry. The guidance encourages the promoter to consult widely and therefore a broad definition has been adopted, encompassing other individual organisations who have an interest in the development at Hinkley Point C. b) Consultation Material 3.3.6 The consultation material provided to statutory and non-statutory consultees took into account the criteria outlined in relevant guidance. The Consultation on ‘Initial Proposals and Options’ document (EDF Energy, November 2009), referred to as the Stage 1 Consultation Document, aimed to provide an outline of the proposals in sufficient detail to ensure that consultees could provide their assessment of likely impacts. 3.3.7 The Stage 1 Consultation Document presented the ‘Initial Proposals and Options’ for both the Hinkley Point C site and off-site associated development. Additionally, the Environmental Status Report (in its Appendix A.1) provided preliminary environmental information. The Stage 1 Consultation Document outlined the following:
the pre-application consultation process; the need for new nuclear power; the suitability of the Hinkley Point C site for new nuclear development; an outline description of the nuclear power station and its physical characteristics; land use and activities during the construction of the nuclear power station; the regulatory regime for the nuclear power station; the waste management and spent fuel arrangements for the nuclear power station; the decommissioning activities for the nuclear power station; the need for, and outline description of, development required off-site to support the development of the nuclear power station; information on EDF Energy’s approach to sustainability, community benefits and compulsory purchase; and a report on the current status of EDF Energy’s EIA for the nuclear power station and off-site development.
c) Consultation Approach 3.3.8 The proposals set out in the Stage 1 Consultation Document fell into two broad categories: those elements which were already preferred and likely to remain unchanged, for example the reactor design and the location of the proposed nuclear power station; and those which were more likely to be subject to change as a result of ongoing technical and environmental studies, and in response to consultation. In the latter category, options for development were presented and consultees were encouraged to make particular comment on these areas. d) Consultation Methods 3.3.9 Direct Mail: The Stage 1 Consultation Document presented the main route for consultation with statutory and non-statutory consultees at Stage 1 and feedback was encouraged on the material presented. The Stage 1 Consultation Document was primarily directed towards statutory consultees and other interested parties (non-statutory bodies). However, EDF Energy invited comment from all those with an interest in the development. 3.3.10 Hard copies of the Stage 1 Consultation Document were sent out to over 450 statutory and non- statutory consultees, and a number of copies on CD were made available on request. Access was provided to the full suite of documents and further information on the Stage 1 consultation provided through the dedicated project website www.edfconsultation.info.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 33 STAGE 1 CONSULTATION REPORT
3.3.11 Where ‘return to sender’ copies were received, an attempt to find an alternative address was made and a copy of the consultation material provided where possible. 3.3.12 Landowners: Prior to the commencement of Stage 1 consultation, all landowners highlighted within the search areas were identified and contacted individually to inform them of the consultation process. A number of landowners were also consulted informally to explore possible option sites in order to begin to investigate the issues and options surrounding them. 3.3.13 In accordance with section 42 of the Act, the Stage 1 Consultation Document was sent to the identified landowners accompanied by an appropriate covering letter setting out the avenues for providing feedback and obtaining further information from the EDF Energy Land Programme Team if required. 3.3.14 During the Stage 1 consultation process a number of parties with an interest in land contacted EDF Energy to discuss the proposals. Additionally, a number of informal meetings were held with interested parties over the course of the Stage 1 process. 3.3.15 Consultation Time Period: The Stage 1 consultation period ran from November 2009 to 18 January 2010 to provide sufficient time for all consultees to consider the outlined proposals and openly engage with EDF Energy. The period of consultation extended beyond the minimum 28 days specified in the Act. 3.3.16 Feedback Mechanisms: A number of feedback mechanisms were put in place in order to provide a transparent and coherent approach to pre-application consultation. Responses and queries could be made through the following means:
a dedicated email address, [email protected]; via the Freepost address (FREEPOST CONSULTATION RESPONSE); and by hand to the EDF Energy Project Office in Bridgwater (14 King Square, Bridgwater, Somerset TA6 3DG).
3.3.17 Further information could also be obtained via the dedicated website, www.edfconsultation.info and freephone number 0800 169 6507. 3.3.18 Consultation Meetings: During the period of Stage 1 consultation, and the time immediately running up to it, a number of meetings were held with the various statutory consultees to discuss the proposals outlined at Stage 1. 3.3.19 EDF Energy has met with the majority of those parties, or their appointed agents, who had a direct interest in the land identified as being affected by the proposals. This has been in addition to phone calls and letters, which have addressed the issues of potential acquisition, access for survey work and progress updates. There have been over 100 separate contacts on an ad hoc basis with landowners over this period. Negotiations are ongoing with those landowners directly affected by the proposals and meetings have been continuous. 3.3.20 Regular meetings were held for several liaison groups to look at specific areas of the Hinkley Point C Project. This formed part of the ongoing stakeholder engagement to develop a coherent and considered set of proposals. EDF Energy set up the mechanisms to achieve this close ongoing dialogue for the various interested parties. 3.3.21 The Strategic Officers Group (SOG) was organised by EDF Energy to ensure a regular forum for senior representatives of the key statutory stakeholders to meet and discuss current issues and actions arising through the process of design, environmental and technical work undertaken in relation to the Hinkley Point C Project. SOG includes officials from the three local authorities, Environment Agency, Natural England, English Heritage plus representatives of EDF Energy. The purpose of these monthly meetings was to update the local authorities and discuss the proposals. SOG continues to meet regularly.
34 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 3.3.22 Strategic Project Board (SPB) was a vehicle for ensuring the Planning Performance Agreement (PPA) that has been made between the Councils and EDF Energy, is implemented and managed effectively. PPAs are intended to provide local authorities with a mechanism to improve the management of large scale planning applications. The SPB also discusses and agrees the content and finance of Work Packages that enable the authorities to research and respond to issues relating to the Hinkley Point C Project. This meeting, held once a month, monitored the programme for delivery of material and the high level risks of the Project. The board have been meeting monthly since the PPA was signed in October 2009. The SPB continues to meet regularly. 3.3.23 The Core Project Team ran in parallel with the SPB, and had meetings fortnightly to discuss programming issues, risk items and Work Packages that are to be escalated to the Strategic Project Board. The team includes the Councils’ project officers along with key officers and representatives from EDF Energy. 3.3.24 The Marine Authorities Liaison Group (MALG) was a forum to undertake the pre-application consultation in relation to all marine impacts of the Hinkley Point C development. The MALG includes officials from the three local authorities, the Environment Agency, Natural England, and representatives from the Drainage Boards and Marine Authorities. MALG met monthly with the focus of the meeting on water and drainage issues mainly within the marine environment, but still covering a number of terrestrial issues. The MALG continues to meet regularly. 3.3.25 Meetings have also been held with various consultees including: with the appropriate regulators to discuss the potential requirement for Appropriate Assessment; an NHS meeting was held during the Stage 1 consultation to discuss any implications or benefits of the development to local health services; and EDF Energy made a formal presentation to CABE on the development proposals at the Hinkley Point C site. 3.3.26 Regular meetings were held with the IPC to update on progress and discuss any outstanding issues or requirements of the promoter (EDF Energy). Additionally, periodic meetings at a working level were held with various stakeholders, including the Councils, to discuss a variety of topics including transport, socio-economic, jobs and training, archaeology, local benefits, landscaping, ecology, Public Rights of Way (PRoW) and amenity. 3.3.27 In addition to the formal stages of pre-application consultation, EDF Energy continued to hold informal discussions with the key statutory consultees and other interested parties as appropriate. These discussions are expected to take place up to the point of the DCO application submission to the IPC and are likely to continue under the auspices of the IPC during the formal examination.
3.4 Next Steps
a) Taking Account of Responses 3.4.1 The Act imposes a duty on promoters of NSIPs to ‘have regard to any relevant responses’ (section 49(2)) received from those who would be directly affected by the proposed development, those living in the vicinity of land proposed for development, the general public, local authorities and a range of other statutory consultees when it proposes to submit an application to the IPC for a DCO. 3.4.2 In line with the amended SOCC published on 24 June 2010, EDF Energy is undertaking a second stage of public consultation on its ‘Preferred Proposals’ for Hinkley Point C, and will take into account the comments it receives in relation to these proposals, before it submits an application to the IPC.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 35 STAGE 1 CONSULTATION REPORT
3.4.3 The comments received and documented in this Consultation Report relate to EDF Energy’s Stage 1 consultation on ‘Initial Proposals and Options’ for the development of Hinkley Point C. EDF Energy has had regard to all the comments made in response to the consultation and these helped to inform its Stage 2 ‘Preferred Proposals’. 3.4.4 All consultation responses received from the local community and community stakeholders have been entered into EDF Energy’s Tractivity consultation database which has been specifically created to assist with management and documentation of the consultation process. 3.4.5 Section 5 of this Consultation Report sets out, in detail, EDF Energy’s response to the key issues and comments raised during the Stage 1 consultation. Where appropriate, it explains how these comments have influenced EDF Energy’s Stage 2 ‘Preferred Proposals’. Where EDF Energy has not made changes to its proposals in line with comments or suggestions made, this is explained along with the reasons why the ‘Preferred Proposals’ do not reflect these consultation responses. 3.4.6 Comments made in response to EDF Energy’s Stage 1 consultation by statutory and non- statutory organisations are clearly identified in this Consultation Report. In accordance with the Data Protection Act 1998, comments made by members of the general public are not publicly attributed and comments have been summarised and categorised to enable a comprehensive response. During the Stage 1 consultation process, EDF Energy made it clear to members of the public that copies of their comments might need to be made available to the relevant planning authority (in this case the IPC) but that EDF Energy would request that their personal details were not placed on the public record to preserve anonymity. 3.4.7 A system has been provided to enable members of the public responding to the consultation to track how EDF Energy has considered their comments and suggestions. The main method of response to the consultation was the EDF Energy Hinkley Point Initial Propsals and Options questionnaire. This was available online via the project website, and in hard copy form at the public exhibitions and other consultation events. 3.4.8 At the end of the questionnaire, respondents were invited to enter their email address so that an electronic receipt with a personal reference number could be sent to them via email. This could then be used to track EDF Energy’s response to their comments through the consultation process. 3.4.9 Not all the comments received from the local community in relation to EDF Energy’s Stage 1 ‘Initial Proposals and Options’ consultation were submitted via the questionnaire. A number of other methods of response were used:
some respondents used the enquiry form available on the project website, www.edfconsultation.info. This enabled respondents to make their comments directly to EDF Energy on-line via the website; a specific email address, [email protected] was also made available and widely publicised on all consultation material; a Freepost facility, FREEPOST CONSULTATION RESPONSE, was provided and publicised on all consultation material. Letters posted to this address were recevied by PPS who have been managing the public consultation programme on behalf of EDF Energy; a freephone telephone number, 0800 169 6507, was also available during normal office hours (Monday to Friday 9am to 5pm, excluding public holidays) and widely publicised on all consultation material. This number connected to the PPS Bristol office where an operator was available to record comments; and EDF Energy’s local office at 14 King Square, Bridgwater, TA6 3DG, was available for people to drop into at any time during normal office hours (9am to 5pm, Monday to Friday,
36 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT excluding public holidays) and comments could be handed in or given to the reception staff. This facility was also widely publicised on all consultation literature.
3.4.10 All comments and views received through these various mechanisms have been entered into the EDF Energy Tractivity database. 3.4.11 It should be noted that not all the enquiries received through these various mechanisms have related to EDF Energy’s Stage 1 ‘Initial Proposals and Options’ consultation. Those concerned with general questions about the project, customer billing enquiries, enquiries from potential suppliers, people seeking jobs or those wanting to provide accommodation have not been treated as consultation responses or entered into the consultation database. 3.4.12 This Consultation Report sets out how EDF Energy has had regard to all the comments and views expressed during its Stage 1 consultation on ‘Initial Proposals and Options’ in framing its Stage 2 ‘Preferred Proposals’. b) Stage 2 Consultation 3.4.13 EDF Energy’s Stage 2 consultation on its ‘Preferred Proposals’ is taking place between 9 July and 4 October 2010. A revised SOCC has been prepared, consulted upon with the relevant local authorities, in line with the requirements of the Act, and published in the Somerset Gazette. The revised SOCC and supporting detailed consultation strategy and programme are available on the project website www.edfconsultation.info, and have been widely distributed to key community stakeholders. 3.4.14 The revised SOCC builds on the principles set out in the original SOCC, published in November 2009, that set out how EDF Energy intended to consult on its ‘Initial Proposals and Options’ for Hinkley Point C. A revision to the SOCC was necessary to guide the stage 2 consultation on ‘Preferred Proposals’ in order to:
take account of the lessons learnt from the Stage 1 consultation process; stay in line with new guidance issued by CLG and the IPC since the original SOCC had been prepared; and provide a clearer and more concise SOCC than the original SOCC to make it more user friendly to the local community.
3.4.15 Some of the key changes to the revised SOCC compared with the original version are described briefly below:
the programme of engagement with ‘hard to hear’ groups has been extended to reach out to some of the groups who did not engage extensively in the Stage 1 process including: women; young adults; those living in deprived communities, particularly in Bridgwater; and young people not currently in education or employment; the geographic zones for consultation have been amended by extending the ‘inner zone’ to ensure it covers residents living close to the proposed associated development sites, as well as the main site. The ‘inner zone’ now covers: approximately 5 mile radius of the Hinkley Point C site (covering the West Somerset parishes of Holford, Kilve, Stogursey and Stringston and the Sedgemoor parishes of Cannington, Fiddington, Nether Stowey, Otterhampton and Stockland Bristol); Williton; Puriton; North Petherton; and a half mile radius of each of the Bridgwater proposed associated development sites; within the ‘inner zone’: newsletters will be distributed by post; exhibitions will be held close to every location where there may be development; and home visits, residents meetings and ‘drop in’ surgeries will be held. In the ‘middle zone’ there will be exhibitions at key
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 37 STAGE 1 CONSULTATION REPORT
locations, such as Burnham-on-Sea, while in the ‘outer zone’ mainly stakeholder consultation will be undertaken; the accessibility of Stage 2 consultation materials and events will be enhanced specifically for: those with disabilities; people with limited mobility; working people and their families; residents living close to associated development sites in and around Bridgwater; and residents of Williton; and the Stage 2 consultation period will be longer than Stage 1 to allow sufficient time for the public and stakeholders to respond to the ‘Preferred Proposals’, taking account of the summer holiday period.
3.4.16 EDF Energy’s Stage 2 consultation programme will be consistent with the original Statement of Community Consultation (SOCC) but with the addition of further consultation events, compared with Stage 1, to help improve opportunities for public and stakeholder engagement. 3.4.17 At the close of the Stage 2 consultation process, EDF Energy will review all the comments received and respond to these when publishing its final proposals for submission to the IPC. A detailed consultation report documenting the whole statutory pre-application consultation process, and how EDF Energy has responded to the views received, will be published alongside the final application documents. c) Application to the Infrastructure Planning Commission 3.4.18 Following the close of Stage 2 consultation in October 2010, EDF Energy will consider all responses received and work towards an application to the IPC this Winter that takes account of those responses. EDF Energy will submit a Consultation Report to the IPC with its DCO application, which will set out how it has had regard to responses to Stage 1 and Stage 2 consultation. The IPC must then decide whether it accepts EDF Energy's application. In making this decision the IPC will, among other things, have regard to any representations made by relevant local authorities concerning the adequacy of EDF Energy's consultation process. 3.4.19 Once the IPC has accepted the application, EDF Energy must notify all statutory consultees (including affected land owners and relevant local authorities) and publish a notice addressed to the general public in relevant local newspapers and the national press. Statutory consultees will be sent a copy of the application and the public will be informed of the location where the application documents can be viewed. Both statutory consultees and the public will be invited to make representations to the IPC in relation to the application within 28 days. 3.4.20 In due course, the IPC will then make an initial assessment of the main issues arising in relation to the application and hold a preliminary meeting at which invitees will be given the opportunity to make representations to the IPC about how the application should be examined.
38 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 4 RESULTS OF CONSULTATION
4.1 Introduction
4.1.1 This section summarises the responses received to the consultation from the public and local community (section 47) and statutory consultees, non-statutory bodies and landowners (section 42). 4.1.2 Section 4.2 gives a general overview and section 4.3 provides the detail of the public responses. Section 4.4 summarises comments from all consultees about the main development site, while section 4.5 deals with responses in relation to the associated development. Section 4.6 deals with comments on broader community issues, while section 4.7 summarises comments not directly related to this consultation process.
4.2 Overview of Public and Community Responses
4.2.1 EDF Energy’s Stage 1 consultation on its ‘Initial Proposals and Options’ for development at Hinkley Point C attracted almost 700 responses from members of the public, statutory consultees and non-statutory bodies. These ranged from detailed and lengthy submissions covering all aspects of the proposed development to succinct comments on particular proposals. 4.2.2 The key messages that EDF Energy has derived from aspects of the consultation process are summarised briefly below:
broad support locally and limited opposition to the principle of developing new nuclear power at Hinkley Point; a minority of respondents raising issues of health and safety and the long-term storage of radioactive waste on-site; widespread scepticism and opposition to EDF Energy’s initial proposals for accommodation and travel plans for workers; significant public and stakeholder support for the provision of a northern Bridgwater bypass; concern about increased traffic on the A39 between Bridgwater and Minehead and the safety of this road; general concern from Cannington residents that EDF Energy’s plans would have a negative long term impact on the character of the village; opposition to workers’ accommodation, park and ride and freight consolidation in Cannington; support for a northern Bridgwater bypass combined with an outer western bypass for Cannington evidenced by the Parish Council’s own survey; a slight preference for the proposed eastern route for the Cannington bypass compared with the western route; opposition from those living closest to Hinkley Point to the proposed location of the landscape bund on EDF Energy’s southern site boundary;
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 39 STAGE 1 CONSULTATION REPORT
people living near the site would prefer the bund moved north onto the ridge line and are supported by Stogursey Parish Council; Stogursey Parish Council and residents living close to Hinkley Point oppose a worker’s campus on the main development site. Elsewhere there is strong support for an on-site campus; significant opposition from residents and the Parish Council to EDF Energy’s proposals for a park and ride and a workers’ campus in Williton; general support for workers’ accommodation to be located in Bridgwater; general support for park and ride and freight handling facilities near Junction 23 of the M5 with J23-A (Dumball site) being the favoured location; general support for a park and ride at Junction 24 of the M5 but with less support for freight handling facilities; broad support for the plans to upgrade Combwich Wharf tempered by concerns about freight handling, local roads and the impact on the village; suggestions for potential community benefits were made by the local community but most people did not believe that the legacy benefits outweighed their opposition to those developments; general support for maximising training and employment opportunities for local people; and general support for the proposed preliminary works, although some concerns from those living closest to the site.
4.2.3 Full details of the consultation responses received are set out in this chapter.
4.3 Local Community Consultation
a) Questionnaires 4.3.1 At the end of the extended Stage 1 consultation period, 472 questionnaires were completed and returned, either online or in hard copy format. 4.3.2 People were asked to supply their postcode so EDF Energy could geographically analyse the responses to specific questions. Postcodes have been grouped, as listed in Table4.1 below. Table 4.1: Areas of Questionnaire Responses
Number of Percentage of Areas Questionnaires Responses
Shurton, Burton and Stogursey 48 10%
Nether Stowey 13 3%
Cannington 114 24%
Otterhampton/Combwich 31 6%
Bridgwater (including Wembdon, Puriton and North 43 9% Petherton)
Burnham-on-Sea and Highbridge 16 3%
Watchet, Williton, Donisford and Sampford Brett 108 23%
40 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT Number of Percentage of Areas Questionnaires Responses
Taunton area 8 1.5%
Minehead 7 1.5%
Bristol area 15 3%
Between Bristol and Burnham-on-Sea (including 13 3% Weston-super-Mare, North Somerset, rural parts of north Sedgemoor and parts of Mendip)
Outside these areas or no postcode supplied 56 12%
Total 472 100%
Figure 4.1: Map Showing Areas of Questionnaire Responses
4.3.3 As Table 4.1 and Figure 4.1 above show, of the 472 completed questionnaires, 416 respondents supplied their postcode (88%). This provides a helpful average and illustrates that the areas expressing most interest in the proposals are those that live close to the Hinkley Point C site and search areas for associated developments – namely those in Shurton, Burton and Stogursey (10%), Cannington (24%), Williton/Sampford Brett (23%) and, to a lesser extent, Bridgwater (9%) and Otterhampton (6%). 4.3.4 The questionnaire included a mixture of quantitative and qualitative questions on proposals for the main site and the associated developments. It also sought the local community’s views on the preliminary works to get the site ready for construction. A blank copy of the questionnaire,
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 41 STAGE 1 CONSULTATION REPORT
which includes maps of the site areas discussed throughout this report, can be viewed in Appendix A.3. 4.3.5 There was a misprint on the maps for Cannington in question 8 of the original version of the questionnaire, which was brought to EDF Energy’s attention following the first Cannington exhibition. This was rectified immediately and those who had responded to either map (26 online questionnaires and 13 hard copies) were informed of the printing error and given the opportunity to clarify their answer. 4.3.6 Details of the quantative responses follow in this section of the report. Summaries of comments received have been categorised and can be viewed in Sections 4.4 to 4.7 of this report. 4.3.7 Question 1a: Do you agree that EDF Energy’s proposals to provide a landscape buffer on the southern boundary of the site is the best way of minimising the potential impact of the construction site for nearby local residents?
Responses Number Percentage
Yes 242 67%
No 49 11%
Don’t know 79 22%
4.3.8 As can be seen from the table above, over two thirds of respondents were supportive of EDF Energy’s proposals to provide a landscape buffer on the southern boundary of the site. 4.3.9 Question 1b: If yes, should this be retained as a permanent feature once construction is completed?
Responses Number Percentage
Yes 212 67%
No 32 10%
Don’t know 71 23%
4.3.10 Two thirds of respondents thought a landscape buffer on the southern boundary of the site should be retained as a permanent feature after completion of construction. 4.3.11 Question 2: There are a number of options for the restoration of the site at the end of the construction phase. How would you rate the following options:
Responses Number Percentage
Return land to its previous use
Very important 165 52%
Important 68 21%
Not important 41 13%
Not at all important 11 4%
Don’t know 33 10%
42 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT Responses Number Percentage
Creation of wildlife habitats
Very important 189 59%
Important 88 27%
Not important 13 4%
Not at all important 10 3%
Don’t know 22 7%
Grassland
Very important 121 41%
Important 102 35%
Not important 28 10%
Not at all important 9 3%
Don’t know 33 11%
Woodland
Very important 162 52%
Important 99 32%
Not important 14 5%
Not at all important 8 3%
Don’t know 27 8%
4.3.12 Restoration of the land required during the construction period is very important/important to the majority of local community respondents, with the creation of wildlife habitats being rated as either very important or important by 86% of respondents. Woodland planting was also highly valued and was regarded as either very important or important by 84% of respondents. 4.3.13 Question 4: What is your view of EDF Energy’s initial proposals for managing transport and accommodation during the construction phase?
Responses Number Percentage
Transport
Very satisfied 13 3%
Satisfied 69 18%
Not satisfied 66 17%
Not at all satisfied 205 54%
Don’t know 29 8%
Accommodation
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 43 STAGE 1 CONSULTATION REPORT
Responses Number Percentage
Very satisfied 11 3%
Satisfied 65 17%
Not satisfied 51 14%
Not at all satisfied 214 57%
Don’t know 34 9%
4.3.14 Of those who responded to the question about EDF Energy’s initial proposals on transport and accommodation during the construction phase, nearly a quarter were very satisfied/satisfied, whilst over three quarters were not satisfied/not at all satisfied. 4.3.15 Question 5: We are proposing a bypass for Cannington. Do you think the road is needed? If so, should it go to the east or west of the village?
Responses Number Percentage
East of the village 122 36%
West of the village 69 20%
Not required 53 16%
Don’t know 93 28%
4.3.16 There appear to be mixed views in the local community about whether a Cannington bypass offers the best solution and, if so, whether the route should be to the west or the east of the village. 4.3.17 Of those who responded 44% did not know or did not think a Cannington bypass was required. However, 56% were supportive of a Cannington bypass. Of those who were supportive of a Cannington bypass, 64% favoured the Eastern route option and 36% preferred the Western route option. 4.3.18 135 people did not answer this question when completing the questionnaire. 4.3.19 Question 6: We are proposing a mix of solutions for accommodating construction workers. Please tick in the table below to indicate your preferences:
Responses Number Percentage
Temporary campus on-site for up to 700 workers
In favour 261 70%
Not in favour 83 22%
Don’t know 27 8%
Campus accommodation on a site to the south of Cannington for up to 200 workers with potential long- term legacy uses including student accommodation, hotel or other
In favour 112 31%
Not in favour 195 53%
44 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT Responses Number Percentage
Don’t know 59 16%
Additional campus accommodation at Cannington College for up to 120 workers, with the potential for long-term legacy benefits for the College
In favour 164 45%
Not in favour 144 9%
Don’t know 60 16%
Campus accommodation at Williton for up to 200 workers, with the potential for long-term legacy benefits including a care home, hotel or other
In favour 79 21%
Not in favour 227 60%
Don’t know 74 19%
Accommodation for up to 500 workers at one or several campuses in Bridgwater, with potential for long- term legacy uses including student accommodation, hotel or other
In favour 236 64%
Not in favour 71 19%
Don’t know 59 16%
Use of existing owner-occupied and privately rented accommodation, including guesthouses and caravan parks
In favour 216 59%
Not in favour 94 25%
Don’t know 61 16%
4.3.20 The most popular locations for worker accommodation from respondents within the local community were the temporary campus on site (with 70% in favour) and campuses in Bridgwater (with 64% in favour). Over 40% of the objections to a temporary campus on site were from people living in close proximity to the Hinkley Point C site. 4.3.21 Using existing owner-occupied and privately rented accommodation also attracted support from the local community with only a quarter not in favour of this option. 4.3.22 The least popular options for campus accommodation were at Williton (with only 21% in favour) and south of Cannington (with just over 30% in favour). 4.3.23 Question 7: What are your views on the four locations EDF Energy is proposing for the new park and ride sites? Please indicate your preferences below and with reference to the maps:
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 45 STAGE 1 CONSULTATION REPORT
Responses Number Percentage
Cannington
To the south of the village and 68 21% adjacent to the proposed workers’ campus
To the north-west of the village 61 19%
Neither 196 50%
Junction 24 of the M5 on the southern outskirts of Bridgwater
Location A 49 17%
Location B 67 23%
Location C 77 27%
None of these 95 33%
Junction 23 of the M5 on the northern outskirts of Bridgwater
Option 1 154 53%
Option 2 65 22%
Neither 71 25%
Near Williton
To the west of Williton 44 13%
To the east of Williton 49 15%
Neither 235 72%
4.3.24 The majority of respondents favoured park and ride facilities at Junctions 23 and 24 of the M5, with opinion divided over the most suitable location at each site. The clear preference was Option 1 (J23-A) at Junction 23. 4.3.25 Cannington was a less popular option with almost 60% of respondents not favouring a park and ride facility on the outskirts of the village. Of those who felt Cannington was appropriate for a park and ride both options received a similar level of favour, with the site to the south of the village, adjacent to the proposed workers’ campus, marginally more popular. 4.3.26 A park and ride facility near Williton was the least popular option with 70% of respondents opposed to the proposals. Of the 30% who chose Williton as a potential park and ride, the views over location were split almost equally. 4.3.27 Question 8: What are your views on proposed freight handling facilities adjacent to some of the proposed park and ride sites and at Combwich? Please indicate your preferences below and with reference to the maps:
46 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT Responses Number Percentage
On the outskirts of Bridgwater
North – near Junction 23 of the M5 159 56%
South – near Junction 24 of the M5 59 21%
Neither 67 23%
Near Cannington
North-west of the village adjacent to the 58 18% C182
South of the village adjacent to the A39 46 15%
Neither 212 67%
At Combwich
In favour 211 66%
Not in favour 108 34%
4.3.28 Freight handling facilities at Combwich were the most popular option, with two thirds of respondents in favour of the proposals. 4.3.29 The site at Junction 23 of the M5 also appears to be an option favoured by the local community with 56% supportive of freight handling facilities in that location. 4.3.30 Cannington was the least popular location for freight handling facilities with two thirds of people wanting neither site to be brought forward. Of those who supported a freight handling facility at Cannington, both options received almost equal support, with the north-west of the village adjacent to the C182 slightly preferable. 4.3.31 Question 11: What are your views on our proposals for undertaking, at our own risk, preliminary works to get the site ready for consultation?
Responses Number Percentage
Construction of temporary sea jetty
Very satisfied 80 23%
Satisfied 98 28%
Neither satisfied nor dissatisfied 67 18%
Not very satisfied 13 4%
Not satisfied at all 6 13% 46
Don’t know 51 14%
Construction of sea wall
Very satisfied 76 21%
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 47 STAGE 1 CONSULTATION REPORT
Responses Number Percentage
Satisfied 108 31%
Neither satisfied nor dissatisfied 60 17%
Not very satisfied 9 3%
Not satisfied at all 46 13%
Don’t know 53 15%
Site preparation and earthworks
Very satisfied 60 17%
Satisfied 98 28%
Neither satisfied nor dissatisfied 66 19%
Not very satisfied 17 5%
Not satisfied at all 54 15%
Don’t know 56 16%
4.3.32 EDF Energy’s proposals for preliminary site works, at its own risk, have generally been met with support or acceptance by respondents to the questionnaire. Only 17% of respondents were not very or not at all satisfied by proposals to construct a temporary sea jetty and site preparations/earthworks. 16% of respondents were not very or not at all satisfied by the sea wall proposals. 4.3.33 Over 50% of respondents were supportive of the construction of the temporary jetty and the sea wall, with 45% supportive of the site preparation and earthworks. b) Petition and Standard Letters 4.3.34 During the consultation period EDF Energy received a number of petitions and standard letters. These included: Cannington Parish Council undertook a survey of all residents in the village on EDF Energy’s ‘Initial Proposals and Options’. A total of 521 replies were received and the Parish Council’s formal response was based on the majority opinions expressed in the survey:
GENERAL: 1. Do you think Cannington will lose its “village” identity by accommodating a temporary park and ride, freight consolidation facility and one or two campuses for up to 320 workers?
Yes 434 83.3%
No 68 13.1%
Don’t know 19 3.6%
Total 521
48 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT ROADS: 2. It is anticipated that during the construction period many extra vehicles will use roads in Cannington in order to get to the site at Hinkley Point. EDF Energy has suggested building a bypass. Are you in favour of a bypass?
Yes 397 78.9%
No 94 18.7%
Don’t know 12 2.4%
Total 503
3. EDF Energy has offered to build a bypass – possible routes are:
3a. Western route: A route that starts from the A39 roundabout to the 57 12.3% west of Cannington that crosses Brymore’s front and back drives before heading NNE between Withiel Farm and Withiel Drive, to Sandy Lane to the west of Knapp Farm. It would then cross Chads Hill lane before swinging NE to join with the Hinkley Point road between Rodway Farm and Sharks Lane.
3b. Outer Western route: To start from a new junction to the west of 75 16.2% the existing roundabout near Blackmoor Lane on the A39 around the back of Brymore School crossing Sandy Lane between the quarries and joining with the Hinkley Point Road by the Grain Store. (Please note that this road has been considered but not offered as a possible route in the EDF Energy plan.)
3c. Eastern route: A route that starts at the A39 roundabout on the 61 13.2% southern side of the village then swings in a large arc to the east before joining the Hinkley Point road between the Grain Store and Putnell Farm.
3d. A northern route from Bridgwater to link with the Hinkley Point 107 23.2% road somewhere north of Cannington which could link up with a proposed western bypass. (Please note that this route has not been offered as a possibility.)
3e. A northern route from Bridgwater to link with the Hinkley Point 140 30.3% road somewhere north of Cannington which could link up with the proposed eastern route around Cannington (Please note that this route has not been offered as a possibility)
3f. No preference 22 4.8%
PLEASE CONSULT THE MAPS IF IN ANY DOUBT (Further details of the maps and routes can be found on the home page of the Cannington Website – www.cannington.org.uk)
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 49 STAGE 1 CONSULTATION REPORT
TRAFFIC CALMING: 4. Whichever route is chosen for the bypass there will always be commuters who will try and travel through the village as a short cut. Would you like to see some sort of traffic calming measures in the village?
Yes 415 82.2%
No 63 12.5%
Don’t know 27 5.3%
Total 505
TEMPORARY WORKERS ACCOMMODATION: 5. EDF Energy has identified two possible sites to accommodate a workforce of up to 320 in Cannington. Up to 120 within the college campus and up to 200 on a site to the south of the village (exact locations are not known at this time). Are you in favour of an extra 320 workers living in the village during the construction period?
Yes: On both sites 32 6.6%
Yes: But only on the College site 45 9.3%
Yes: But only on the Southern site 29 6%
No 361 74.4%
Don’t know 18 3.7%
Total 485
If you answered ‘no’ or ‘don’t know’ to question 5 please answer question 6 and 7.
6. There is a strong possibility that the accommodation at (5) above could be left to the College after the completion of the building project. The College could use the accommodation for student residential use. Would you now be in favour of this project?
Yes 38 9.1%
I could be but would need further information 57 13.6%
No 303 72.3%
Don’t know 21 5%
Total 419
7. There is a strong possibilty that the accommodation at (5) above could be left to the village after the completion of the building project. The village could use the accommodation for much needed affordable housing. Would you now be in favour of this project?
Yes 48 11.2%
I could be but would need further information 74 17.3%
No 288 67.4%
Don’t know 17 4%
50 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT Total 427
TEMPORARY PARK AND RIDE: 8. In order to lessen the number of journeys to the construction site EDF Energy has proposed a series of Park and Ride schemes in Sedgemoor and West Somerset areas. Two proposals have been made to use land in Cannington. One on the south side adjacent to the present bypass and the second on land opposite or near the Grain Store. Are you in favour of a Park and Ride scheme in Cannington to accommodate up to 900 cars?
Yes (by bypass) 61 13%
Yes (by Grain Store) 80 17%
No 319 67.7%
Don’t know 11 2.3%
Total 471
TEMPORARY FREIGHT CONSOLIDATION FACILITY: 9. EDF Energy has stated that it would like a freight consolidation facility to offload up to 120 “white van” size vehicles per day on site other than those to be used for the Park and Ride proposals. There are two proposals. On the south side adjacent to the present bypass and the second on land opposite or near the Grain Store. Would you accept such a facility in Cannington? PLEASE CONSULT THE MAPS FOUND ON THE CANNINGTON WEBSITE OR THE PAMPHLETS DISTRIBUTED BY EDF Energy (Further details of the maps and routes can be found on the home page of the Cannington Website – www.cannington.org.uk)
Yes (by bypass) 52 10%
Yes (by Grain Store) 113 21.7%
No 338 65%
Don’t know 17 3.3%
Total 520
COMPENSATION: 10. All the above will make an impact on village life in varying degrees. In view of this EDF Energy is willing to give the village certain facilities. These could be in the form of a new Village Centre which may incorporate a hall for plays, sports/social facilities and car parking; recreational facilities for football and cricket together with changing rooms could be incorporated; a landscaped area possibly including a lake as well as a communal park area or other schemes that the village so wishes. To this end would your views change your answers to any of the above?
Yes 12 2.4%
No 391 76.7%
My views could be changed but I would need further information 94 18.4%
Don’t know 13 2.5%
Total 510
Please feel free to add any comments below that you feel could help the Council with its response Source: Cannington Parish Council survey, December 2009 HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 51 STAGE 1 CONSULTATION REPORT
4.3.35 Save Cannington Action Group handed in a petition to the Bridgwater Office with 757 signatures. The petition was not in opposition to EDF Energy’s proposals for nuclear new build at Hinkley Point but against the associated development proposed for the village. The petition stated: “We the undersigned who live in the Parish of Cannington reject all site-related activity within the Parish. We also reject access to Hinkley ‘C’ site via the A39 to the west of Bridgwater. We implore you to investigate provision of a dedicated site access road from the A38 near M5 Junction 23 to the north of Bridgwater.” 4.3.36 Approximately 67 standard “Stop Hinkley” letters were received. These objected to the principle of nuclear new build at Hinkley Point and referred to the impact of the development on surrounding communities, highlighting concerns about:
health risks from radioactive emissions; risks of leaks, accidents, terrorism; highly radioactive spent fuel remaining on-site for 160 years plus; no planned repository for onward disposal of this spent fuel; disruption of local life due to a large influx of temporary workers; and nuclear’s tiny contribution to combating climate change.
4.3.37 Residents in Williton held a survey on the merits of the A and B sites in Williton – the results of which were that 283 preferred Site A, 19 preferred Site B and 7 returns for neither. The results of the survey were verified by the Chair of Stogumber Parish Council. c) Public and Stakeholder Meetings 4.3.38 Notes were taken at the meetings held before, during and immediately after the official Stage 1 consultation period to ensure that the key points discussed were recorded and could be considered when developing preferred options. d) Community Forum 4.3.39 EDF Energy’s ‘Initial Proposals and Options’ were the main agenda item at two Community Forum meetings on 12 November and 10 December 2009. The SOCC and the consultation events were discussed at the Community Forum on 12 November 2009, which was attended by 33 representatives from the community. 4.3.40 The Community Forum also met during the consultation period (10 December 2009) to discuss EDF Energy’s ‘Initial Proposals and Options’. Twenty representatives from the local community attended. Key issues raised were: the landscape buffer; rights of way; northern bypass; accommodation legacy; traffic and transport; road safety; accommodation strategy; community benefits; preliminary works; and engagement with hard to hear groups.
52 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 4.4 Summary of Comments on the Hinkley Point C Development Site
4.4.1 The following sections (Sections 4.4 to 4.6) summarise the comments received to the Stage 1 consultation from statutory and non-statutory bodies, in addition to summarising the relevant comments from the local community and general public. Responses have been focused on a themed basis. Appendices A.5 to A.8 summarise the statutory and non-statutory bodies’ comments in more detail based on the themes outlined below. 1) Preliminary Works 4.4.2 Information on the proposed preliminary works was provided at Stage 1 and comprised on-site preliminary works to prepare the site for development; construction of a sea wall; and a temporary aggregates jetty. This formed the pre-application consultation programme undertaken in advance of submissions through the local authority planning route and other related consent regimes for the works. Formal consultation will also be undertaken for the planning application by the local planning authority following submission of the site preliminary works planning application. Further details on preliminary works were provided in Appendix A.3 of the Consultation on ‘Initial Proposals and Options’ document and in the summary document. 4.4.3 Statutory and Non-Statutory Bodies: Comments relating specifically to the construction and design of the jetty and sea wall are discussed within the marine development section (see sub- heading 8) Marine Development). Comments received in relation to preliminary works as a whole and the processes involved in considering them are outlined here. 4.4.4 Some respondents stated that insufficient detail on the preliminary works was provided at Stage 1, considering the proposed timetable of submissions in March 2010. It was stated that information available had not allowed the consultees to influence the development of these elements of the project. It was also suggested that Stage 1 overlooked the significance of individual project elements and provided inadequate justification of need. 4.4.5 It was recommended by a number of respondents that further details on the individual elements of preliminary works should be provided for consultation with statutory bodies in advance of submission of the applications for the preliminary works. For example, a stakeholder commented that the stage reached for the archaeological investigations should be fully understood before levelling the site and another requested further details on the construction of preliminary works to determine whether this would impact the Strategic Road Network. 4.4.6 Specific comments were received relating to environmental information. It was suggested that there was a need to demonstrate that site clearance would not adversely affect statutorily protected species and stakeholders recommended the preparation of a mitigation strategy. The potential for damage to terrestrial archaeological deposits from site levelling and terracing in advance of the IPC application was also commented on. 4.4.7 Consultees sought clarification on how the Environmental Impact Assessment (EIA), and any Appropriate Assessment that might be undertaken, would be conducted and its compliance with regulations. Further information was requested on how cumulative effects of the development would be evaluated. 4.4.8 The potential issue of how the various regulators should proceed with the applications for the preliminary works was raised by stakeholders who sought clarification on which consenting route the works would go through. Consultees requested more information in relation to the implications for the works subject to preliminary applications should the DCO application not be approved by the IPC.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 53 STAGE 1 CONSULTATION REPORT
4.4.9 Local Community and General Public: There was a mixed view on the timing of preliminary works and whether they should take place in advance of the IPC application or not. There were also requests for further information on the reinstatement plans. 4.4.10 Some respondents did not think that preliminary works should be undertaken until development consent for the main development was received. The main reasons were that this could pre-empt the IPC process and the proposed works would cause damage to the environment and wildlife habitats that would be difficult to reverse if development was not approved. 4.4.11 Others recognise the urgent need for new nuclear development and support EDF Energy’s proposals for preliminary works. Some respondents proposed the condition that work should be carried out with as little disruption to local residents as possible and that the land be returned to its previous use if planning permission is refused. 2) Construction Activities and Restoration 4.4.12 Stage 1 consultation provided information on the construction programme, construction phasing and the main construction activities, together with land use requirements for the proposed nuclear power station and initial details on construction land use. A summary of stakeholder feedback in respect of the landscape buffer, forming part of the construction works, is addressed in a separate section (see sub-heading 3) Southern Landscape Buffer). Restoration options were also explored for the Stage 1 consultation, including the retention of existing key features. Objectives and principles for a restoration scheme were presented. 4.4.13 Statutory and Non-Statutory Bodies: Stakeholders in their responses promoted sustainable construction of the power station and the development of an overarching construction strategy to incorporate the submission and implementation of a Construction Environmental Management Plan, Construction Logistics Strategy, and Site Waste Management Plan as part of the DCO application. Consultees were encouraged by the package of measures presented, including the avoidance of statutorily designated sites for laydown areas during construction. Comment was also received on the extent of land required for construction. Consultees remarked on the impact to landscape features, which it was suggested should be minimised and materials reused, and it was queried whether the environmental impact of the transportation distance of construction materials had been considered. Some respondents also welcomed the approach to sustainability. 4.4.14 Stakeholders sought to encourage the inclusion of details within the construction strategy on the area required for construction related activities; how the site would link together as part of a coherent strategy; tie in with local supply chain initiatives, training, employment and community benefit; construction time limits; and construction and site restoration phasing. 4.4.15 In respect of the management of construction waste, it was suggested that Stage 1 made limited reference to this. Respondents suggested that full consideration on the generation, transportation, storage and disposal of construction waste was required. Spoil arisings and disposal was discussed by respondents and clarification sought in terms of its composition and management, including the extent and location of spoil storage, reuse and disposal, and the potential increase in flood risk. 4.4.16 Responses relating to site restoration fell into two broad categories: the restoration/landscaping scheme and restoration management. Some stakeholders were positive about the restoration design concepts presented at Stage 1 and recommended further development of the restoration scheme which reflects existing features and landscape character, including the historic landscape. Flexibility in the height and location of earth bunding was suggested in order to accommodate landscape features.
54 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 4.4.17 Enhancement of wildlife corridors and hedge management in any off-site mitigation measures was also encouraged by respondents. Other stakeholders commented on the potential for timely habitat restoration, creation and enhancement, taking into account existing habitat interests. The retention of the Green Lane feature was also welcomed by a respondent and clarification was sought on how the retention of its current setting would be achieved. It was recommended by another consultee that a landscape management plan should be prepared to detail how the landscape would be managed in the future. 4.4.18 Further consultation was recommended with the local authorities, Stogursey Parish Council and West Hinkley Action Group regarding on-site layout and landscaping proposals, and it was suggested that the Forestry Commission be consulted in respect of screen planting. 4.4.19 Local Community and General Public: The local community raised similar issues as the statutory and non-statutory bodies stressing the importance of minimising the visual impact of the new nuclear build as much as possible, encouraging use of sustainable building methods and keeping the removal of hedgerows, trees and barns to a minimum. 4.4.20 The majority of respondents advocated restoring the construction sites to green fields after cessation of use. Favoured options included restoring agricultural use, replacing woodland, protecting wildlife (such as Skylarks and Meadow Pipits), establishing nature reserves (with scrub and freshwater habitats if possible) and restoring/improving Public Rights of Way (including bridleways). 4.4.21 Some respondents were sceptical that the site could be restored after cessation of use and there was some unease that once a site has been developed it would be reclassified as brownfield land and thereby set a precedent for future development. 3) Southern Landscape Buffer 4.4.22 Stage 1 consultation summarised how the creation of a landscape buffer along the southern perimeter of the Hinkley Point C construction site would help to reduce visual impacts from nearby residential properties. 4.4.23 A number of respondents discussed the opportunity of creating a multifunctional buffer, with the bund also creating short to medium term mitigation for habitat losses on-site. 4.4.24 Statutory and Non-Statutory Bodies: Stakeholders suggested that the bund should be planted immediately. This would create a semi-natural buffer which would be well established by the end of the construction period. Mature trees would provide an additional barrier from residential properties and increase environmental diversity. It has been requested that the bund should be environmentally friendly and visually appealing in ways that lay the groundwork for future use by the community. A number of responses discussed that the buffer should be considered for permanent use, with the habitat creation retained and managed in situ. 4.4.25 A number of respondents commented on the location of the bund and the interaction with public access and residential properties to the south of the Hinkley Point C site. It was suggested that any significant amounts of suitable spoil from the site should be utilised by building up this bund, ideally established early on in the construction phase, and stakeholders believed that it would not be acceptable for spoil from the site to be transported from the jetty to off-shore dumping sites. 4.4.26 It was recommended that EDF Energy consults further with the local community and key stakeholders to ensure that the buffer design takes account of their views. Respondents also suggested that greater detail of the proposals and wider landscape plans should be provided, including the scale of the bund to assess the impacts on residents living in the vicinity. 4.4.27 Local Community and General Public: Some respondents from the local community felt that there was not enough detail given at Stage 1 about the possible size/scale of the proposed
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 55 STAGE 1 CONSULTATION REPORT
landscape bund and how it would minimise visual impact as well as light, noise and pollution. Suggestions were made about planting trees and hedgerows, partly as screening and partly for local wildlife. 4.4.28 There also appeared to be some confusion about the purpose of the bund, with many respondents believing it relates to the new power station rather than the associated development and construction activity. This prompted some confusion as to why it might be removed after construction is completed. 4.4.29 There was, however, a general consensus with the statutory and non-statutory bodies that the bund should be built and planted up at the start of the construction process and be a permanent feature. Those people most directly affected should, however, be closely consulted on all aspects of the bund. 4.4.30 Those living closest to the Hinkley Point C site were concerned about noise, light, views and loss of daylight, with the majority preferring the bund to be moved further north, nearer the ridge. 4) On-site Accommodation 4.4.31 Stage 1 consultation discussed the on-site workers’ accommodation campus. Respondents mainly commented on the need, suitability and operation of the campus with comments divided as to whether the on-site facility was appropriate or not. 4.4.32 Statutory and Non-Statutory Bodies: Stakeholders suggested that more justification and a robust examination of exact worker numbers and services was required. The proposed worker numbers were commented on in light of the fact that the site lies in an isolated position away from amenities and that it does not align with these stakeholders’ preferred distribution for residential development. However, they accepted that some personnel would need to be located on-site. Respondents have suggested that the campus accommodation should be limited to 700 beds. It was requested that EDF Energy clearly state how the potential social issues of locating a significant number of workers on-site will not have a negative impact on the local community. Further information was requested on the operation and facilities to be provided before being able to confirm its suitability. 4.4.33 Comments were made on locating the on-site campus as far to the north-east of the site and as far away from Shurton as possible. It was also suggested that effective measures should be implemented to prevent unofficial shortcuts from the entire site to Shurton and Stogursey. 4.4.34 In respect of potential legacy use, respondents commented that the on-site accommodation would offer very limited legacy gains to the local community. It was put forward that the accommodation, built for single occupancy use, would not be acceptable for affordable housing once the site is complete. It was felt that it would ‘ruin’ the rurality of the area. The local authorities suggested that the only appropriate legacy option available after construction would be restoration of the southern construction land. Consultees requested that any options on the land be subject to further consultation. 4.4.35 Stakeholders noted that locating workers on-site would potentially reduce traffic movements and the need to travel. 4.4.36 Local Community and General Public: The views from the local community were generally divided on the proposals for an on-site campus. People from the wider area thought all the accommodation (not just the 700 proposed) should be on-site, with appropriate facilities for workers. 4.4.37 However, those living in the immediate area of the site were less convinced about the plans to accommodate 700 workers in a campus on-site. Some people felt moving the accommodation
56 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT away from the southern edge of Shurton would be advantageous. The main issues raised included the impact on the village and its rural setting, increased traffic and how workers would spend their weekends as the village does not have the infrastructure to cope with such an influx of ‘largely single male’ workers. 5) Operational Considerations and Design 4.4.38 Stage 1 presented an initial masterplan and architectural considerations for the permanent development site and outlined the process of power station siting; reactor design; safety and security considerations; and the component buildings, infrastructure and land use for the power station. 4.4.39 Statutory and Non-Statutory Bodies: Stakeholders commented on the masterplan approach and land take. This approach was welcomed by some stakeholders and specific comment was made on the form and legibility of the masterplan, along with promoting high quality architecture through the emergence of architectural design principles. Some stakeholders were keen to provide guidance on the design principles established. The amount of land take for the permanent development at Hinkley Point was also questioned and further information sought on options for reusing existing site areas. 4.4.40 Respondents commented on safety-related issues of reactor design and the GDA process; interaction with military and aviation activity; and potential impact of incidents on police operations. More information was requested by stakeholders on the GDA process and assurance sought that the UK EPR design meets regulators requirements and safety standards. The potential impact of the development on military and aviation activity relating to the requirement for new/altered restricted fly areas, the recommendation of fitting aviation warning lighting to relevant structures and identifying potential impact to land-based military activity was also raised. Further consultation with relevant bodies was requested. 4.4.41 Other responses received relating to operational considerations and design include the wish to gain an understanding of measures to be put in place to ensure sustainable operation and other stakeholders who commented on the provision of further details on the appropriate levels of security and utilities provision, i.e. water and waste water services. 4.4.42 Local Community and General Public: A number of people expressed concern about the safety of the proposed reactor and made reference to a Finnish nuclear power station, which was believed to be running late due to design and safety issues. It was also queried whether the new design had been sufficiently tried and tested. 4.4.43 Concern was also expressed about the risk of leaks, accidents and terrorism. 6) Landscape and Visual 4.4.44 Initial proposals and options for landscaping and restoration, particularly of the southern part of the site following the construction phase, were presented at Stage 1 consultation. Preliminary environmental information on landscape and visual impact was discussed in the Environmental Status Report alongside the presentation of a number of photomontages from key viewpoints. The landscape buffer, part of the landscaping scheme, is discussed in a separate section (see sub-heading 3) Southern Landscape Buffer). 4.4.45 Statutory and Non-Statutory Bodies: As one of the environmental assessment topics, respondents focused on the visual impact of the power station in relation to the masterplan, building materials and landscaping. Comments were received in relation to the methodology of viewpoints and the Landscape and Visual Impact Assessment (LVIA). Further details on the LVIA and additional viewpoints were also remarked upon. 4.4.46 A number of respondents commented on the baseline material provided and sought to clarify points of interest on the factual information and recommended additions to the baseline. A
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 57 STAGE 1 CONSULTATION REPORT
couple of stakeholders discussed the inclusion of more detail on the assessment of the local landscape character to form part of the baseline. Additionally, it was suggested that a visual baseline assessment should be provided for the southern construction area. 4.4.47 Some respondents commented on the photomontages from key viewpoints provided at Stage 1. In relation to the figures provided (Figures 10.11 and 10.12 of the Stage 1 Consultation Document) it was suggested that the development identified a connection between the development and the coastline, and the scale of the development against the existing structures at the site. It was suggested that the appearance of the proposed power station at Hinkley Point C would present a significant risk to the views of the coast and its rural setting. It was also noted that it was not clear as to why the photomontages had been selected and that limited reference was made to them. 4.4.48 Other landscape impact comments were noted in relation to views in the wider landscape setting and cumulative impacts on views from the addition of Hinkley Point C with Hinkley Point A and Hinkley Point B from the Quantock Hills AONB. Clarification was sought on removal of Hinkley Point A and Hinkley Point B buildings in the future. It was also noted that material at Stage 1 was inconsistent in not providing information on the construction activities and their potential landscape and visual landscape impact as provided for the permanent development. 4.4.49 Landscape and visual impact comments relating to the masterplan welcomed its aim to minimise visual impact. Respondents felt that the masterplan needed further development so that it addresses additional key views. It was suggested that preparation of the masterplan and visual assessment should be iterative and that the impression and desire lines of the masterplan would only be effective from a limited viewpoint and not have a positive impact on the wider setting. It was also noted that there was no indication of how the masterplan would propose to minimise impact on the Area of Outstanding Natural Beauty (AONB). Clarification was sought on whether the masterplan would build on the predominant character of the existing complex. 4.4.50 Respondents commented on the provision of viewpoints within the LVIA and one stakeholder provided details on a number of additional viewpoints and requested they be included in the LVIA. It was also commented that the LVIA omitted viewpoints considered essential to assessing impact on historic assets. They also commented on the recognition of historic assets and historic landscape character within the baseline and impact assessment for landscape and visual amenity. 4.4.51 Comments were received on potential landscape and visual mitigation. A stakeholder stated that it was not clear what attempts had been made to mitigate against the ‘inevitable impacts’. They suggested that more needed to be done to ensure a better ‘fit’ into the landscape. Another respondent advised that as part of the mitigation of impacts, the assessment should identify nationally protected landscapes. Suggestions were made for a number of mitigation measures including screen planting of trees; measures to prevent light pollution; and consideration of building material which could reduce visual impact. Clarification was also sought on the interaction of mitigation proposals with Green Lane. 4.4.52 Stakeholders suggested that further details should be provided, including making the LVIA and supporting plans available, in order to fully assess landscape impacts. Further consultation was recommended on the landscaping proposals with key stakeholders. 4.4.53 Local Community and General Public: The main issue raised by the local community was the need to screen the new nuclear build and associated works. Suggestions included replacing natural woodland, grassland, wildlife habitats, planting of hedgerows and constructing a small fence to reduce the visual impact.
58 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 4.4.54 Other suggestions were that land used should be returned to greenfield status after construction and a nature reserve or water feature could be constructed for the local community. Comments were made on the importance of protecting existing flora and fauna, bird population, historic conservation and the need for further public consultation on landscaping and visual issues. 4.4.55 Concerns were also expressed over the loss of footpaths, light pollution and the need to blend the exterior of the power station into the current landscape. The suggestion was also made that the Southern Ridge of the site should be given to local residents. 7) Spent Fuel, Waste and Decommissioning 4.4.56 Decommissioning and the treatment and processes associated with spent fuel and waste were discussed at Stage 1. As an important issue for stakeholders and the local community, comments were received in relation to spent fuel management and decommissioning arrangements. General comment was also made on waste management and sustainability. 4.4.57 Statutory and Non-Statutory Bodies: Respondents suggested that there should be a sustainable approach to waste management and it was recommended that Site Waste Management Plans (SWMPs) should be provided. Some respondents suggested that waste matters had not been addressed sufficiently at Stage 1. 4.4.58 Stakeholders sought clarity on the provision of on-site storage of spent fuel and the potential associated environmental risks. Stakeholders wanted comfort that suitable measures were being put in place to ensure safety. In relation to the European designated sites, stakeholders wished to ensure sufficient environmental mitigation/prevention measures and a full environmental assessment of the facility are provided. 4.4.59 The use of the Hinkley Point C site for the proposed on-site storage of spent fuel was seen as a departure from current practice by some respondents, who also sought clarification on the use of the facility. Consultees requested further information on the provision of on-site storage of spent fuel, including the length of time for storage and spent fuel disposal. 4.4.60 A number of respondents recommended that impacts, if any, on long-term human health and the environment from waste storage should be considered and that a Health Impact Assessment should be carried out. 4.4.61 Other stakeholders asked that more information on the decommissioning strategy and associated environmental considerations be provided. An explanation of the decommissioning plans and funding arrangements was also requested. 4.4.62 Local Community and General Public: Spent fuel and waste management were also key issues for the local community, in particular the storage of long-term spent fuel on-site and the lack of a national repository. Comments were also made about potential health risks and the possible risk of pollution. It was suggested that EDF Energy publicise its proposals in regards to nuclear waste at Stage 2 of its consultation. 8) Marine Development 4.4.63 Marine development and parts of the scheme bordering on the marine environment proposed at Stage 1 comprise: the cooling water infrastructure (including intake/outfall tunnels), sea wall and jetty. Comments relating to those elements subject to preliminary works applications have been identified and discussed in the Preliminary Works section (see sub-heading 1) Preliminary Works). The comments relating to their construction and design are discussed within this section. 4.4.64 Statutory and Non-Statutory Bodies: Stakeholders requested more detail on the construction and design options presented on the cooling water tunnels and mitigation proposed. It was
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 59 STAGE 1 CONSULTATION REPORT
noted that the cooling water tunnels extended through Lilstock firing range and may affect firing activities. Cooling water tunnel arisings and their constitution was also discussed by stakeholders. 4.4.65 Consultees suggested that the potential impact of cooling water would need to be fully assessed, including modelling and assessment work to inform Habitats Regulations Assessment (HRA) and the potential significant impact of the outfall tunnel, associated thermal plume and chemical deposition on designated sites. 4.4.66 Comments relating to the sea wall considered the potential for coastal squeeze implications. Further details were requested on the construction of the sea wall, including treatment of its east and west boundaries, and full assessment of its potential impacts including its interaction with the jetty and cooling water infrastructure. 4.4.67 A number of respondents commented on the construction and use of the jetty. Generally stakeholders welcomed the use of the jetty for transport by sea and to offset HGV movements as a sustainable transport method. More detail was requested on the construction methods and materials intended to be used for the jetty and on the EIA undertaken, particularly in relation to the European designated sites. Assessment was also expected on maritime traffic associated with the jetty, dredging and disposal activities and on implications for firing ranges. Additionally, consultees wished to clarify the planned consenting process intended for the scheme. 4.4.68 Respondents also commented on the marine development works as a whole and discussed the safety aspects, including assessment of military activity on the proposed marine development and vice versa, and the consideration of unexploded munitions or hazardous substances in Bridgwater Bay. Stakeholders also suggested that the marine works could result in a possible loss of fishing grounds, which also has a recreational value. Additional consultation with relevant bodies to address EIA matters in association with marine works was requested. 4.4.69 Local Community and General Public: The majority of respondents on this issue suggested that as much equipment/material as possible should be brought in by sea to minimise the impact on local roads. There was, however, some concern that the extra ship movements would cause more sea pollution. 4.4.70 There were also some comments about the size and location of the temporary jetty, with some respondents wanting the jetty to be as small as possible and located to the east, away from Shurton Beach. The majority want the jetty removed as soon as possible. However, after construction, some suggested that it should be made permanent and used for shipping. 4.4.71 Only a few local people made reference to the proposal for the sea wall. Those that did sought reassurance that it would not affect the rest of the immediate coastline, including Steart Point, and that it would not cause additional localised flooding. 9) On-Site Parking and Access 4.4.72 The proposed on-site car parking and access was outlined briefly in the Stage 1 Consultation Document. Respondents generally commented on the construction of the emergency access road from the south of the site. 4.4.73 Statutory and Non-Statutory Bodies: A number of respondents questioned the suitability and appropriateness of the emergency access road. Clarity on the use, design and management of the route was requested. Issues raised by consultees included the proximity of the route to nearby residents, flood prevention works required and the potential loss of rurality. 4.4.74 A guarantee has been requested that the access road is for emergency use only. Some were concerned that the emergency access at Shurton (between Benhole Lane and Bishops Farm)
60 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT would become a dedicated route to access the workers accommodation. Organisations commented that the access road and gate should not be lit at night and that the gate and fencing should be secured and in keeping with the rural nature of the village surroundings. It has also been suggested that further discussion over the suitability of the access road should be undertaken with them and clearer design details presented. 4.4.75 Stakeholders requested further information about the Hinkley Point C station staff car park. Generally information has been requested on the number of car parking spaces proposed and the use of the outage car park. It was felt that parking should be provided on-site at a level that does not encourage unnecessary trip generation. 4.4.76 Additionally, stakeholders wished to know if EDF Energy proposes to make any changes to the existing access road into the Hinkley Point Power Station complex, which would also be the main access for the proposed development. Respondents also suggested a cycle path being provided along this route, the C182. 4.4.77 Local Community and General Public: The main issue raised by the local community was in relation to the emergency road with suggestions that it should be positioned as far from existing residential properties as possible and shielded by vegetation. Clarification was also sought in respect of how the emergency road would be controlled and whether it would be lit. 4.4.78 It was suggested that a larger car park be constructed on site. 4.4.79 It was proposed that EDF Energy should create an alternative footpath to encourage people away from using the existing footpath at the back of local residential properties. A cycle path along the C182 was also encouraged by some local people currently working at Hinkley Point B. 10) Overhead Line Infrastructure 4.4.80 The Stage 1 consultation provided a description of the existing and proposed transmission infrastructure on-site and the intended method of connection to the National Grid transmission system. A new 400kV substation will be required on site and output from the nuclear power station to the substation would be transmitted through two new EDF Energy overhead lines carried by towers within the site boundary. A figure was provided to indicate new lines, towers and substation. 4.4.81 To facilitate connections between the proposed substation and the national grid high voltage transmission system, six overhead line landing gantries approximately 15m high are required along the southern and eastern boundaries of the substation site. The landing gantries will connect via overhead line to three overhead line terminal towers approximately 48m high outside the substation compound to the south and east. Modifications to the existing overhead line network south-east of the substation will also be required and will form part of a separate Development Consent Order (DCO) application by National Grid. 4.4.82 Statutory and Non-Statutory Bodies: Comments were made on the potential impact of proposed power lines on important bird populations. Respondents recommended that this impact should be assessed. Other comments relating to transmission infrastructure were made in relation to the National Grid connection, which does not form part of EDF Energy’s DCO application proposals for Hinkley Point C, and the relationship between the National Grid connection and the proposals at Hinkley Point. 4.4.83 In terms of National Grid’s proposals, some comments were made on the overhead line route corridors and line entries at the Hinkley Point site, including the proximity to Pixies Mound, and EDF Energy’s plans should the new transmission lines from Hinkley Point C not eventuate. Further consultation was recommended with the local authorities and local interest groups when more detailed proposals are available.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 61 STAGE 1 CONSULTATION REPORT
4.4.84 Local Community and General Public: The local community did not generally address transmission infrastructure as part of the Stage 1 consultation. 11) Amenity and Recreation 4.4.85 With regard to the amenity and recreation resource, Stage 1 consultation provided information on the Public Rights of Way (PRoW) serving Hinkley Point C and the surrounding area, along with results obtained from a Recreational Access Survey undertaken to ascertain patterns of use within this PRoW network. Potential mitigation measures identified to address any adverse impacts on PRoW were discussed, including possible footpath diversions, rationalisation of the existing PRoW network (in consultation with Somerset County Council’s Rights of Way Team), and improvements to existing footpaths and bridleways. Details on further consultation with statutory consultees and the local community, including specific user groups such as equestrians, were also provided. 4.4.86 Statutory and Non-Statutory Bodies: With regard to PRoW, respondents commented that the proposed development would affect a large number of footpaths, and that mitigation should be identified to manage any adverse impacts. In particular, respondents stated that measures should be explored to rationalise the existing PRoW network, whilst ensuring no overall adverse impact on public access. 4.4.87 The consultation undertaken with Somerset County Council’s Rights of Way Team was welcomed, but stakeholders stated that more information was required regarding impacts on existing PRoW, in order to understand how public access at Hinkley Point will be maintained. Respondents noted that a coordinated approach should be undertaken to jointly consider public access and ecological mitigation. 4.4.88 Respondents suggested that alternative PRoW would need to be provided to mitigate for the closure of existing footpaths, and a stakeholder stated that a new PRoW should be established along the western boundary of the Hinkley Point C site, from Benhole Lane to the coastal path. It was also requested that parish councillors be provided with access during construction, in order to monitor works being undertaken on PRoW. 4.4.89 Further information was requested in order to establish impacts on existing PRoW, and that consideration should be given to the maintenance of access between Benhole Lane and the coastal path. 4.4.90 Concern was expressed over the lack of information provided at Stage 1 relating to the provision of on-site recreational facilities. Respondents suggested that the assessment needed to demonstrate a greater understanding of the level of recreational services currently provided within the surrounding area in order to determine the requirements for on-site facilities. Additionally, information would be needed on the type of recreational facilities to be provided on-site, as well as the location of any off-site recreational facilities established to supplement those provided on-site. 4.4.91 Comments relating to the provision of cycle paths were made, recommending the establishment of new cycle routes between Williton and the Hinkley Point C site, and the upgrade of the coastal path to include provision for cyclists. 4.4.92 Local Community and General Public: The main issue for the local community was the disruption to public footpaths and bridleways during the construction period. The majority of people accept that some PRoW would be lost but wanted to retain as many as possible and replace those lost with alternatives. The need for the coastal footpath to be kept open during construction and fully restored afterwards was also stressed. 4.4.93 Additional suggestions included a new PRoW to the north of the village running parallel to the landscape buffer giving people easy access to the countryside. A number of respondents
62 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT expressed concern about the close proximity of footpaths to the back of residential properties and the disruption and possible security risk of greater footfall from workers accommodated on the site. 4.4.94 Several suggestions were made about improving Benhole Lane and making it more passable as other routes to the coast will be restricted. These included creating a green, all seasons path and a footbridge over “the ford” (Bum Brook). 4.4.95 A number of people also made reference to a visitor centre or viewing platform so the public can watch the construction process. It was also suggested that an area at the southern edge of the site should be set aside as an amenity area to compensate for the closure of PRoW during the construction process. 4.4.96 Provision for horse riders was also highlighted and it was suggested a crossing off the main road to the Hinkley Point C site be provided, as this will be a much busier road when construction starts on-site. 12) Historic Environment 4.4.97 With regard to the historic environment at Hinkley Point C, Stage 1 consultation provided information on existing historic assets, identifying specific features, including several hedgerows, historic buildings and a Scheduled Monument, which would require further consideration during the assessment process. The existing environment was identified through desk-based assessments, surveys and a Historic Buildings Assessment. Key issues identified through consultation with statutory consultees were discussed and details provided on further survey work and consultation to be undertaken. 4.4.98 Statutory and Non-Statutory Bodies: Statutory consultees provided the majority of comments received with regard to the historic environment. Consultees acknowledged the high archaeological potential associated with the site. 4.4.99 Some stakeholders stated that a complete assessment of the impacts associated with the proposal could not be made until the results of all surveys were made available, and that these survey results should be submitted at Stage 2 consultation. 4.4.100 Concern was raised over the potential impacts of the development on the character of West Somerset and Sedgemoor, and its broad range of designated and undesignated features. 4.4.101 With regard to the impact assessment process, some respondents stated that the assessment to date demonstrated a limited understanding of the historic assets located within and around the Hinkley Point C site, and noted that a full assessment of the impacts of the proposed development on historic buildings would be required, along with further work to establish the visual impacts associated with the proposed development on the built heritage resource. 4.4.102 Further consideration of the impacts on Scheduled Monuments, and any designated sites, including the Conservation Areas of Cannington and Stogursey, was also requested. In particular, respondents stated that careful consideration should be given to impacts on the setting of Pixies Mound, a Scheduled Monument, resulting from the construction of any new infrastructure. 4.4.103 The opportunity of working with EDF Energy and the local planning authorities to deliver positive legacy benefits to the historic environment was welcomed. Respondents noted that a Strategic Environmental Assessment/Sustainability Appraisal should be undertaken to inform the assessment of impacts on the historic environment, and the subsequent identification of appropriate mitigation measures to manage these impacts. 4.4.104 Local Community and General Public: The local community was also concerned about the visual impact of the new build and the impact it would have on the surrounding area.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 63 STAGE 1 CONSULTATION REPORT
13) Environmental Information and Assessment 4.4.105 Stage 1 consultation provided preliminary environmental information and a summary outlining the status of the EIA process for the Hinkley Point C development proposals. Appendix A.1 of the Consultation on ‘Initial Proposals and Options’ document provided an Environmental Status Report which outlined the environmental baseline for the project area a summary of the work undertaken to date and further studies in progress or planned. It also provided a preliminary view of the key issues associated with the development proposals and the potentially significant impacts, as well as viable mitigation measures. 4.4.106 Statutory and Non-Statutory Bodies: Environmental studies undertaken and proposed were generally welcomed by respondents. The availability of technical documents (survey data and reports) was commented on and a recommendation made that this technical information relating to the environmental topics outlined should be made available either prior to or at Stage 2 consultation. 4.4.107 Some stakeholders made comments relating to provisions included within the Environmental Statement (ES). They wished to ensure the comprehensive and rigorous assessment of the nature and potential effects of the project, also suitable for assessment in line with Appropriate Assessment. There was an expectation of commitments within the Environmental Statement (ES) to monitoring and suitable mitigation measures. Consultation on the ES prior to commencement of works was also requested. 4.4.108 The amount of technical information presented at Stage 1 was commented on by a couple of stakeholders. In summary, their comments related to the inclusion of further details on baseline, methodology, assessment and proposed further studies that should be addressed to provide transparency and a thorough assessment. In respect of the availability of survey data and other information, it was requested that this information should be made available to stakeholders as soon as possible, particularly in relation to marine, coastal and terrestrial ecology surveys, conservation and ecology designations, landscape and visual assessment and archaeology data. 4.4.109 Specifically, it was recommended that additions to baseline assessment and further information, or clarity on baseline material, be provided in a number of environmental topic areas. The baselines provided for the remaining environmental topics outlined at Stage 1 were considered to be adequate. These comments were also made in relation to the proposed studies outlined. In order to establish confidence in the environmental studies undertaken in support of the EIA, provision of further details on the scope and timing of Phase 2 intrusive investigation was advocated. 4.4.110 Additional information on assessment methodology and on modelling or studies undertaken was requested in some topic areas. Furthermore, information on potential impacts and data analysis or on assessment findings was also sought. 4.4.111 Comments were made on the inclusion of references to source material and guidance used for assessment. In a number of topic areas this was believed to be inadequate and more detail should be provided. Further information was also sought with reference to technical consultation undertaken and agreements made on assessment or further work recommended by key consultees. 4.4.112 Additional graphical material in a number of environmental topics was also considered necessary. 4.4.113 Local Community and General Public: Although the local community did not raise specific issues in relation to the Environmental Impact Assessment, a range of environmental issues
64 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT were raised which are summarised in the following section (see local Community and General Public section in sub-heading 14) Other Environmental Issues). 14) Other Environmental Issues 4.4.114 As discussed in the previous section above on environmental information and assessment (see sub-heading 13) Environmental Information and Assessment), preliminary environmental information and a summary outlining the status of the EIA process for the Hinkley Point C development proposals, was presented at Stage 1. As well as those categories covered previously, stakeholders commented on a number of additional areas of environmental assessment relating to the development at the Hinkley Point C site. These are more technically detailed and specific to environmental topics and are set out below. 4.4.115 Statutory and non-statutory bodies commented on the following environmental topic areas: i) Hydrology, Drainage and Flood Risk 4.4.116 A number of comments were received with respect to flood risk. A fully compliant and comprehensive Flood Risk Assessment (FRA) is considered necessary for this development, including the consideration of decommissioning and spent fuel storage phases, and the sea protection scheme. The fact that new development should be compliant with Planning Policy Statement (PPS) 25 (Development and Flood Risk) was also highlighted by a respondent. Although the key issues were identified by EDF Energy, it was noted that there would need to be a linked to a mitigation strategy and future survey programme. 4.4.117 Consultees wished to ensure that flood risk and surface water drainage are managed effectively with no increased flows into watercourses in the Stockland area. Statutory consultees were concerned about the exacerbation of flood risk and suggested a number of mitigation measures that could be implemented. Comment was made on the culverting of Holford Stream, which would only be consented if the need was proven to be exceptional and there would be no adverse impact on flood risk, amongst other considerations. 4.4.118 Stakeholders wished to participate in ongoing discussions relating to the assessment of flood risk or where works impact on an area of their concern. ii) Groundwater and Land Contamination 4.4.119 In general, comments received on issues relating to contaminated land and groundwater demonstrated that a satisfactory level of baseline information was provided during Stage 1. Whilst the methodology was deemed adequate and appropriate, the stakeholders would welcome further detail on source data, survey locations and analysis results, as well as details of consultations with statutory bodies. 4.4.120 A number of comments were received which discussed the potential for existing land contamination, particularly concerning sources within the identified Built Development East, and the potential contamination created (and its potential impact) during construction, operation and decommissioning periods. Respondents noted that this, along with survey findings, was not reported on at Stage 1. 4.4.121 Depending on the type of contaminants identified, it was suggested that these could have implications for a number of aspects of the scheme including health and safety. Respondents stated that precautionary measures should be used to prevent run-off. They also noted that a detailed scheme should demonstrate appropriate disposal of surface water and protection of controlled waters. 4.4.122 It was recommended that assessment was needed of the potential dewatering operations during construction and that reference be made to how potential land contamination impacts
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 65 STAGE 1 CONSULTATION REPORT
could be addressed and mitigated. Additionally, further studies and investigations were requested. 4.4.123 Statutory consultees commented on groundwater in terms of disposal of discharged waters from the dewatering process. They requested that this should be included in future assessments. Respondents recommended that pollution prevention measures and related guidelines be followed; sought assurance that the sewerage infrastructure would be adequate to deal with the development; and commented that hydrological assessment should be considered, including the breaching scenario, discharge water quality and sea levels. iii) Terrestrial and Marine Ecology 4.4.124 Stakeholders commented that they were satisfied that sufficient data was now available in relation to the Hinkley Point C site to inform the baseline of the EIA. However, they stated that more work was required to address overall impact of the development together with the associated development sites in order to assess overall ecological impact. Consideration should further be given to the in-combination effects with other projects or plans. Respondents sought confirmation of whether statutory consultees had agreed that no further terrestrial and marine ecological surveys were required. 4.4.125 It was suggested that a comprehensive and timely mitigation strategy should be provided to address ecological impacts and demonstrate community benefit and net gain for biodiversity. Assurance was sought that species and habitats would be conserved and impacts mitigated. It was suggested that this could be worked with other projects in the area through strategic mitigation. It was noted that periodic surveys may be needed during the lifetime of the project to ensure mitigation measures are properly managed and sustained where necessary. 4.4.126 Other comments recommended that development proposals should be multifunctional where possible. For example, the southern landscape buffer, which would provide screening during the construction period, could be retained and enhanced to provide an ecologically valuable habitat. 4.4.127 Respondents commented on the need to assess the potential impacts from lighting during construction and operation of the Hinkley Point C development, in particular on sensitive ecological receptors such as bat and bird species. Consultees suggested that at Stage 1 there was inadequate consideration of planning mitigation to minimise the potential effects of lighting. 4.4.128 Stakeholders also encouraged the proposals to protect and enhance the existing natural heritage, and if possible provide a net gain in local biodiversity which could potentially be achieved through a project of this scale. To achieve this, and avoid substantial biodiversity loss, it was recommended that a site-wide landscape strategy be developed incorporating comprehensive ecological mitigation including networked habitat creation and avoidance of habitat fragmentation be prepared. iv) Noise and Vibration and Air Quality 4.4.129 Specific comments on noise and vibration and air quality requested that the assessments should consider both human and non-human receptors, including potential noise and vibration effects on marine species. It was also recommended that consultation with local authority Environmental Health Officers is undertaken to agree the scope and methodology of the noise and vibration assessment, and, similarly the air quality assessment.
66 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT v) Coastal Geomorphology, Hydrodynamics, and Marine Water and Sediment Quality 4.4.130 Respondents had a sound understanding of the elements of the Hinkley Point C development which could have a potential effect on the marine environment including coastal geomorphology, hydrodynamics, and marine water and sediment quality. Comments suggested that further surveys and analyses of marine water quality would be required in-combination with modelling of coastal processes. 4.4.131 Comments were made on hydrodynamics and coastal geomorphology in respect of coordination and compliance with relevant data, Shoreline Management Plans and legislation. Consultees also sought confirmation of whether impacts from the sea wall and wider environmental effects had been considered in the EIA. vi) Radiological 4.4.132 Respondents sought further information with respect to any potential radiological doses on human and non-human species and recommended that sensitive habitats should be considered in modelling and that potential health impacts, if any, should be addressed. Further information was also sought on the methodology employed for radiological dose assessment, including that critical group doses should be assessed below 20 microSievert, i.e. negligible, and that the meaning of “so-called detection limits” be explained in the ESR provided at Stage 1. 4.4.133 A respondent sought a better explanation of the radioactivity in drinking water standards than that provided at Stage 1. Consultees proposed that Radioactivity in Food and the Environment (RIFE) reports should be included in the information provided on the development and that full details of completed studies should be made available. Additionally, a respondent suggest that they were unhappy at being unable to comment at Stage 1 until the practice is Justified. vii) Designations 4.4.134 There was considerable interest over the assessment of potential impacts on designated sites, including the ecologically sensitive European designated sites, Bridgwater Bay National Nature Reserve and SSSI; County Wildlife Sites; the geologically significant Blue Anchor to Lilstock; and Areas of Outstanding Natural Beauty (AONB) in the surrounding area. It was recognised that the development had the potential to affect the integrity of designated sites and there is a potential need to undertake an Appropriate Assessment (AA). viii) Cumulative and In-combination Effects 4.4.135 A number of comments were received which reiterated the EIA regulatory requirement to provide an assessment of cumulative effects, in particular the in-combination effects with other consented or reasonably foreseeable projects, or plans that have a spatial or geographical overlap with the potential effects associated with the Hinkley Point C Project. These included: the proposed National Grid transmission system; the existing Hinkley Point Power Station Complex; decommissioning of Hinkley Point B; development of Oldbury nuclear power station; the Steart Managed Realignment Project; and other major projects in the area. A respondent suggested that the in-combination impacts of the proposed development on the Severn Estuary environment could not be mitigated. Additionally, it was noted that the Stage 1 documentation had not identified potential cumulative contamination and waste issues. 4.4.136 Further information was requested on the potential in-combination and cumulative socio- economic impacts, including the methodologies used to assess these impacts. Respondents stated that sufficient information should also be provided in the ES on appropriate legislative requirements and assessment. Additionally, consultation with stakeholders was encouraged to discuss the consideration of in-combination and cumulative impacts.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 67 STAGE 1 CONSULTATION REPORT
ix) Sustainability 4.4.137 A number of comments were received relating to sustainability for both the construction and operational periods of the development. Areas concerning sustainability raised by consultees included: meeting energy efficiency and environmental standards, such as CEEQUAL and BREEAM; alignment with regional and local objectives, as well as project objectives; and sustainability in other initiatives including the supply chain and education and training. 4.4.138 Local Community and General Public: A range of environmental issues were raised by the local community including the need to minimise the carbon footprint of constructing the new power station and the associated development, rising sea levels, impact on the marine eco-system and questions about emissions, flood risk, noise and pollution. 4.4.139 It was also suggested that the public need to see an EIA and sustainability appraisal in order to make informed comments on this issue. 15) Other Hinkley Point C Development Site Comments 4.4.140 Some comments were made on the proposals at the Hinkley Point C Development Site that have not been covered under the categories discussed above due to their specific nature. 4.4.141 Statutory and Non-Statutory Bodies: NHS Somerset made a number of comments relating to the on-site medical facility provision and sought clarification of its use, functioning and services available. 4.4.142 Local Community and General Public: There were no comments from the local community on other main site issues. All comments received are covered in the other sections in this report relating to main site development.
4.5 Summary of Comments on Associated Development
16) Overall Associated Development Strategy 4.5.1 The Stage 1 consultation presented a series of options for the siting of accommodation and transportation measures to mitigate the impacts of the proposed development, in particular during the construction phase. Comments were invited at Stage 1 in respect of the location and scale of developments, as well as the potential legacy benefits for the local community following EDF Energy’s cessation of use of those sites. 4.5.2 Statutory and Non-Statutory Bodies: Stakeholders commented on a wide range of issues, including impacts and mitigation measures of the off-site associated developments, potential legacy use and community benefits. In particular, specific environmental issues related to the search areas were raised. 4.5.3 The principles of the strategies to conform to the objectives were generally supported. Respondents requested further justification of the off-site associated development strategy and recommended a comprehensive development strategy as a necessary supporting document. 4.5.4 Respondents suggested that EDF Energy should clarify the potential impacts that the off-site associated developments may have on the wider area in terms of environmental, amenity and other impacts. They stated that other issues such as tourism, housing, transport and quality of life should also be considered. 4.5.5 There was concern that the proposed developments may increase traffic activity in the local area. One respondent claimed that increased congestion could interfere with its day-to-day operations.
68 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 4.5.6 A respondent commented on the possible impacts to the historic environment and advised that these should be appropriately assessed. 4.5.7 Several respondents raised concerns about the impacts on ecology. It was suggested that appropriate mitigation should be incorporated into all proposed developments to limit potential impacts. 4.5.8 It was requested that any proposed developments should seek to reduce local flood risk, in accordance with PPS25. 4.5.9 Several consultees raised population increase as a major concern. Respondents suggested that the rate of growth in Sedgemoor and West Somerset may increase as a result of the proposed development and that relevant services will need to be put into place. 4.5.10 A number of respondents commented on the opportunity for leaving a positive legacy from the off-site associated developments in order to address the needs of the local community. Respondents stated that further clarification should be provided in respect of any long-term uses be proposed by EDF Energy. 4.5.11 It was suggested that both the accommodation and transport strategies should take into account other developments in the local area in terms of cumulative impact. It was also suggested that any cumulative impacts of the whole Hinkley Point C development should be presented, including all of the proposed on and off-site associated developments. 4.5.12 Local Community and General Public: The local community responses were on similar lines to the stakeholder comments, including: concern about the overall impact of the associated development on the area; that developments should be focused within existing town centres, especially Bridgwater to the east nearer to the motorway, and suggestions for alternative sites to the ones proposed. Some respondents were supportive of the potential for accommodation to be used as affordable housing (as legacy) following EDF Energy’s cessation of use. 4.5.13 There was a general view from the local community that a northern Bridgwater bypass should be provided to relieve traffic congestion through Bridgwater and Cannington. Local opinion was that such a bypass would also help to limit adverse impacts on tourism and the local, rural villages. 4.5.14 A number of people within the local community felt that the development could cause disruption and social problems but there were also suggestions that the workers could bring custom to the local area. Local perception was that development could also put a strain on existing health facilities and other local infrastructure in the area. 4.5.15 Some comments focused on the traffic increase in the local villages as being a potential negative legacy arising from the movement of workers and the provision of accommodation during the construction phase. A couple of respondents expressed the view that any siting or land uses of the associated developments should be consistent with the emerging West Somerset Council Local Development Framework and strategies of the local authorities. 17) Overall Accommodation Strategy 4.5.16 The Stage 1 consultation presented options for accommodating workers during the construction phase. As well as ongoing discussions with local authorities and stakeholders, comments were invited from statutory consultees and the local community on the need for and suitability of the campus proposals, along with identification of possible legacy benefits for the local community. 4.5.17 Statutory and Non-Statutory Bodies: Stakeholders commented on a wide range of issues relating to the overall accommodation strategy, many of which concentrated on the impacts on the local community, alternative location suggestions and possible legacy benefits.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 69 STAGE 1 CONSULTATION REPORT
4.5.18 Mixed comments were received on the overall accommodation strategy. A respondent suggested that the majority of the associated development sites should be located in or around Bridgwater, and that the proposed strategy is in fact a temporary one, which does not extend to any wider impacts. 4.5.19 The promotion of non-car based transport to and from the proposed campus accommodation was supported by several consultees. 4.5.20 A number of consultees commended plans for high levels of sustainability as part of the building designs of the campuses. 4.5.21 It was expected by respondents that the campuses should achieve the same design standards as any other permanent development. Respondents recommended that the visual impacts on the surrounding areas be considered. 4.5.22 The main issues raised centred on the social and community impacts on the surrounding areas. It was recommended that a full assessment of social and community infrastructure requirements should be undertaken and further consultation with infrastructure providers. Other respondents also listed increased pressure on public services and schools as a main concern. 4.5.23 It was also raised that a possible large migrant worker population could result in a loss of community identity and potential increase in law and order issues. Respondents requested that EDF Energy work with them to positively integrate the non-local worker population into the existing communities. It was recommended that EDF Energy outlines its contingency plans to deal with higher than predicted non-local worker numbers. 4.5.24 There was concern that workers using local bed and breakfast accommodation might have a negative impact on the tourism industry. A respondent advised that an increase in bed and breakfast occupancy during the winter months may not compensate for the loss of bed space available to tourists, in particular during the summer months. 4.5.25 Stakeholders felt that increased demands on residential housing might exacerbate current problems of affordable homes for young people in the area. They stated that further information should be provided on this issue to demonstrate that the impact on housing can be managed in both the long and short term. In contrast other respondents suggested that local accommodation should in fact be the first route to be explored before creating purpose built campus accommodation. 4.5.26 Several potential legacy uses were recommended by respondents, including affordable housing, student or sheltered accommodation. Consultees suggested that further information is needed in relation to possible legacy scoping criteria and careful consideration should be given to the layout of the campus in order to best serve the local community through the provision of shared facilities. 4.5.27 Further information was sought from consultees to clarify points related to the accommodation strategy. Clarification was also sought on how consents will be achieved for campus developments. 4.5.28 Local Community and General Public: The local community commented on similar issues to the stakeholders such as the impact on tourism, the need to locate workers near to amenities, to train and employ local people in order to limit the accommodation needed and to create high quality developments for future use. A number of respondents commented on the need to integrate workers by spreading out the accommodation, which they felt would also help to limit the impact on existing communities. A number of respondents suggested that the view of those living in areas where development is proposed should be given greater consideration.
70 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 4.5.29 A recurring concern was the potential impact and disruption to local rural communities, which local people believe have insufficient infrastructure to cope with the workers coming to the area. It was also suggested that the park and ride, freight handling facilities and accommodation should be located in towns not in the local villages. 4.5.30 Other recurring themes in the comments regarding accommodation strategy were to use existing industrial areas or brownfield sites, use a mixture of accommodation methods and create housing rather than campus accommodation for future legacy. Some respondents suggested that the accommodation should just be located at the Dunball area (M5 Junction in association with a northern Bridgwater bypass) and on-site. Other responses were that the associated development sites should be returned to previous use after cessation of use. 4.5.31 In the responses from the local community there were a number of suggestions to use existing accommodation available provided it does not undermine the local tourist industry or existing tenants. 4.5.32 A number of respondents also suggested alternative sites that might be suitable for the associated developments. Several commented that a mix of accommodation approaches could benefit the surrounding areas. 4.5.33 The local community felt that the use of off-shore accommodation would be a positive way to accommodate EDF Energy workers. 4.5.34 Other suggestions were that there would be a need for policing of the accommodation and that campus accommodation should be located away from the villages to limit disruption. 18) Overall Transport Strategy 4.5.35 Information was presented at Stage 1 on the draft travel plan, which proposed to move workers and construction material whilst minimising disruption to the local area. It outlined EDF Energy’s commitment to minimise disruption to the local community and promote sustainable modes of transport to protect the environment. Comments were invited on the strategy as a whole, which included options for park and ride facilities, freight logistics, bypass routes, road improvements and upgrades to Combwich Wharf. Key issues raised by consultees included environmental issues, possible effects on traffic, legacy and mitigation. 4.5.36 Statutory and Non-Statutory Bodies: The benefit of the proposed freight handling facilities was generally accepted by respondents as having the ability to minimise traffic impact on the local highway network. It was generally felt that the freight handling facilities should be located at the point closest to the source, therefore near to motorway junctions. 4.5.37 Generally consultees were supportive of measures to decrease pressure on the local highway network and improve transit times. A number of consultees supported the provision of park and ride facilities on the basis that the proposals will minimise the number of individual vehicle movements by consolidating trips. 4.5.38 The issue of car parking was raised by a respondent in terms of how the park and ride strategy will integrate with car parking on-site and around the proposed developments. It was suggested that stringent parking measures should be adopted in and around Hinkley Point C to ensure workers comply with the use of the park and ride facilities. A respondent warned that Cannington and Bridgwater could become areas that people drive around, rather than through, as a result of the park and ride strategy and that this could have an adverse effect on local businesses. 4.5.39 Respondents commented on the inadequacy of the present road system and requested the need for significant investment. Details of, and requirements for, these road improvements should be clarified further. Suggestions were put forward on possible improvements including
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 71 STAGE 1 CONSULTATION REPORT
the development of major junctions and the widening of certain roads to make them suitable for heavy traffic. 4.5.40 Several consultees commented on the possibility of using rail services as an addition to the travel plan. Enhancements to the rail services between Minehead, Taunton, Williton and Bridgwater were suggested as positive additions to the travel plan. In contrast, a respondent stated that the current train service in Bridgwater is already running at capacity and an increase in passenger numbers could have a negative impact. 4.5.41 A consultee stated that they were against all off-site associated developments due to traffic implications. Many respondents commented on the existing over-reliance on the A39, citing that motorway traffic use it as a diversion in the event of a motorway incident. It was suggested that increased accommodation in West Somerset would, in turn, increase journey times for leisure and business use on the A39. 4.5.42 Concerns were expressed about increased noise and air pollution, safety issues and increased congestion on the A38 and the Bridgwater Northern Distributor Road. It was suggested that traffic-related noise, vibration and air quality should be assessed as part of the EIA, with a respondent requesting copies of the assessments to be made available. 4.5.43 More detailed information on environmental impacts and mitigation strategies of the park and ride and freight handling facilities was requested by consultees. 4.5.44 Many consultees support the implementation of a sustainable travel plan to include measures to encourage non-car modes of transport. Further clarification as to how these measures will be implemented was requested. Respondents also stated that consideration should be given to cycle and footways across Bridgwater to ensure continued safe access for schools and the local community. 4.5.45 It was suggested that potential travel issues be outlined within a mitigation strategy and that impacts arising from the changes to traffic patterns should be addressed. 4.5.46 Further investigations and discussions into the long-term viability of park and ride as a legacy benefit were considered necessary. Several consultees welcomed the opportunity to provide positive legacy of transport infrastructure to the area and suggested further investigation into the ongoing viability of the park and ride facilities as a legacy benefit. 4.5.47 Respondents requested consideration of other proposed developments in the area to identify potential cumulative impacts on the local road network. It was stated that a strategy identifying such impacts and the management of them is considered an essential element of the pre- application consultation. 4.5.48 Several consultees expressed views that a Bridgwater bypass, comprising a bridge over the River Parrett to link to the M5, would be preferable. In contrast, some respondents suggested that a Bridgwater bypass might have a negative impact on the Steart Common SSSI. 4.5.49 Several consultees stated that further clarification on the transport proposals is required before an informed decision can be made. The scale of the transport facilities at Cannington, Combwich and Williton were questioned. 4.5.50 Local Community and General Public: The local community commented on similar issues to the stakeholders in respect of transport strategy. The main theme of comments was the belief that existing local transport infrastructure is not capable of coping with EDF Energy’s proposals. 4.5.51 Issues were also raised about the general disruption to the local area, proposed siting of the facilities, crime, use of greenfield sites, positioning facilities on heavily used routes and clarification on whether these facilities would be needed after the construction phase.
72 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 4.5.52 A large number of comments focused on the need for a northern Bridgwater bypass from Dunball across the River Parrett. It was suggested this should join the Hinkley Point road (C182) near the site to alleviate the traffic from the local roads and to avoid Cannington. 4.5.53 Other suggestions were to improve rail links, provide new cycle paths, keep to off-peak travel, create better roads, deliver a sustainable travel plan, improve existing roads, survey traffic and provide more facilities on-site to minimise the impact on surrounding areas. A number of respondents suggested greater use of the existing water approaches to carry more freight by sea. 4.5.54 Some local respondents commented that further traffic modelling was required to gain insight into the local area. Respondents commented that local roads are already overcrowded and the extra traffic proposed would increase danger on the roads and traffic problems. A couple of respondents expressed concern over the management of the park and ride and freight handling facilities. 4.5.55 The majority of comments made by the local community suggested that there would be insufficient demand for the park and ride facilities. A significant number of respondents stated the park and ride facilities are not needed due to lack of demand in the local area and that the facilities should not be retained after cessation of use but that more parking should be provided at the Hinkley Point C site. A few people commented that the park and ride facilities would be more successful if they were smaller and in different locations. 4.5.56 A small proportion of the local community respondents expressed the view that the park and ride proposals were a positive asset to the local community and could help reduce traffic flow in the area. Some suggested that the park and ride facilities should be retained after cessation of use by EDF Energy for use by local residents and operational staff from Hinkley Point. 19) Cannington 4.5.57 Stage 1 presented a number of proposals for the village of Cannington across four sites, which included a possible campus, freight handling and park and ride facilities. Comments were sought on the preferred location and scale of the developments, suitability and potential legacy benefits for the local community. The Cannington bypass summary is included separately within this report. 4.5.58 Statutory and Non-Statutory Bodies: Consultees commented on a wide range of issues, including potential impacts on the village, social and community issues, and legacy benefits for the local community. Comments were received on the strategy for Cannington as a whole, as well as on a site-specific basis. 4.5.59 A respondent recommended that Bridgwater should be the focus for residential development, with CAN-C being the preferred Cannington site for limited campus accommodation. Refurbishment of existing accommodation on this site was also supported, subject to design approval. In contrast, other respondents suggested that CAN-A and CAN-B are not suitable for development on the grounds that they would impact on the village setting. 4.5.60 A number of consultees were opposed to the freight handling facilities proposed at Cannington and requested the need for such a facility to be demonstrated. Overall respondents preferred the proposal at CAN-B due to the reduced disturbance to residential properties. A number of respondents were also opposed to the proposed park and ride facility, stating that other sites closer to the motorway would be more suitable. 4.5.61 Further information was requested on how the associated development sites will resolve traffic issues. Several stakeholders requested that the proposed associated developments be supported by a robust traffic assessment and be incorporated into the travel plan as appropriate.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 73 STAGE 1 CONSULTATION REPORT
4.5.62 Respondents suggested that the locations of CAN-C and CAN-D could create greater traffic impacts on Cannington village. If CAN-A is to be developed, it was requested that traffic should not be adversely affected by a new bypass. 4.5.63 A consultee requested more details on the access arrangements for all sites and recommended that sustainable transport measures should be provided. A number of consultees suggested the need to implement traffic-calming measures within the village and requested assurance that buses for workers will stick to the A39/C182 route. 4.5.64 Ecological issues were raised by several consultees, primarily requesting further information as to how the setting of the Cannington Conservation Area, Cannington Brook and Putnell Moor would be protected should CAN-A or CAN-B be progressed. It was noted that no information was provided at Stage 1 on the wildlife surveys to be carried out at CAN-A. A stakeholder suggested that foraging bats and veteran trees are likely to be of interest at CAN-C. 4.5.65 There was concern that the proposed developments might increase the possibility of flood risk to “the nearby farm”. It was suggested that Cannington is prone to flooding and that the hard surfaces of a park and ride facility and freight logistics might increase this risk. 4.5.66 A respondent stated that all four search areas fall wholly or predominantly within flood zone 1, meaning that they are at little or no risk of flooding. It was, however, suggested that as the Cannington Brook runs through CAN-A, the site layout would require further investigation to establish the viability of development in light of the floodplain constraints. Monitoring points along the Brook would be expected. 4.5.67 It was commented that CAN-C and CAN-D are acceptable for development “in principle” but that CAN-A offers the potential to implement a flood protection scheme for Cannington, leaving a positive flood risk reduction legacy for the village. It was recommended that all sites be subject to a FRA. 4.5.68 It was suggested that further investigative work would be needed at CAN-A, CAN-B and CAN-C with regards to groundwater abstractions and queried the prevention measures to avoid land contamination. 4.5.69 A respondent advised that CAN-C and CAN-D are located in an Area of High Archaeological Potential and further assessment would be needed prior to any planning applications. Cannington quarry is also a designated County Geological Site, meaning that significant archaeological remains have been found there in the past. On this basis, one respondent did not support the use of the quarry as a spoil tip unless a full assessment of the alternatives is presented. In contrast, another respondent stated that temporary use of the quarry for spoil might be suitable. 4.5.70 Respondents suggested other potential impacts to the village, including loss of village character and identity, and increased policing needs as a result of the potential migrant worker influx. It was questioned whether measures and funding would be put in place to positively integrate workers into the local community. The completion of a socio-economic study was recommended to identify social and community infrastructure requirements in Cannington that are associated with worker households. 4.5.71 A number of consultees discussed the possible legacy benefits of a campus in the village. Several suggestions were put forward, including affordable housing, sports facilities and student accommodation. It was recommended that further consultation be undertaken to enhance the opportunities for legacy use of the campus recreational facilities. Should CAN-A or CAN-B be progressed, respondents stated that full restoration/legacy proposals would be required where temporary developments are to be located on agricultural land.
74 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 4.5.72 One respondent supported refurbishment of existing accommodation at CAN-C, subject to design approval. It was noted that where there is quantifiable unmet affordable housing in a village, the Council might be willing to release land in order to address this need. In contrast, another respondent dismissed the idea of leaving CAN-C accommodation to affordable housing as they did not consider that the benefits outweighed potential loss of village life. 4.5.73 Several consultees stated that they would rather no development occurred in Cannington and would like the associated development strategy to be reassessed to consider the benefits of historic assets. Further justification regarding the scale of the proposed developments at Cannington was sought. 4.5.74 Local Community and General Public: The local community commented on similar issues regarding accommodation and park and ride facilities in Cannington. Respondents expressed opinions on issues such as traffic generation, loss of village identity, noise and light pollution, use of greenfield sites, devaluation of property, concern about crime and that the existing infrastructure would not be able to cope. 4.5.75 A number of respondents suggested that accommodation in Cannington could cause social problems as the village is a small size with limited existing recreational facilities. Concern was also expressed over the safety of the children in the area. A few respondents also felt that the level of development proposed would undermine the village identity of Cannington. 4.5.76 However, several consultees highlighted the positive aspects of accommodation in Cannington such as new facilities and the integration of workers into the local community. 4.5.77 Overall there was a mixed response with regard to accommodation legacy. A large proportion of the respondents felt there should be no accommodation in Cannington as more housing is needed in Bridgwater and Minehead and that if accommodation is needed, then temporary buildings should be constructed at Cannington College. However, a number of people commented that the village could benefit from the accommodation being left after EDF Energy’s cessation to convert into a residential care home, a hotel, affordable housing or leisure and sports facilities. It was also felt that accommodation should be constructed where it benefits the local community the most. 4.5.78 The CAN-A site received mainly negative comments with suggestions that the proposals would be detrimental to the area due to the environmental impact, noise pollution, light and air pollution, building on a flood plain, the dangerous existing road infrastructure and the close proximity to existing dwellings. A few other comments offered the opinion that it could be a good place to build a hotel and that park and ride was a good option, as it would limit traffic entering Cannington. 4.5.79 The proposed accommodation at site CAN-B received mainly positive responses with respondents describing the proposal as the best option for expansion of the College, which would benefit the local community economically and bring future legacy. However, several consultees felt the college expansion would be detrimental to the area and it would not be suitable for the college students to be located next to the workers. 4.5.80 The majority of respondents suggested that a park and ride should not be developed in Cannington as the proposals are on dangerous roads and may increase the likelihood of traffic accidents. It was also felt that the workers would not use the park and ride and that it would have no future benefit or legacy. Many respondents stated that there should not be both accommodation and park and ride developments in the village. A few respondents expressed the view that the park and ride development could benefit the local community and students when linked to the eastern bypass. A few comments were also made about the dangerous road link at Chad Hill.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 75 STAGE 1 CONSULTATION REPORT
4.5.81 There were several comments that CAN-A park and ride would have a negative impact due to the increase in noise, traffic on the A39 and the effect on the local residents. 4.5.82 Similar comments were made on the CAN-B site as several respondents commented that the site was too close to existing dwellings and the wrong side of the village. 4.5.83 Most respondents felt that the freight handling facilities would have a negative impact on Cannington due to environmental implications, location of an industrial site in the village and the proximity of the southern site to existing dwellings. 20) Cannington Bypass 4.5.84 Within the transport strategy proposal at Stage 1, options for a Cannington bypass were presented. Comments were invited on the preferred route options, necessity and suitability of the proposals, and the potential traffic impacts for the local area. 4.5.85 Statutory and Non-Statutory Bodies: Stakeholders commented on several issues relating to the bypass including environmental and ecological impacts, preferred options, impact on the local area and the strategy in general. A bypass strategy for Cannington was supported by the majority of consultees. 4.5.86 A respondent requested more information on a number of issues in order to comment definitively. Traffic modelling, further ecological and environmental surveys, a traffic-related environmental assessment to support the western option and possible provision of funding, were all points raised as needing follow-up information. 4.5.87 Consultees raised concern about the use of Cannington as a short cut for traffic. To make the bypass a more ‘attractive’ option, calming measures were suggested as a possible solution to deter through-traffic. Stakeholders requested additional information on the volume of anticipated traffic through Cannington. 4.5.88 A respondent noted that the western option would be to the detriment of non-nuclear traffic and a suggestion to widen areas of the A39 was made. Several consultees also stated that they believe the eastern bypass will not alleviate problems on the A39 and the straighter route could potentially increase traffic speeds. 4.5.89 It was suggested that both route options are too close to residential properties in the village, with the western option potentially bringing increased noise, dust and pollution. 4.5.90 A numbers of respondents suggested that the western bypass would have less impact on the local ecology as it is located a good distance away from any protected habitat sites. 4.5.91 It was suggested that the eastern route will have a greater impact on local biodiversity as it cuts through land with established badger setts. A respondent advised that the proximity to the Severn Estuary Special Protection Area (SPA) should also be a matter for consideration. Further ecological and environmental assessments were requested. 4.5.92 The western route was considered the preferred option by many consultees. The smaller land take and location of this route was considered beneficial from a landscaping perspective. 4.5.93 A consultee advised that the western route is located entirely within flood zone 1, meaning that there is little to no risk of flooding. A respondent advised that the eastern route falls predominantly in flood zones 3A and 3B, and is likely to pose the greatest engineering challenge for construction. 4.5.94 It was suggested that the eastern route would have to be raised in order to avoid flood risk issues and that this might offer positive legacy benefits to the village in the form of enhanced tidal protection. In contrast, a respondent claimed that this option could pose as a potential
76 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT flood hazard by keeping water in at times of flood. Several consultees requested the need for a FRA. 4.5.95 It was suggested that both routes will need further ground investigation work due to their proximity to a historic landfill feature and licensed groundwater abstraction. 4.5.96 A respondent suggested that further consultation between EDF Energy and local stakeholders should take place to discuss the possible legacy benefits. Concern was raised that the eastern bypass route will limit possible expansion of the golf course and equestrian centre. 4.5.97 A clear justification for the need of a bypass was sought. Respondents advise that the bypass must only be considered if the transport strategy indicates an overwhelming need for one. 4.5.98 Local Community and General Public: There were a number of objections to the proposed Cannington bypass options for a variety of reasons including damage to the environment and concern about increased traffic, noise and light pollution. 4.5.99 Concerns about the impact on the environment included possibility of flood risk, loss of wildlife and natural habitats, particularly in relation to badger setts, damage to footpaths and the impact on the existing landscape. 4.5.100 There was also some concern that a bypass would not help alleviate the impact of additional vehicles on local roads and that traffic would still use the village as a rat run. 4.5.101 Respondents in favour of the bypass felt that it would help divert traffic away from the village and stop it overloading the existing bypass. A number of comments were received that the bypass is needed but that the current proposals set out at Stage 1 did not provide the best option for the village. 4.5.102 A large number of respondents suggested that a better option would be a northern Bridgwater bypass from Junction 23 of the M5, across the river Parrett, which would completely remove the requirement for a Cannington bypass. 4.5.103 Others suggested that traffic from Bridgwater be taken off the A39 onto a new bypass at Sandford Corner and that further improvements were needed to the existing road structure. A few comments focused on the possibility of a rail link instead of a bypass or that more materials could be brought in by sea. 4.5.104 Those in favour of a bypass stressed that it should be completed before construction begins on- site and that it should be combined with speed reduction measures in the village. 4.5.105 Of those in favour of a Cannington bypass, the local community’s comments on the options were divided but slightly more people felt that the eastern option would cause less disruption and had the potential to leave a flood barrier as a future legacy for Cannington. 4.5.106 Those in favour of the western bypass route felt it would affect fewer dwellings and be the shorter and more favourable option. However, others disagreed with this and suggested that the western bypass would cause significant disturbance to car users and tourism. 4.5.107 The need to protect Brymore School was raised by a number of respondents concerned about the potential impact of the western route option, in particular the need to protect the school’s agricultural educational facilities. 4.5.108 Several respondents also remarked that traffic approaching from the east would not use the western option and those drivers were more likely to drive through the village. 21) Combwich Wharf 4.5.109 The Stage 1 Consultation Document summarised the potential use of Combwich Wharf for freight logistics, including the delivery of freight by water and the use of the land adjacent to ‘the Wharf’ as a consolidation/storage facility for waterborne freight.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 77 STAGE 1 CONSULTATION REPORT
4.5.110 Statutory and Non-Statutory Bodies: Several consultees commented positively on the proposed freight logistics at Combwich Wharf, mainly on the basis that road freight trips would be reduced. It was suggested that the benefits of the waterborne freight transportation would outweigh the loss of agricultural land. A respondent commented that ‘The Wharf’ would alleviate pressure off the M5 corridor as Abnormal Indivisible Loads (AIL) would be transported by water. 4.5.111 Respondents requested that the layout of the existing junctions at Combwich and Otterhampton are improved to cope with already excessive loads on the C182, Hinkley Road. It was suggested that the vehicular access onto the C182 be revisited to ensure that it is constructed to current design standards. 4.5.112 It was noted that no information has been provided on how existing river users will be affected by the proposed development and no information has been provided on the design vessel(s). The completion of a desk-based assessment on existing navigation was recommended. 4.5.113 Mitigation was requested for the timing of the development works to avoid disturbance to over wintering and nesting birds. Respondents stated that development that will damage the conservation value of the area should be kept to a minimum and mitigation or compensation measures provided. 4.5.114 Respondents raised flood risk as an important issue on the basis that the entire site falls within flood zone 3 and also sits in a tidal residual risk area. It was requested that an appropriate FRA is undertaken to identify any adverse flood risk implications to the Wharf and existing development in the locality as a result of these works. A respondent advised that they will not object to the freight logistics, provided that sufficient testing takes place that identifies no fluvial flood risk from the Rhyme network. 4.5.115 A respondent requested flood risk mitigation by proposing alternative solutions to the diversion of transportation in the event of a flood. 4.5.116 A consultee suggested that pollution prevention guidelines be followed when designing the working methods on this refurbishment. It was noted that no research has been undertaken that details how EDF Energy plans to reduce the suspended solid and other debris from entering the water from the development. 4.5.117 A number of respondents discussed the opportunity of creating legacy benefits after the construction of Hinkley Point C is complete. Suggested legacy benefits include turning the jetty into a permanent feature to assist with proposals for a passenger ferry link and utilising ‘The Wharf’ for commercial purposes/services. 4.5.118 Additional engagement and consultation with EDF Energy was requested by a number of respondents. Further information was also requested in relation to the design, construction and operational requirements of the freight logistics. 4.5.119 Local Community and General Public: A large majority of local community responses were positive about EDF Energy’s proposals to upgrade Combwich Wharf, subject to a variety of conditions such as improvements to road infrastructure and traffic management, restricted off- peak working hours, noise and light control, community benefits and landscaping. Minimising disruption to the area was stressed as important in a number of responses. 4.5.120 Some suggestions for the upgraded wharf focused on the concept of off-shore accommodation, with workers transported by boat and more construction material coming through the Wharf. 4.5.121 There were, however, concerns that the upgrade of Combwich Wharf would be too much development for the area. Issues raised included the need to retain the character of the area,
78 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT road access, tidal restrictions, archaeological implications, noise pollution, light pollution and disruption of wildlife habitats and the local residents. 4.5.122 The majority of comments from the local community in respect of freight consolidation were positive. The respondents commented that this proposal would take pressure off other areas, help reduce local carbon footprint and take traffic off the surrounding roads. Suggested conditions included restrictions on the type of freight and the amount of inbound freight. 4.5.123 A few people, however, felt the size of the freight handling facility should be reduced, that all freight handling should be on-site and that the village of Combwich could not support a development of this size. 4.5.124 There was also some confusion that a park and ride facility was proposed at Combwich and that this would be inappropriate due to traffic impact. 22) Williton 4.5.125 Options for a campus and a park and ride facility at Williton were presented at Stage 1. Comments were sought on the preferred location and scale of the developments, suitability and potential legacy benefits for the local community. 4.5.126 Statutory and Non-Statutory Bodies: Stakeholders commented on the proposals at Williton on both a general and site-specific basis. The main points raised related to the proposed campus and park and ride facility, potential legacy benefits and environmental impacts. 4.5.127 A number of respondents were against either development in Williton, suggesting that a bus service to collect workers from West Somerset would be preferable to a park and ride facility. A respondent questioned the justification of the park and ride strategy, stating that evidence determining the need for such a development is required. 4.5.128 Several consultees highlighted the potential traffic impacts as a result of the proposed park and ride facility. The suitability of the roads was the main concern, with a number of respondents commenting on the unsuitability of the A39. It was suggested that several possible improvements to the local road network could be implemented to ease traffic flow. Reflecting these comments, it was suggested that a transport assessment should be undertaken at Williton to establish whether the proposed sites are feasible in traffic terms. 4.5.129 Statutory consultees requested that further ecological surveys are conducted. 4.5.130 The visual impact from the Quantock Hills AONB was mentioned as an important area for consideration. 4.5.131 It was commented that WIL-B falls entirely within the parish of Sampford Brett; a village designated in West Somerset Council Local Development Plan as not allowing any further development due to the lack of infrastructure. WIL-B was also noted as a key prehistoric route way. 4.5.132 Consultees requested further clarification on the level of flood risk at each site and on the potential implications for existing developments. It was suggested that if WIL-A is to be pursued, it may be possible to lower the site flood risk category by delivering flood alleviation measures and thus provide a worthy flood risk reduction legacy to the town. 4.5.133 It was requested that appropriate drainage and pollution prevention measures should be looked into for both sites to reduce the effect of the developments on the surrounding areas. 4.5.134 Further consultation with the local authorities was suggested to understand the opportunities for future legacy use of the campus. It was deemed appropriate that provision of affordable housing should be explored by EDF Energy.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 79 STAGE 1 CONSULTATION REPORT
4.5.135 In order for respondents to clarify support for one or both site proposals, several points were raised as needing further consideration. This includes an assessment of community infrastructure, possible legacy benefit and provision of affordable housing. 4.5.136 Local Community and General Public: The majority of respondents, especially those living in the Williton area, opposed the proposed associated development in Williton due to increased traffic on the A39 and the distance from Williton to the Hinkley Point C site. 4.5.137 Other major themes in the responses were limited capacity of the local road network, road safety, loss of footpaths, the use of greenfield sites, flood risk, lack of anticipated use of park and ride, perceived anti-social behaviour from workers, impact on tourism and the distance from the Hinkley Point C site. 4.5.138 A number of consultees felt there should be no development in the area as it is a small village with insufficient amenities for the proposed workers and that the development would have a negative impact on the existing residents. 4.5.139 Respondents suggested other locations including Nether Stowey, Kilve, Bridgwater and Taunton as more suitable options. Other comments from the local community focused on the need to investigate alternative sites in Williton and disused industrial sites in Watchet. 4.5.140 There were some positive comments made on the proposed accommodation and, if the Williton sites were to be used, the need to ensure the design is attractive and that it provides a future legacy of affordable housing or a care home. Other legacy suggestions included leisure facilities, recreation areas for the local community and a hotel. A bypass around Williton was also suggested. However, there was some scepticism that the legacy benefits would be worth the general disruption to the area. A few respondents focused on the increase in customers, which could help support local trade and bed and breakfasts in the area. 4.5.141 A number of respondents felt that site WIL-A would cause less disruption and affect fewer residents but were still not in favour of development in Williton. Concern was also raised about the proposed access routes to the site. 4.5.142 Some felt that WIL-B, to the west of Williton, was the best option for associated development as it is near to the village centre and could be used in the future as a new village hall. 4.5.143 The majority of comments on the park and ride development were opposed to the proposals due to the limitations of the A39 and the lack of demand for a park and ride in that area. It was stated that both sites are situated on a floodplain, which could cause problems for existing residents in Williton. 4.5.144 Other comments focused on the positives of having a park and ride, as it would reduce traffic on the A39, thus reducing the likelihood of congestion and accidents. 4.5.145 A number of members of the local community felt the park and ride should be located nearer Minehead, Bridgwater or Taunton as this would be of more benefit. Suggestions were also made about using existing industrial sites and moving the development away from residential areas. More information was requested about operation of the park and ride facilities such as the number of coaches, frequency and timings. 4.5.146 Some people commented positively on the WIL-A park and ride site as it will have future legacy benefits for shoppers and could be linked to a Williton bypass to stop congestion in the town. A larger number of respondents, however, were opposed to the proposals, raising issues about the archaeological significance of the greenfield site, flood risk, dangerous roads and the reduction in value to existing properties. 4.5.147 Reasons why some respondents did not consider the WIL-B park and ride site as being suitable for a park and ride included badger habitats, flooding, use of agricultural land and the
80 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT increased traffic in a residential area. Other respondents commented that the WIL-B construction should be temporary or linked to a bypass to the A39. 23) Bridgwater 4.5.148 Options for a campus at various sites in Bridgwater were presented at Stage 1. Comments were sought on the preferred location and scale of the developments, suitability and potential legacy benefits for the local community. 4.5.149 Statutory and Non-Statutory Bodies: Generally there was support for the search areas at BRI-A, BRI-B and BRI-C, as potential locations for a campus. Although stakeholders provided comments on a wide range of issues, limited reference was made to specific site preferences. 4.5.150 Respondents stated that consideration should be made to implement sustainable transport options/links between the proposed sites and the surrounding areas of Bridgwater. Such options included: a new link road across the railway line to the A38 (Bristol Road), a new pedestrian/cycle link crossing the motorway and railway line and the visual improvement of the A39 (Bath Road) as a main arterial route into Bridgwater. BRI-D was considered to be a poorly located site with respect to current and proposed public transport links. 4.5.151 Overall there was support for the dispersal of the workforce in Bridgwater. It was noted by consultees that BRI-A is sited in a sustainable location with key infrastructure already in place. Similarly it was noted that BRI-C is located close to a bus terminus area, as well as being located within easy walking distance of the town centre. BRI-D was considered to be a poorly located site with respect to existing facilities. 4.5.152 BRI-B and BRI-C were considered to have less impact on biodiversity, with only foraging bats noted to be present at these site locations. BRI-D adjoins the Bridgwater-Taunton Canal CWA, which has been reported to support Daubenton bats, otters and water voles. BRI-A encompasses the Cellophane Pits County Wildlife Site, which has been reported to support Great Crested Newts and other legally protected species. A respondent has suggested that further ecological surveys and impact assessments should be carried out. 4.5.153 All of the sites are within flood zone 3A, meaning that they are at risk from both tidal and fluvial flooding. Respondents advised EDF Energy to seek opportunities to reduce the overall level of flooding in Bridgwater. 4.5.154 Respondents requested that full contaminated land investigations are undertaken before development works commence. 4.5.155 It was noted that the northern extent of BRI-D contains a Site of County Importance for Archaeology. A respondent advised that planning permission will not be granted for development which is likely to damage or destroy locally important archaeological remains, under policy HE12. 4.5.156 Several respondents request that the proposed accommodation campus in Bridgwater is secured as a vital legacy benefit. To enhance the legacy value, it has been suggested that accommodation is built to a high standard with the provision of sufficient leisure and social facilities. A number of suggestions for possible legacy benefit were put forward, including the provision of affordable housing, student housing and hotel use. 4.5.157 Respondents suggested that the campus proposals in North East Bridgwater (BRI-A, BRI-B and BRI-C) have the potential to support the Bridgwater Vision. Similarly, they noted that the rugby club at BRI-C has the added benefit of an existing and sizable clubhouse for possible conversion/refurbishment. Overall respondents suggest that BRI-D offers poor prospects for legacy use to benefit Bridgwater.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 81 STAGE 1 CONSULTATION REPORT
4.5.158 Further information was requested in order for some respondents to make conclusive decisions, including in respect of community infrastructure requirements, the cumulative impact of other developments in the area and details of how the accommodation strategy for Bridgwater fits in with the wider strategy. Stakeholders also require further discussions on additional site locations. 4.5.159 Local Community and General Public: The overall theme of the local community comments towards accommodation in Bridgwater was positive as the development could help to regenerate parts of Bridgwater. Most respondents suggested the northern area as being suitable for accommodation, as this could leave future legacy, along with increased transport links to and from Bridgwater. It was generally felt that Bridgwater has the amenities to service workers and it would minimise the impact on surrounding villages. Some concerns were raised that accommodation should not be situated on a single site and that the development could put pressure on existing road infrastructure. 4.5.160 A few of the local respondents commented that the Bridgwater developments should be concentrated on brownfield sites or derelict industrial areas. Suggestions were also made about a northern Bridgwater bypass and accommodation to be constructed at Dunball. 4.5.161 Traffic in the Bridgwater area was a key theme in the local community’s comments. Key concerns were the impact on existing road infrastructure (A39 and A38) and fears that there will be a large increase in traffic during peak hours due to the associated developments. 4.5.162 Several respondents commented that a Bridgwater park and ride site would be a positive legacy and that sites close to the motorway should be used in order to minimise additional traffic. A few comments were made that the facility would not be used due to lack of shoppers in Bridgwater. 4.5.163 Some respondents felt that although EDF Energy’s strategy could help create employment it could cause disruption to the Bridgwater area and the existing community, without future legacy. 24) Junction 23, M5 4.5.164 Options for a park and ride facility and freight logistics at Junction 23 of the M5 were presented at Stage 1. Consultees were invited to comment on their preferred site, as well as provide feedback on the need, suitability and possible legacy benefits for the community. 4.5.165 Statutory and Non-Statutory Bodies: Positive comments were provided from several respondents for both the park and ride facility and the freight logistics at J23-A. 4.5.166 With both proposed search areas being in close proximity to each other, similar transport comments were raised by stakeholders. The rationale for providing park and ride facilities and freight logistics at Junction 23 is supported on the basis that vehicle movement throughout the area would be minimised. A concern was raised that the development at Junction 23 could have a potentially negative impact on the strategic road network and further traffic modelling work is required to determine this. 4.5.167 Respondents suggested that both sites are likely to generate a level of trips that could detrimentally impact upon the safe and efficient operation of this junction and the flow of traffic to the M5. A respondent considered the access strategy for J23-A more appropriate than that of J23-B. 4.5.168 It was suggested that both sites could potentially support Great Crested Newts and attract birds from the Severn Estuary SPA and as such recommended that an ecological survey is required to check for any protected species.
82 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 4.5.169 Respondents noted that both search areas fall wholly within flood zone 3A. Respondents also stated that J23-B has been designated as a high flood risk hazard area due to its proximity to the Parrett flood defence embankments and further modelling work would be required to establish whether J23-A should be similarly categorised. Respondents requested further information regarding the possible impacts to the strategic road network in the event of a flood. 4.5.170 Several consultees made suggestions on the potential legacy opportunities, however further information was requested on the ongoing viability of the park and ride facilities post- construction. In contrast, a respondent remarked that park and ride facilities should not be seen as a legacy to the town. 4.5.171 Respondents requested further assessments and consultation relating to historic uses of the site, habitat regulations and how the proposed strategy coincides with council objectives and flood risk management. 4.5.172 Local Community and General Public: The M5 Junction 23 park and ride proposals received mainly positive comments from the local community. The comments described both sites J23-A and J23-B as being appropriate for development. It was suggested that the park and ride would help eliminate local gridlock on the existing road network and benefit Bridgwater. 4.5.173 Several responses suggested that a northern Bridgwater bypass from Dunball over the River Parrett would help relieve traffic congestion. 4.5.174 A few people commented that the park and ride would not be needed in the area, it would have no legacy of community benefit and could put more pressure on the local road infrastructure. It was suggested that more information was needed and detailed studies should be conducted to assess whether it will be used. 4.5.175 The freight handling facility proposals at Bridgwater received only a few comments with suggestions made about linking it to freight travelling by river. Concern was also raised about associated traffic on inadequate local road infrastructure. 25) Junction 24, M5 4.5.176 Options for a park and ride facility and freight logistics at Junction 24 of the M5 were presented at Stage 1. Consultees were invited to comment on their preferred site, as well as provide feedback on the need, suitability and possible legacy benefits for the community. 4.5.177 Statutory and Non-Statutory Bodies: Positive comments were provided from several respondents for both the park and ride facility and the freight logistics at J24-A. 4.5.178 The rationale for providing park and ride facilities and freight logistics at Junction 24 was supported on the basis that vehicle movements through the area would be minimised. A respondent commented that the access strategies for J24-B and J24-C are achievable, however development at J24-A may result in further improvements being required. 4.5.179 Search area J24-A was considered to have less of an impact on the current transport system and was therefore the preferred location for the park and ride facility and/or freight logistics for many consultees. Several alternative locations to the ones proposed were suggested. 4.5.180 Stakeholders recommend that further ecological surveys are undertaken to identify any protected species and stated that a number of species have previously been recorded in the area. 4.5.181 All three search areas fall within flood zone 1, meaning that they are at low risk of flooding. As such, a respondent stated that it had no flood risk objection in principal subject to an appropriate FRA and proper drainage systems being in place.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 83 STAGE 1 CONSULTATION REPORT
4.5.182 Respondents noted that all three areas have potential for land contamination due to previous historic usage. 4.5.183 It was considered by a respondent that J24-A presents the greatest opportunity for legacy, with J24-B considered the weakest. It was suggested that the proposals could contribute towards the local authorities’ non-car based transport initiatives and further research was needed into the ongoing viability of park and ride facilities post-construction phase. 4.5.184 Further information was requested by consultees relating to traffic modelling and how the proposed strategy coincides with the council’s objectives and flood risk management plans. 4.5.185 Local Community: The park and ride facilities proposed at M5 Junction 24 were strongly supported by the local community. Most felt all the proposed sites had potential for associated development (for park and ride and accommodation) on them and would help reduce traffic through Bridgwater and on the A39. Only one comment suggested that the park and ride facilities were on the wrong side of Bridgwater. 4.5.186 There were only a handful of comments on the freight handing facilities, with respondents expressing concern over increased traffic on existing road infrastructure and the need to integrate the plans with other the proposals affecting Junction 24.
4.6 Summary of Comments on Broader Community Issues
26) Broader Community Issues 4.6.1 Respondents commented on issues covering the wider community impacts and/or benefits from the development. These fell into three main categories: Jobs and Trainin,; Procurement and Community Benefits, and are discussed in the sections below. 4.6.2 Stakeholders also made broader comments on the socio-economic issues. In terms of socio- economic assessment, it was suggested that there is currently a lack of analysis describing the existing socio-economic conditions and how socio-economic impacts correlate with planning policy. Additionally, they suggest that the socio-economic methodology presented may not be the best means to assess impacts of the project of this scale. 4.6.3 A stakeholder commented that no evaluation was presented at Stage 1 on the potential impact on tourism and it would be necessary to provide a strategy to manage and mitigate impacts before confirming the accommodation strategy. 4.6.4 Some respondents noted the wider regeneration and economic impacts/benefits of the project and suggested that little information was provided at Stage 1 on how EDF Energy’s proposals integrate with wider regeneration and economic objectives. A respondent advised it would only be able to assess the ability of the development to deliver regional economic priorities when additional information was available. 4.6.5 An additional comment relating to socio-economic issues was received regarding the potential increase in demand on local policing services. A consultee raised this issue due to the rise in local population by the incoming workforce during the construction and operation periods. 27) Jobs and Training 4.6.6 Stage 1 discussed the development of a training and recruitment programme with the provision to enhance skills through training and educational activities. A training and recruitment strategy was presented with objectives in place to encourage local community opportunities during both the construction and operation phases of the power station.
84 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 4.6.7 Statutory and Non-Statutory Bodies: Respondents were generally positive and encouraged the opportunities presented in jobs, training and skills development. Respondents welcomed the chance for increased wages, however, it was noted that this could also increase the local cost of living and there appeared to be no employment benefit for the area of Burnham and Highbridge. In developing employment and contractor contracts, a stakeholder expressed the desire to ensure that these contracts address cross-cutting issues such as equality, training and environmental considerations. 4.6.8 Stakeholders wished to ensure involvement of local educational facilities for training and appropriate skills development, linked to the community benefits package, and in securing jobs for the local community – particularly for young people. Further information was requested on the community development initiatives for job creation and enterprise. 4.6.9 Respondents wished to obtain a better understanding of the labour force and skills requirements, including the likely sourcing of the labour force and verification of the identified local labour participation figures. A mechanism for ensuring the 50% local labour provision and maximising opportunity was requested. 4.6.10 Further development of the training strategy was recommended by respondents in order to identify and create opportunities for ‘hard to hear’ groups, enhance opportunities for the female workforce, consider the impact of local workforce displacement to the project on local jobs and potential outward migration of the workforce to other nuclear projects, and how the strategy can help achieve local area targets and create positive outcomes. 4.6.11 Respondents encouraged further working with local education provider and businesses to develop the skills, training and jobs package. 4.6.12 Local Community and General Public: The vast majority of respondents to this issue were supportive of the employment opportunities presented by new nuclear build at Hinkley Point. 4.6.13 The main emphasis of the comments received was on education and training with a large number of comments on the need for apprenticeships. A few respondents suggested choosing students from the local area to put through university and bursaries for students studying science in the local area to help ensure local people had every opportunity to benefit from the new jobs. 4.6.14 Continued funding for education and training, to include apprenticeships, was considered essential to achieving this goal. 4.6.15 There was, however, concern expressed by respondents that local businesses would have trouble recruiting if they had to compete with an employer such as EDF Energy, who would be able to offer better salaries and benefits. 28) Procurement 4.6.16 A procurement strategy outlining a number of objectives for the development of Hinkley Point C was outlined at Stage 1. Objectives included the assurance for a reliable supply chain, the facilitation of local business involvement and to make a positive contribution to the local area. Opportunities for local businesses in the supply chain for construction and operation of the new power station were encouraged. 4.6.17 Statutory and Non-Statutory Bodies: Stakeholders responded positively to the economic development of the local area through the local supply chain. They encouraged further involvement and understanding of the mechanisms to ensure local supply chain development initiatives for the procurement strategy, and in securing the long-term legacy benefit to the local economy.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 85 STAGE 1 CONSULTATION REPORT
4.6.18 Local economic growth as a result of the local supply chain was encouraged and respondents wished to understand how the business community might benefit and how it can become part of the supply chain. Additionally, respondents advised that local businesses would need to be provided with the relevant skills in order to ensure their involvement. ‘Into Somerset’ was recommended as a mechanism to support EDF Energy in coordinating procurement, training and investment opportunity. 4.6.19 A stakeholder sought assurance that the strategy would seek to find suppliers that are environmentally accredited, whilst others recommended that the training and procurement strategy recognises Local Area Agreement targets. 4.6.20 More information was requested on the baseline informing the procurement strategy, including the socio-economic background work to the project of delivering 50% local labour force and local business profiling. It was suggested by the local authorities that socio-economic assessment and the likely supply chain relationships could draw on international data from similar projects in order to gain a better understanding on impacts. Feedback from previous procurement events would also be useful in this instance. 4.6.21 Further information was also sought on the additional benefits associated with local supply chain initiatives, how it would reduce the physical impacts associated with the development, and how initiatives relating to the local supply chain would be secured, including for operational phase procurement opportunities. 4.6.22 Local Community and General Public: The majority of respondents on this issue were keen that local businesses should have the opportunity to work for EDF Energy and that they are given early notice of contracts and advice on how to respond. 4.6.23 It was suggested that there should be a policy about engaging local businesses in construction and operation of the new power station and a commitment to positive discrimination in favour of local businesses and assistance in establishing suitable business models to help in this process of engagement. 29) Benefits to the Community 4.6.24 Introduction: Stage 1 consultation outlined the approach to community benefits and identified initial options on the measures that may be needed to support the development proposals. As well as ongoing discussions with the local authorities and other stakeholders, comments were invited at Stage 1 on the approach and development of a package of measures to be included from both statutory consultees and the local community. 4.6.25 Statutory and Non-Statutory Bodies: Stakeholders were interested in a wide range of measures including accommodation and transportation infrastructure, and social and environmental gain to produce a comprehensive package of measures. Respondents commented on the process of developing the benefits package, its content and longevity of local community support. 4.6.26 A number of responses discussed the opportunity of creating legacy benefit from the development to address the needs of the local community, either directly through the associated development proposals itself or the benefits package. Legacy benefits from the proposed associated development sites that were suggested by respondents included the use of workers accommodation to provide permanent housing which meets local housing needs (e.g. affordable housing, residential care homes, and student accommodation) and the use of ancillary parking and leisure facilities. Potential recreational legacy use of the jetty was also commented on. 4.6.27 Some stakeholders desired positive legacy outcomes through participation of the authorities and local community, via community planning and the political process, to develop an appropriate package which identifies local aspirations. A number of organisations would like to
86 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT work with EDF Energy or are recommended to be consulted with to develop the package of measures and identify provisions. 4.6.28 Stakeholders commented on improving the local transport infrastructure by encouraging road enhancements and a better understanding of the use of the park and ride sites by the local community (including legacy or restoration options) and integration with local public transport services. 4.6.29 Environmental measures suggested from organisations include the opportunity to enhance flood protection from the development and recreational benefit to the local community by creating a valuable resource from the restoration scheme, e.g. creation of community woodland, enhancements to the environment (including the use of low carbon technologies), provision of a landscape legacy and the creation of wildlife gains on the associated development sites and to the southern land north of Shurton. Respondents suggested that it is not sufficient to just incorporate footpaths and nature trails and that there is a need to provide a wet weather attraction linked to the low carbon agenda to mitigate the negative impacts of the development. 4.6.30 Stakeholders suggested a number of local initiatives which could be improved or invested in as part of the benefits package, including support for community projects; tourism initiatives; health, education and social services; and civil protection. For example, open space provision, village hall improvements, investment in local education and recreational facilities including schools, improvements to PRoW, dedicated police and community liaison officers, a Lengthsman scheme and cycle route improvements. 4.6.31 Some stakeholders suggested that direct benefits could be gained from the construction in terms of economic, educational and cultural influences. Another was not convinced the advantages from community benefits would outweigh the disadvantages. 4.6.32 Many respondents suggested benefits that provided the opportunity and encouragement of training, jobs and procurement directly related to the development and through additional provision. These are discussed in the sections relating to jobs and training, and procurement. Additionally, some respondents wished to know how the package would complement economic regeneration for the area, particularly for Bridgwater. 4.6.33 The consultees requested more detailed information on the community benefits package, clarifying what is being provided as planning mitigation and that which adds value to the community. Comments were made as to how the package would be administered and the intended distribution of provision. A full assessment of the social and community infrastructure requirements of the development was also requested. 4.6.34 In developing the package, a respondent felt that the package should be developed to offset the consequences of hosting the nuclear power plant and interim waste storage, which is proportionate to the actual and perceived impacts of the development. 4.6.35 Comment was also made on the intended response to planning blight. 4.6.36 Local Community and General Public: Of those who responded to this issue, the general assumption was that EDF Energy should provide community benefits as part of its proposals; however, there was a mixed view as to what form and where these benefits should be focussed. 4.6.37 Those living in local villages suggested a range of community benefits, from specific projects to general community facilities such as a village hall, swimming pool, playing fields, social clubs, youth facilities and children’s play areas. A permanent Community Liaison Officer, based locally, was also suggested as a point of contact for local people. 4.6.38 Other suggestions were based on legacy benefits and included affordable housing and a care home. It was also suggested that EDF Energy provide cheaper electricity tariffs for those living in the areas most affected by the main site proposals and associated works.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 87 STAGE 1 CONSULTATION REPORT
4.6.39 There was also a desire for EDF Energy to contribute to the local infrastructure including doctors’ surgeries, health centres, schools, roads, flood prevention and policing. 4.6.40 There were, however, a number of responses from people who were sceptical that any community benefits could outweigh the impact EDF Energy’s proposals would have on the local community.
4.7 Summary of Issues Not Directly Related to the Proposals
4.7.1 A number of comments were received that did not directly relate to the proposals for Hinkley Point C. In order to provide a comprehensive overview of the feedback to Stage 1 consultation, it is important to include a summary of the issues discussed. 30) Nuclear Energy and the Principle of Development 4.7.2 Statutory and Non-Statutory Bodies: Stakeholders commented on the generation of energy from nuclear power and the principle of developing new nuclear at the Hinkley Point site. Both were generally supported, conditional on demonstrating safe practice and sufficient environmental standards. A few comments received did not support this approach. 4.7.3 Allowing for appropriate associated development and subject to addressing the pressures of development, the majority also supported the economic development benefit to the area. 4.7.4 Local Community and General Public: Those from the local community who raised this issue had a mixed response to nuclear energy and the principle of development. There was a recurrent theme that although not opposed in principle to nuclear power or the proposed station, the local community were concerned about impact the associated developments would have on the area. 4.7.5 Those against the principle of development cited concerns about health and safety associated with nuclear power, the size of the development and questioned the role of nuclear as a viable energy source. 31) Submission Documentation 4.7.6 Statutory and Non-Statutory Bodies: A number of documents were recommended for submission as part of the DCO application to the IPC. Some of the recommendations are incorporated into the categories discussed previously. In addition, respondents advised EDF Energy to undertake an EIA and Sustainability Appraisal, as well as provide a Transport Assessment and Travel Plan, Environmental Management Plan, Economic Assessment, Training and Procurement Strategy and draft Development Consents Obligations. 4.7.7 Local Community and General Public: Only a few comments were received regarding submission documentation. It was suggested that a Construction Environment Management Plan and a Training and Procurement Strategy be provided as part of the DCO application. 32) Stage 1 Consultation 4.7.8 Statutory and Non-Statutory Bodies: A few comments were received on the Stage 1 consultation, its overall content and consultation process. Observations suggested a limited level of detailed information and evidence in support of the proposals provided at Stage 1, and the underestimated significance of individual project elements. 4.7.9 It was commented that there was limited evidence of consultation and true engagement during Stage 1 consultation, particularly in relation to tourism. Comment was also received on the public exhibitions. Other consultees welcomed the way the consultation process had been handled and the period of extension provided for comments due to the inclement weather.
88 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 4.7.10 Local Community and General Public: There were mixed views from the local community on the Stage 1 consultation. A number of comments suggested the consultation did not fully engage with all the local communities potentially affected by the proposals. Some respondents felt the areas being consulted were not broad enough and further consultation should have been conducted in areas further a field (Taunton and Bristol). 4.7.11 A few comments suggested the consultation period was held too late and the consultation was invalid due to the proposed options being decided before the consultation period, that only restricted information was made available in consultation documentation and at exhibitions or that the consultation was premature as the draft NNPS had not been finalised by DECC. 4.7.12 However, some members of the local community commented on the informative nature of the consultation process and complimented the EDF Energy team members for listening and responding to local community concerns. Positive comments were made about the clarity of the proposals and there was a feeling from some respondents that apathy in the local community had prevented more people fully engaging in the consultation process. 4.7.13 A few comments were received on the Stage 1 Questionnaire. The issues mentioned were the lack of a ‘neither’ option on Questions 5, 7 and 8 and one person suggested the language used in the consultation document pre-empted decisions which were being consulted on in the questionnaire. 33) Further Consultation 4.7.14 Statutory and Non-Statutory Bodies: Further consultation and engagement was encouraged and welcomed by a number of consultees who wished to become involved in various elements of the project and through the continued working of the established liaison groups. Respondents also noted that the formal Stage 2 consultation should not propose or incorporate ‘new’ options. 4.7.15 Local Community: Some people felt that further consultation with the local area was desirable and that more focused consultation should be conducted with specific organisations and areas affected by the development. Further consultation was also recommended on key issues, which have been identified, and for more of the local community to become involved.
4.8 Summary of Late Responses
4.8.1 A handful of comments were received from the local community and some statutory consultees after the close of the consultation period. These were taken into account by EDF Energy, although they did not raise any significant new issues from those already raised during the formal consultation period.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 89 STAGE 1 CONSULTATION REPORT
5 EDF ENERGY RESPONSE TO CONSULTATION
5.1 Introduction
5.1.1 This section sets out EDF Energy’s response to the key issues raised during the Stage 1 consultation process. It explains where and how EDF Energy has altered its plans in its Stage 2 ‘Preferred Proposals’ in response to the consultation. It also explains where changes have not been made in response to comments and why. 5.1.2 Comments received from statutory consultees, other stakeholders and the local community have been summarised and grouped under a number of different headings to make it easier for the reader. This information is presented in tabular form in this section. 5.1.3 The headings in the table relate to: the different forms of development proposed (e.g. preliminary works, the main site and associated development sites); subject specific areas (e.g. accommodation and transportation strategies, visual impact, fuel and waste); and geographic specific areas (e.g. Cannington, Williton and other areas where development was proposed in the Stage 1 ‘Initial Proposals and Options’). 5.1.4 Members of the public who commented have not been individually identified, in order to comply with data protection legislation. However, a tracking system has been introduced to enable people to follow EDF Energy’s response to their individual comments. This is based on individual respondents receiving a reference number to use to track responses. Appendix A.9 provides a list of these reference numbers, which cross-refers to the sections in the following tables in which EDF Energy’s responses to their particular concerns are shown.
90 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT EDF Energy Response to Stage 1 Consultation
1) Preliminary Works Comments EDF Energy Response
Level of detail provided at Stage 1 was too little EDF Energy acknowledges that more information is required in support of preliminary works applications. The Stage 1 consultation provided outline information to initiate discussions. EDF Energy has been and Considering the proposed timetable of submissions in continues to engage with directly affected parties and has discussed proposals with local residents on two March 2010, information had not allowed the public to occasions in April and June 2010. EDF Energy will continue to undertake further consultation with the influence the development. affected parties as proposals are finalised. The applications are intended for submission during the summer 2010.
Overlooked the significance of individual project elements EDF Energy’s timetable to provide early deployment of new nuclear power generation is in line with and does not provide adequate justification of need for Government policy. Preliminary works consent would enable the power station operation to be advanced by preliminary works at least a year, without prejudicing the outcome of the DCO application. EDF Energy has recognised the significance of the individual project elements and their associated environmental effects. These have been thoroughly investigated as part of comprehensive environmental impact studies. The Environmental Statements will outline consideration given to alternatives in accordance with legal requirements and best practice. The proposals will aim to satisfy regulatory requirements individually and collectively.
Construction and design of the jetty and sea wall as part of More details on the design and assessment of potential impacts from preliminary works proposals will be preliminary works set out in the relevant consent applications. EDF Energy no longer intends to develop the sea wall as part of the preliminary works principally due to the difficulty in reversing the physical construction should consent from the IPC not be granted for the main Hinkley Point C Project. Instead a limited length temporary retaining wall, set in from the shoreline has been proposed as part of the preliminary works.
Further details needed on preliminary works for EDF Energy has undertaken consultation with relevant statutory bodies and has recently received scoping consultation with statutory bodies opinions from West Somerset Council and the MMO. Consultations are planned with relevant bodies over the coming weeks leading towards submission of the application later in summer 2010. For example, archaeological investigations should be fully understood before levelling the site and more detail on the construction strategy to determine whether this would impact the Strategic Road Network.
Environmental information Detailed ecological mitigation has been proposed on-site and in surrounding land and mitigation strategies for protected species have been developed in consultation with the local authorities and Natural England.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 91 STAGE 1 CONSULTATION REPORT
1) Preliminary Works Comments EDF Energy Response Need to demonstrate that site clearance would not Further details will be provided in the planning application. The site restoration scheme has been designed adversely affect statutorily protected species and that a to maximise the ecological interest of the site commensurate with other interests. mitigation strategy will be prepared. Comment on the The proposals for preliminary works acknowledge the potential impact as a result of site preparation on potential impact to terrestrial archaeological deposits in areas of archaeological interest. All material found of archaeological importance will be recorded and dealt advance of the IPC application. More information required with in the appropriate manner. EDF Energy believes that in policy terms, this should not constitute on the implications of the works subject to preliminary sufficient grounds for refusing preliminary works consents. However, this will be a matter for West applications in the event that the IPC application is not Somerset Council (WSC) (as planning authority) to consider when assessing the application. approved. The Government has acknowledged that promoters of new nuclear development may wish to engage in Proposed works could cause damage to the environment early site preparation, at the promoter’s own risk, to ensure early deployment of new nuclear power which would be difficult to reverse if development consent stations. In doing so, proposals should allow for restoration of the land should development consent not is not approved. be granted by the IPC. The determining authorities in respect of both applications will weigh up all planning considerations and decide on what factors to take into account in determining the proposals.
Clarification of how EIA and any Appropriate Assessment The applications for preliminary works development will comply with the requirements of EIA and the would be conducted and its compliance with regulations Habitats Regulations Assessment, as appropriate. In the assessment of potential impacts of other developments either in-combination or cumulatively with the preliminary works, assessment will be made in two ways: temporally and spatially. Judgement will be made on the potential impacts of the development on this basis and appropriate mitigation measures will be proposed as a result. The two separate preliminary works applications will be assessed, each taking into account the other, as well as cumulative and synergistic effects associated with other relevant schemes, including the implementation of the Hinkley Point C Project.
Clarification of which consenting route the works would go Two separate applications for preliminary works will be made to coincide with this Stage 2 consultation. through The first, for a Harbour Empowerment Order (HEO) for the temporary jetty will be made to the MMO. The second, for planning consent under the Town and Country Planning Act 1990 (as amended) for site preparation works, will be made to WSC.
92 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 1) Preliminary Works Comments EDF Energy Response
If development consent for the main Hinkley Point C Project At EDF Energy’s own risk and cost, if development consent is not granted for the main Hinkley Point C is not approved, the land should be returned to its previous Project, the land on which preliminary works are carried out would be restored while seeking to enhance use the biodiversity of the area. EDF Energy no longer intends to develop the sea wall as part of the preliminary works principally due to the difficulty in reversing the physical construction should consent not be granted for the main Hinkley Point C Project. Instead a limited length temporary retaining wall, set in from the shoreline has been proposed as part of the preliminary works and has been chosen for its reversibility should consent not be granted and the land restored.
Preliminary works should be carried out with as little Proposals for site preparation works have been developed to minimise potential disturbance to local disruption to local residents as possible residents close to the southern construction land (in terms of noise, light and visual impacts). The southern limit of construction activity and main construction fence will now be some 200m to the north of Bum Brook. During the main phase of construction works, apart from the construction of the emergency access road and bridge across Bum Brook, bunding for the accommodation campus, including an associated drainage pond and final restoration activity, no other construction work is anticipated south of the main construction fence. Early planting is proposed along the southern perimeter of the site in order to establish growth in advance of the works being undertaken. A landscape buffer (bund) is proposed to the north of Doggets to provide some visual, light and noise mitigation from sources to the north of it. This would be established during the main works as part of the construction of the accommodation campus. All preliminary works consents would be undertaken in accordance with limits set as conditions on the development and within policy standards. EDF Energy is committed to protecting the amenity of local residents and is in the process of developing detailed construction mitigation and management plans to aid this. EDF Energy will continue to listen to the views and concerns of local residents and adapt the proposals to take account of these views where practicable.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 93 STAGE 1 CONSULTATION REPORT
2) Construction Activities and Restoration Comments EDF Energy Response
Sustainable construction EDF Energy is promoting the sustainable development of Hinkley Point C including Associated Development by adopting a series of sustainability objectives aligned with its corporate strategy. The Sustainability Respondents welcomed the approach to sustainability and Evaluation, available as part of this Stage 2 consultation, identifies commitments to sustainable design responses promoted sustainable construction of the power and construction for Stage 2, including how principles have been considered and implemented. More station and the development of an overarching construction detailed information relating to specific standards is available within the Masterplans. Sustainable strategy to incorporate the submission and implementation construction will be delivered through various separate strategies, including a construction logistics of a Construction Environmental Management Plan, strategy and Travel Plan, as well as a Construction Environmental Management Plan and Site Waste Construction Logistics Strategy and Site Waste Management Plan. Management Plan as part of the DCO application.
Consideration of environmental impact from construction In line with EDF Energy’s sustainability policy, contractors would be encouraged to utilise locally-sourced material sourcing goods, materials and services, subject to technical acceptability. The construction strategy would address materials sourcing and associated environmental impacts. Targets should be set for the proportion of locally sourced/recycled materials and consideration should be Delivery of cement and aggregates for concrete production and Abnormal Indivisible Loads (AILs) would given to the transportation distance of construction primarily be achieved via sea transport. Consideration would also be given to sea transport of other bulk materials. materials where feasible and appropriate.
Potential flood risk to local residents as a result of large A Flood Risk Study, taking account of proposed earth movements, has been carried out by EDF Energy and scale earth movement is available as part of the Stage 2 consultation. The study has not identified any significant increase to flood risk to the area as a result of the proposals.
Extent of land required for construction Site and project constraints determine the use of land during construction. There is a need for a construction area for construction compounds, areas for heavy prefabrication and workshops, aggregates Respondents commented on the amount of land required and cement stockpiles, and for surplus materials stockpiles (due to the nature of the materials, technical for development. and time constraints for re-use or landscaping). Other land is needed for allocated uses and for protecting natural features including the Green Lane, for buffer zones and temporary haulage roads. During the construction period, the construction areas will be progressively developed and reused from existing construction uses in order to maximise its use and minimise impact on land take and off-site vehicle movements.
94 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 2) Construction Activities and Restoration Comments EDF Energy Response
As a result of ongoing consultation, EDF Energy is now proposing not to use the south-west pocket of construction land closest to Shurton. Instead, EDF Energy will endeavour to make maximum use of available land within the areas further north and, as appropriate, at Combwich Wharf for the storage of materials.
Construction strategy The construction strategy integrates consideration of transport of materials and people to the site as well as the training and recruitment of local skills. Phasing of work, particularly land use in the southern part of the Encourage inclusion of details within the construction construction area has been carefully considered. strategy on the area required for the construction related activities; how the site would link together as part of a The impact on local roads would be minimised by the construction of a jetty to facilitate sea delivery of coherent strategy; tie in with local supply chain initiatives, cement and aggregates for concrete production. Abnormal Indivisible Loads (AILs) would be shipped to training, employment and community benefit; construction Combwich where the existing facility would be strengthened to accommodate the larger items associated time limits; and construction and site restoration phasing. with the EPR design. In order to maximise local employment opportunities, measures would be put in place to encourage and train local workers to participate in the construction (and subsequent operation) of the Hinkley Point C Project as well as encouraging contractors to utilise local materials, goods and services, subject to technical acceptability. Accommodation campuses park and ride facilities and freight logistics facilities have been located to optimise local benefit and minimise adverse impacts, and worker transport policies would be adopted to minimise the use of private cars, particularly in proximity to the site.
Impact to landscape features EDF Energy will continue to work with statutory bodies, primarily the local Councils, Natural England and English Heritage, and the Somerset Wildlife Trust in developing and implementing its plans to minimise and Impact on landscape should be minimised and mitigate adverse impacts on the landscape and ecology. While a proportion of the Hinkley County Wildlife construction materials reused. Habitats should be Site would be lost, EDF Energy is retaining the most biodiverse habitats including species-rich grassland, protected by keeping the removal of hedgerows, trees and scrub and Pixies Mound. Breeding habitat for nightingale, Cetti’s warbler, sedge warbler, reed warbler, barns to a minimum. whitethroat and reed bunting would be retained. Hedgerows are of value both for the species they contain and for the corridors they provide for species living in and dispersing across the agricultural habitats. A number of hedgerows within the Development Site would be removed. The hedgerows that would be removed have a very limited associated ground flora due to grazing up to the hedge bottoms in pasture areas and the spraying off of weedy margins in the arable fields. Appropriate mitigation is proposed as part of the restoration of the site and in order to
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 95 STAGE 1 CONSULTATION REPORT
2) Construction Activities and Restoration Comments EDF Energy Response provide a net gain to biodiversity and minimise the visual impact. The Green Lane hedgerow would be retained throughout construction and enhanced with additional hedgerow planting afterwards. Hedgerows would also be retained around the perimeter of the Hinkley Point C Development Site. The barns within the Hinkley Point C Development Site would be removed. A bat roost would be provided to the specifications agreed with Natural England. Around 80ha of new habitat to the south of the Hinkley Point C site is proposed to be created post- construction. This habitat would be managed to meet objectives for biodiversity, landscape and amenity. Furthermore, there would be a net gain for biodiversity on the site after the construction period, as land previously intensively farmed for agriculture would be managed for biodiversity. These proposals, including planting, would have a screening and ecological benefit. Construction spoil would remain on-site and would be landscaped to work with the existing landscape character. Calcareous grassland would be recreated using seeds from existing grassland.
The management of construction waste In line with EDF Energy’s sustainability policy, emphasis will be placed on the avoidance of waste, re-use and recycling in preference to disposal. A Construction Environmental Management Plan will be a key Full consideration of the generation, transportation, storage element of the development proposals. and location of disposal of construction waste is required.
Spoil arisings and disposal The site preparation activities are designed to facilitate construction, working within environmental constraints and avoiding the need to export material from the site. Excavated materials would be carefully Clarification was sought in terms of its composition and segregated by type and properties to maximise the ability to re-use for backfill and subsequent landscaping management, including the extent and location of spoil and minimise the need to import fill materials or export spoil off-site. During the construction phase, storage, reuse and disposal, and the potential increase to excavated material would be re-distributed across the site to establish areas suitable for contractors’ flood risk. temporary storage and prefabrication work and these areas will subsequently be incorporated into the final landscaping plan as contractors vacate their working areas. A Flood Risk Study has been carried out and is available as part of the Stage 2 documentation. The Flood Risk Study does not identify an increased flood risk as a result of the proposals.
96 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 2) Construction Activities and Restoration Comments EDF Energy Response
Restoration/landscaping scheme and restoration The overriding approach has been the restoration of landform and landscape character (including the management. historic landscape), whilst increasing biodiversity. Ecological mitigation is required, both for the Hinkley Point C development footprint, and to compensate for the time taken for new habitats to grow. Positive responses were made regarding the restoration design concepts presented at Stage 1 and There would be a significant change in land use including from agricultural use to management for the recommendations were made that further development of benefit of biodiversity, landscape and amenity. the restoration scheme reflect existing features including The accommodation of construction spoil presents opportunities for visual mitigation using landform to nature trails and landscape character, including historic provide a transition between the rural landscape and the proposed Hinkley Point C nuclear power station, landscape. Some respondents advocated restoring the helping the development to sit well within the site. construction sites to green fields once development is The landscape would be accessible to the public via Public Rights of Way (PRoW) after restoration. completed. An intimate mosaic of habitats would be created comprising woodland, scrub, hedgerows, calcareous It was recommended that a landscape management plan grassland and neutral hay meadows. should be prepared to detail how the landscape would be The existing Hinkley Point Land Management Partnership/Steering Group would be key to successful managed in the future. delivery of the project. A landscape management plan would be developed in line with the existing arrangements in order to manage the site and protect the biodiversity. The existing arrangements involve active participation of key stakeholders such as Natural England and the Somerset Wildlife Trust.
Further consultation regarding site layout and landscaping Dialogue has been continuous with all statutory consultees. A number of meetings were held to discuss proposals was recommended proposals, most notably in December 2009 and March 2010 with stakeholders including Natural England, Somerset County Council, West Somerset Council, Sedgemoor District Council, Somerset Wildlife Trust, Additionally, clarification of consultation undertaken with English Heritage, RSPB and the Environment Agency. statutory bodies was sought. Statutory consultees have been very responsive in terms of requirements for the site and these are reflected at Stage 2 in EDF Energy’s ‘Preferred Proposals’.
Clarify whether educational facilities will be provided for A Public Information Centre is included as part of the development proposals and EDF Energy will continue children to promote its educational activities with local schools. Nature trails are also proposed but final details not prepared.
Not acceptable for spoil from the site to be transported There are no plans to transport spoil off-site via the jetty to off-shore dumping sites. from the jetty to off-shore dumping sites
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 97 STAGE 1 CONSULTATION REPORT
3) Southern Landscape Buffer (bund) Comments EDF Energy Response
Confusion over purpose of the bund Taking account of responses to Stage 1 consultation, the landscape bund is proposed to be provided to the north of Doggets, south of the on-site accommodation campus. Planting would be provided along the What is the bund intended to mitigate – the power station remaining southern boundary north of Shurton. The bund to the north of Doggets would provide visual site itself or the associated development and construction screening for the construction area and the campus and an element of noise and light mitigation. The activity? Confusion over whether it would be removed after design of the on-site accommodation campus would assist this further in respect of the construction works. construction is completed. As stated earlier, some planting would be carried out as part of the site preparation works, but the bund would form part of the campus construction and will take place as part of the main phase of construction. The landscape bund to the north of Doggets will be retained and integrated into the landscape restoration scheme.
Extent to which landscape buffer provides noise mitigation The proposed landscape buffer to the north of Doggets would have some noise mitigation benefits. The buffer provides a multifunctional use which mitigates the potential impacts from noise, light and visual amenity.
Opportunity to create a multifunctional buffer The proposed buffer to the north of Doggets, in addition to visual, noise and light mitigation described above, would also have an ecological and amenity value through providing additional habitat for local A number of respondents discussed the opportunity of wildlife. creating a multifunctional buffer, with the bund also creating short-medium term mitigation for habitat losses on-site.
Potential impact of the bund on bats and local wildlife The bund and screen planting would provide additional habitat for local wildlife and act as a wildlife corridor resulting to mitigate the potential impact from construction.
98 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 3) Southern Landscape Buffer (bund) Comments EDF Energy Response
Potential to permanently retain the landscape buffer and Early establishment of planting is proposed as part of site preparation. establishing planting as early as possible. Both planting and the proposed formation of the bund would remain as permanent features of the Respondents suggested that the bund should be planted development. The bund’s southern flank would remain the same throughout the duration of construction immediately. This would create a semi-natural buffer which and afterwards. The northern flank would be advanced northwards to provide additional spoil storage as would be well established by the end of construction. The the construction progresses and retained as a permanent landscape feature. landscape buffer should be environmentally friendly and visually appealing in ways that lay the groundwork for future use by the community. Respondents also suggested that spoil from the site could be used to create the bund rather than transporting spoil off-site. A number of responses discussed the possible permanent retention of the landscape buffer, with the habitat creation retained and managed in situ.
Location of the buffer In response to comments to Stage 1 consultation, EDF Energy has adapted its proposals by proposing planting along the southern perimeter to the north of Shurton instead of a buffer, whilst retaining the buffer Interaction of the bund with public access and residential to the north of Doggets where it would be of most value in terms of potential impact mitigation. properties to the south of the site. It was suggested that the bund be located further north, nearer to the ridge line.
Greater detail of the proposals Stage 2 provides further detail on the proposals and environmental assessment within the Environmental Appraisal Volume 2 Chapters 2, 3, 4, 10 and 21 relating to the proposed development, its construction and Some respondents felt that there was not enough detail potential effects on landscape and visual amenity and noise and vibration. The proposed planting would about the size/scale of the bund and how it would assist with visual screening. All potential light, noise and visual impacts would be appropriately minimise visual impact as well as light, noise and pollution. conditioned and kept within agreed reasonable limits. Concern was expressed in relation to the loss of views and daylight.
Access for walkers The proposals outlined at Stage 2 seek to maintain access for walkers by providing Public Rights of Way (PRoW) around the outside of the construction site. Additionally, proposed improvements to drainage would enhance walking conditions along Benhole Lane.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 99 STAGE 1 CONSULTATION REPORT
3) Southern Landscape Buffer (bund) Comments EDF Energy Response
Further consultation requested on the treatment of the Informal consultation has been undertaken between Stage 1 and Stage 2 consultation with immediate southern area neighbours, local stakeholders and West Somerset Council on the proposals for bunding, planting and fencing in the southern area and the use of the southern land. This has been helpful in formulating the Stage 2 proposals.
Greater detail of the proposals and wider landscape plans In addition to further information on the proposals for site preparation in the preliminary works application, Stage 2 consultation provides details on both the construction and landscape strategy within the In particular, respondents requested details of the scale of Environmental Appraisal Volume 2 Chapters 2 and 3 and in the assessment of potential impacts on the bund in order to assess the impacts on residents living landscape and visual amenity (Environmental Appraisal Volume 2 Chapter 21) and noise and vibration in the vicinity. (Environmental Appraisal Volume 2 Chapter 10).
Possibility of sinking the power station development into The platform level created for the power station development itself is a function of safety. The level created the ground is determined by requirements to provide flood prevention, taking account of potential sea level rise. It is not possible to sink this level further. However, it should be noted that the platform level is still lower in It was suggested that this would reduce its visual impact relative terms than the rest of the site. The landscape strategy to the south of the development would provide some additional screening of the site.
Hill closest to Bishops Wood to be raised to minimise Landscaping is proposed to be put in place as part of the restoration plan. However, during construction visual impact the current site level would be lowered and levelled for use by the temporary on-site accommodation campus.
Extra landscaping to benefit residents living near Wick Additional landscaping proposed is as a result of the assessment of potential areas affected. Therefore, off- site planting is not proposed. It is intended to provide landscape enhancement from additional planting along Wick Moor Drove.
100 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 4) On-site Accommodation Comments EDF Energy Response
Location of campus Construction land use and spoil storage requirements necessitate the location of the on-site accommodation in the south-east of the site as the optimum location. The campus and associated Requests made to locate the campus as far to the north- landscaping has been developed to minimise the impact on local residents through the siting of the quieter east of the site and as far away from Shurton as possible. accommodation uses along the southern boundary and the recreational facilities to the north of the Concern over the potential impact on the village and its campus development. The lighting and landscaping strategies have been designed with the intention to rural setting. minimise light spill to the residential properties to the south. The campus layout has been designed to sit above the 144750mN line, this being the southern limit of main construction activity.
Potential legacy use In response to consultation with local residents and stakeholders, there are no proposals to maintain the on-site accommodation for legacy use and the site would be restored for ecology and landscape The on-site accommodation would offer very limited legacy enhancement. These proposals are outlined as part of the Stage 2 documentation within the Environmental gains to the local community. There was some concern Appraisal and Preferred Proposals: Explanation and Assessment. about proximity of the on-site accommodation to the nuclear installation. There is no radiation risk to personnel in the on-site accommodation campus from normal operation of the existing nuclear facilities at Hinkley Point. The construction site personnel will be considered as 'members of the public' and subject to protective actions in the Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR) off-site plan to limit radiation exposure following the declaration of an off-site nuclear emergency from the existing nuclear plant. Once the site is licensed as a nuclear site it will be covered by the Nuclear Installations Act, imposing conditions to protect workers and the public.
On-site accommodation as part of overall accommodation EDF Energy carried out further detailed work on its accommodation and transport strategy, taking account strategy of the responses to the Stage 1 consultation and considering: the benefits for regeneration and economic development; the proximity to services and facilities; operational requirements (e.g. size of site); Some respondents felt that all accommodation and environmental constraints (including flood risk and other sensitivities) and the ability for the sites to place facilities for construction workers should be on-site, shape. whereas others sought justification for numbers and distribution of accommodation. Comments were divided as Having regard to all these matters, EDF Energy has concluded that it is appropriate to focus development in to whether the on-site facility was appropriate. two strategic locations, on-site and in Bridgwater. The rationale for the siting and scale of development proposed in each location is set out in the Preferred Proposals: Explanation and Assessment.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 101 STAGE 1 CONSULTATION REPORT
4) On-site Accommodation Comments EDF Energy Response
On-site accommodation should be limited to 700 beds EDF Energy is proposing a 700 bed campus at the Hinkley Point C Development Site. In considering the distribution of workers across the proposed campuses, EDF Energy has sought to ensure that campuses are The number of workers accommodated on-site should be designed with the appropriate facilities to minimise the impact on existing local facilities/services. limited due to impact on the village of Shurton and its rural setting.
Potential social issues The proposed on-site campus has been designed to include recreational facilities to meet the anticipated demands of the workers. This includes sports pitches, meeting areas, eating and drinking facilities and IT Comments were made in relation to increased traffic, and facilities. how the workers would spend their weekends as the village does not have the infrastructure to cope with the proposed Additionally, it is intended that bus services would be provided to transport workers who wish to access influx of workers. Further details on the operation of the facilities off-site. This will minimise traffic impacts. campus and its facilities should be provided. Strict controls would be in place in relation to movements of workers away from the on-site campus and a Effective measures should also be implemented to prevent zero tolerance policy on anti-social behaviour would be in place for the duration of the construction period. unofficial shortcuts from the site to Shurton and Stogursey.
Further consultation required in relation to the on-site Consultation has been undertaken informally with local residents, stakeholders and the Councils in relation accommodation to the provision of landscaping and other mitigation measures to limit the impacts of the on-site accommodation campus upon local residents. Further details on the on-site accommodation campus are provided in the Masterplan: Accommodation Campuses.
Suggestion that all workers should be accommodated on a As part of the optioneering exercise undertaken to determine the types of accommodation provision ship or flotel in the Bristol Channel. suitable for workers, both of these suggested options have been considered. EDF Energy does not favour this option because of the sea conditions and tidal characteristics of Bridgwater Bay (Bristol Channel) and the environmental sensitivity of the marine environment.
102 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 5) Operational Considerations and Design Comments EDF Energy Response
Amount of land take for permanent development and The layout of the development is configured for the safe construction, operation and maintenance of the options for reusing existing site areas at Hinkley Point new nuclear power station. The scope for re-use of existing site areas at Hinkley Point has been considered, however, there are limited possibilities on either the operational (Hinkley Point B) or decommissioning (Hinkley Point A) power stations. Security requirements limit the scope for providing access to shared ancillary facilities, but use of car parking areas will be coordinated. None of the decommissioning site is currently available.
Architectural design principles established The masterplan has been progressed since Stage 1 and has been revised in light of comments received. A masterplan of the Hinkley Point C nuclear power station is presented as part of this Stage 2 consultation EDF Energy’s approach was welcomed and specific (Masterplan: Main Site and Buildings). The document provides a masterplan of the Stage 2 consultation comments made on the form and legibility of the proposals with some design information on the key buildings and structures. Issues relating to the impact masterplan, along with promoting high quality architecture of the masterplan from views of the site are dealt with in the document, including the masterplan vision through the emergence of architectural design principles. approach. The landscape restoration scheme has been designed to ‘fit’ in with the local landscape character and to aid the transition between built form and the wider landscape. It also creates an opportunity to enhance the woodland strategy for Somerset and enhance the biodiversity and ecological interest in the area.
Safety-related issues Regulation of the safety of nuclear installations is the responsibility of the Nuclear Division of the Health and Safety Executive (HSE). Consultees were concerned that safety must be treated as paramount and proved to be adequate before construction The Generic Design Assessment (GDA) and Nuclear Site Licensing processes are separate from the IPC begins. Safety-related concerns included: consenting process. As described in the Nuclear Regulatory Context chapter (Volume 1 Chapter 4) of the Environmental Appraisal, GDA allows for the generic safety, security and environmental implications of the Reactor design and the GDA process. UK EPR reactor design to be assessed by the UK’s nuclear regulators. In particular this explicitly includes Design considerations to ensure cracks do not appear technical review by the regulators of civil engineering, control and instrumentation, mechanical in the cladding. engineering, structural integrity, fuel design, human factors and security aspects. Safety system is not independent of the regular control systems. As described in the Nuclear Regulatory Context chapter of the Environmental Appraisal, site specific design and operational aspects relating to nuclear safety are considered in the nuclear site licence processes. Human error. Consent to construct the reactors would only be granted once the regulators are content that all nuclear Interaction with military and aviation activity. safety matters have been satisfactorily progressed. The licensing assessment will include any exclusions Potential impact of incidents on police operations. from and any proposed changes to the site specific design that was submitted to the nuclear safety Accident risk. regulator for GDA approval.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 103 STAGE 1 CONSULTATION REPORT
5) Operational Considerations and Design Comments EDF Energy Response The Nuclear Regulatory Context chapter of the Environmental Appraisal also describes the requirements for emergency plans relating to incidents and the arrangements for managing interaction with the relevant authorities to ensure that the implications for military and aviation activities are covered.
Further consultation with relevant bodies on safety issues The Nuclear Regulatory Context chapter of the Environmental Appraisal describes the regulation of the safety of nuclear installations under the Nuclear Installations Act 1965 (as amended). It also describes the wider framework for the regulation of nuclear safety, security and environmental protection that relates to new nuclear development at Hinkley Point.
Sustainable operation The Sustainability Evaluation describes the approach EDF Energy has taken to considering and integrating sustainability into the project. It provides details of the extent to which the proposals accord with the Understanding needed of the measures to be put in place principles of sustainable development as set out by the Government’s Sustainability Objectives for New to ensure sustainable operation. Nuclear Power Stations. The document also takes into account policy objectives identified at the regional and local levels of Government, to demonstrate how local objectives for sustainable development can be met by the project. During the operation of the power station, the generation of nuclear power from Hinkley Point C would provide a substantial contribution to helping the UK meet its carbon reduction targets by the delivery of low carbon electricity. There would also be wider sustainability benefits, which include the socio-economic benefits from the scheme during construction and operation.
Further details needed on the appropriate levels of security The Nuclear Regulatory Context chapter of the Environmental Appraisal describes the regulation of the security of the UK’s civil nuclear industry under the Nuclear Industries Security Regulations. The security Measures needed to ensure appropriate security and regulator is the Office of Civil Nuclear Security (OCNS) which approves the site security plan and provides protection including counter-terrorism measures and site vetting of personnel. Security arrangements cover physical and information security measures, but by their security. nature details are not published.
Further details needed on utilities provision EDF Energy is working with the utility providers to address the requirements for water and waste water services, for example. The utility water supplies for staff welfare would be drawn from the bulk supplies to E.g. water and waste water services. the station. Sewage treatment facilities would be supplied on-site and be self sufficient.
104 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 6) Landscape and Visual Amenity Comments EDF Energy Response
Methodology of assessment The Environmental Appraisal chapter relating to landscape and visual impacts (Volume 2 Chapter 21) includes the agreed viewpoints based on meetings and consultations with statutory consultees and local Further details requested on the provision of viewpoints to residents. Having worked closely with key statutory consultees, a number of additional agreed viewpoints inform the Landscape and Visual Impact Assessment (LVIA) were added to the LVIA in order to address the comments raised at Stage 1. The Environmental Appraisal and request for additional viewpoints including recognition sets out the assessment process and conclusions in relation to the LVIA. A baseline study of the existing of historic landscape. Clarification requested on points of site has been carried out which recognises the historic landscape and this has helped to inform which fact and baseline material. elements or features are particularly sensitive to the proposed development.
Visual baseline assessment should be provided for The whole Hinkley Point C Development Site has been considered within the LVIA and as outlined above. southern construction area
Photomontages The study area for the LVIA of the development was determined by the analysis of the Ordnance Survey data and it broadly follows the extent of the predicted visibility of the Hinkley Point C site within the surrounding Images provided at Stage 1 show the relationship of the landscape. The study area was also assessed using 3D modelling techniques and took account of advice development to the coastline, and the scale of the from consultees. development against existing structures. Respondents commented that it was not clear why the particular Stage 1 only presented a small number of the photomontages available. Further work on the visual impact photomontages were selected. assessment of the Hinkley Point C project and a full set of photomontages are set out within the Environmental Appraisal.
Impact on existing views Where feasible, building materials will be selected to mitigate against the visual impact of the buildings on the local environment. Materials will generally be light or natural grey in colour and will be selected for Respondents focused on the visual impact of the power design life, durability and ease of maintenance. Landscape materials are proposed that will reflect the local station in relation to building materials, and landscaping. environment, and where feasible would be locally sourced. Respondents suggested that the appearance could present risk to the perception of the coast and the rural setting.
Impact on wider landscape setting The Quantock Hills AONB service continues to be consulted by EDF Energy on the viewpoints from which visual assessment should be carried out to ensure viewpoints are representative of the Quantock Hills Comment made on potential impact on surrounding area AONB. Additional photographs will be taken in the summer to supplement the images in the ES submitted and potential impact on the AONB. with EDF Energy’s DCO application.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 105 STAGE 1 CONSULTATION REPORT
6) Landscape and Visual Amenity Comments EDF Energy Response
Cumulative impacts on views As part of Environmental Appraisal Volume 2 Chapter 3, construction phasing plans are presented. These construction phasing plans present the of key stages of the construction programme i.e. site preparation Images needed to show impact on views caused by the through construction to restoration of landform and landscape. A selection of viewpoints within Chapter 21 addition of Hinkley Point C to Hinkley Point A and B. show what the restored landscape will look like. Clarification sought on timings for the removal of Hinkley Point A and B in the future and the resultant impact on The visual impact of Hinkley Point C with the existing Hinkley Point A and B stations is assessed in the views. Environmental Appraisal in Volume 2 Chapter 21. Timings for the removal of the Hinkley Point A and B stations are dependent on the programme delivered by the Nuclear Decommissioning Authority. Consideration of the cumulative visual impact of the proposed Hinkley Point C Project in-combination with Hinkley Point A and B activities is provided in the Environmental Appraisal chapter relating to cumulative effects.
Interaction with masterplan and design Drawings and description of the masterplan design development since Stage 1, including building forms and use of materials, are included in the Masterplan: Main Site and Buildings for Stage 2 consultation. Respondents felt that the masterplan needed further development so that it responds to all key viewpoints and The arrangement of buildings on site has been developed in response to functional and engineering has a positive impact on the wider setting. Additionally, requirements and by optimising the use of site levels to mitigate against adverse visual impact. The larger clarification was sought on whether the masterplan would built form is arranged to sit on the lowest platform level in relation to its surroundings. The proposed build on the predominant character of the existing landscaped striations running across the site provide a set of rules for the setting out of buildings which complex. bring an order and coherence to the development. These hard landscaped striations merge into soft landscape equivalents, which in turn merge with the surrounding natural landscape. It was felt that preparation of masterplan should be iterative with the visual assessment.
Potential landscape and visual mitigation The Environmental Appraisal chapter on Landscape and Visual (Volume 2 Chapter 21) explains landscape mitigation proposals. The visual impact of the permanent development should be mitigated as much as possible. The accommodation of construction spoil on-site presents opportunities for visual mitigation, using landform to provide a transition between the rural landscape and the proposed Hinkley Point C nuclear Suggestions were made for a number of mitigation power station, helping the development to sit well within the site and landscape. measures including screen planting of trees; measures to prevent light pollution; and consideration of building The overriding approach to the restoration proposals has been the restoration of landform and landscape materials which could reduce visual impact. character (including historic landscape), whilst increasing biodiversity.
106 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 6) Landscape and Visual Amenity Comments EDF Energy Response Building materials will be selected to mitigate against adverse visual impact of the buildings on the local environment. Materials will generally be light or natural grey in colour to minimise impact, and will be selected for design life, durability and ease of maintenance. Landscape materials are proposed that will reflect the local environment, and where feasible would be locally sourced. Planting will also be used as a mitigation measure. A lighting strategy is provided in the Environmental Appraisal (Volume 2 Chapter 2) and is assessed within the Landscape and Visual chapter (Volume 2 Chapter 21).
Further detail on the LVIA and consultation on landscaping All information relating to the LVIA is available, including further technical information, as outlined in the proposals Landscape and Visual chapter of the Environmental Appraisal (Volume 2 Chapter 21).
Stakeholders suggested that further details should be Further consultation with key consultees to discuss more detail behind the restoration scheme is scheduled provided, including making the LVIA and supporting plans for during Stage 2 consultation and leading towards the DCO application. available.
7) Spent Fuel, Waste and Decommissioning Comments EDF Energy Response
Sustainable waste management The Environmental Appraisal chapter on Spent Fuel and Radioactive Waste Management (Volume 2 Chapter 6) discusses the integrated waste strategy and the waste hierarchy principles that would be adopted for Respondents suggested there should be a sustainable radioactive waste. For conventional waste, Volume 2 Chapter 7 of the Environmental Appraisal addresses approach to waste management and the provision of Site issues relating to sustainable waste management including, for example, the waste hierarchy. Waste Management Plans.
On-site storage of spent fuel The Environmental Appraisal chapter on Spent Fuel and Radioactive Waste Management (Volume 2 Chapter 6) provides further information on the on-site storage facility in terms of the spent fuel interim storage Stakeholders sought clarity on the provision of on-site strategy, lifecycle and the proposed storage facility outline design and operation. The on-site spent fuel storage of spent fuel and the potential environmental risks interim storage facility will only be used for Hinkley Point C spent fuel arisings. On-site storage of spent fuel associated. pending final disposal is in line with Government policy (Meeting the Energy Challenge, A White Paper on Nuclear Power, DECC January 2008).
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 107 STAGE 1 CONSULTATION REPORT
7) Spent Fuel, Waste and Decommissioning Comments EDF Energy Response The site will be subject to a Nuclear Site Licence and environmental permits which would only be granted if measures to ensure adequate environmental, safety protection and waste containment measures are in place, including those requirements for the NII and Environment Agency (EA).
For further information see the Environmental Appraisal comments on the timing of all waste management processes.
Potential leakage of waste into the environment There is a licence condition within the Nuclear Site Licence regarding the containment of waste. A licence would only be granted if it is demonstrated that appropriate measures are in place to prevent leaks of waste. Nuclear Site Licence arrangements are described in the chapter on Nuclear Regulatory Context in the Environmental Appraisal (Volume 1 Chapter 4).
Currently no availability of final repository for higher level The process for establishing a geological disposal facility for higher activity radioactive waste is in its early wastes stages. It is a Government-led process and further information can be found in the chapter on Spent Fuel and Radioactive Waste Management (Volume 2 Chapter 6) of the Environmental Appraisal. However, the provision of this facility does not form part of the determination by the IPC in granting the DCO. It will be provided in due course by an appropriate party in the future. The Nuclear Decommissioning Authority is the implementing organisation responsible for planning and delivering the geological disposal facility and, as part of this process, will engage with communities and other stakeholders.
Potential Health Impacts A Health Impact Appraisal has been commissioned to further investigate and address the community health concerns. This builds upon the outputs of the Stage 1 consultation and has been further refined with input A number of respondents recommended that impacts, if from the Primary Care Trust and Local Authorities. any, on long term human health and the environment from waste storage should be considered and that a Health The Appraisal is primarily intended to inform the IPC process, but is also intended to provide local Impact Assessment should be carried out. A response to communities with information to address their particular health concerns. local health studies on infant mortality and cancer, Additionally, impacts on human health are also considered within the Environmental Appraisal in the radionuclides and damage to DNA was also recommended. Radiological chapter (Volume 2 Chapter 20).
108 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 7) Spent Fuel, Waste and Decommissioning Comments EDF Energy Response
Decommissioning The Stage 2 consultation documents provide more detail on the decommissioning strategy for Hinkley Point C. The strategy is for prompt decommissioning so that long term monitoring arrangements would not be More information on the decommissioning strategy and needed, except in relation to the spent fuel storage building. Decommissioning will be subject to its own associated environmental considerations was requested. Environmental Impact Assessment (EIA) at the appropriate time. An explanation of the decommissioning plans and funding arrangements was also requested. The costs for waste management, decommissioning and spent fuel management will be funded through a Funded Decommissioning Programme (FDP) which will need to be approved by the Secretary of State. The FDP ensures that EDF Energy sets aside funds over the life of the power station to cover the full costs of decommissioning and the required waste management and disposal costs. The Decommissioning chapter within the Environmental Appraisal (Volume 2 Chapter 5) expands on this strategy.
8) Marine Development Comments EDF Energy Response
Cooling water tunnels The Environmental Appraisal chapters 2 and 3 of Volume 2 provide additional detail on the extent of the cooling water tunnels and their means of construction as well as the intake and outfall structures Stakeholders requested more detail on the construction themselves. Extensive environmental studies have been carried out in the vicinity permitting both an and design of options presented for the cooling water understanding of the marine ecological sensitivities concerned and the development of predictive tunnels and mitigation proposed. The potential impact of numerical modelling tools. Detailed assessment of alternative configurations for the intake and outfall has the cooling water would need to be fully assessed, also been carried out. A preferred configuration has been identified for further more detailed assessment. including modelling and assessment work to inform a Habitats Regulations Assessment (HRA) (addressing the In relation to the Habitats Regulations Assessment (HRA), a series of further studies are being undertaken potential significant impact of the outfall tunnel, associated with input from stakeholders. These various studies and current best understanding of their findings and thermal plume and chemical deposition on designated consequences are also described in the Environmental Appraisal chapter on Marine Water and Sediment sites) and potential impact on military activity. Quality (Volume 2 Chapter 17) and Coastal Geomorphology and Hydrodynamics (Volume 2 Chapter 16). Cooling water tunnel arisings and their constitution was The Environmental Appraisal provides further detail on cooling water tunnel arisings and the proposed also discussed by stakeholders. means of management. Impacts relating to marine activities are dealt with in Volume 2 Chapter 25 in the Environmental Appraisal.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 109 STAGE 1 CONSULTATION REPORT
8) Marine Development Comments EDF Energy Response
Sea wall The proposed sea wall for the development is deliberately set behind the current seaward facing line of the Comments focused on the potential for coastal squeeze, existing cliff and designed for coastal protection along the site frontage. Potential impacts including those relating to hydrodynamic processes are assessed in the Coastal Geomorphology and Hydrodynamics increased localised flooding and impact on local coastal processes, especially those affecting sea defences to the chapter of the Environmental Appraisal (Volume 2 Chapter 16). The facing of the structure, in plan view, east of the site. Further details were requested on the would be smooth and plane so as to avoid any hindrance to possible wave driven sediment transport processes on the upper shore. The Environmental Appraisal chapter on the Description of the Permanent construction of the sea wall including its treatment of the east and west boundaries and full assessment of its Development and Construction Activities (Volume 2 Chapter 2) provides further details of this design potential impacts including its interaction with the jetty and including some detail of how it is to be finished at both its eastern and western extremities. The jetty would not be integrated into this design, being a temporary structure, and at its landward end would simply be cooling water infrastructure. elevated to cross over the line of the sea wall without causing any interruption to access along the coast. Cooling water tunnels would be buried at depth and, again, would not have any interaction with the sea wall. The cooling water intake and outfall structures would be connected to the cooling water tunnels, deep under the seabed, by vertical shafts and would be sufficiently far off-shore that no interaction between these isolated seabed structures and the sea wall would be foreseen.
Construction and potential environmental effects of the The Environmental Appraisal chapters on the Description of the Permanent Development and Construction jetty Activities (Volume 2 Chapter 2), and Construction Programme (Volume 2 Chapter 3), provide further details Detail was requested on the size, location, construction of the proposed design and construction of the jetty, including the proposed means of fixing it securely to the sea bed and shore. The primary means of mitigation of potential marine environmental impacts has methods and materials intended to be used for the jetty and on the environmental impact assessment undertaken. been to select an open piered design option which would be highly transparent to both waves and tidal Some respondents wanted the jetty to be as small as currents. No impact on either the wave regime close to shore or the existing tidal hydrodynamic regime possible and located to the east, away from Shurton Beach. would be anticipated as a result. Respondents requested an outline of the studies that have There would be a need to dredge a shallow ‘berthing pocket’ in the sea bed immediately fronting the head been undertaken on the effects of the jetty on coastal of the jetty in order to allow vessels to rest there over the time of low water without impacting on the sea processes. bed. The Environmental Appraisal describes both the means of constructing this berthing pocket and the extent of any impacts that might be expected. As described in the Environmental Appraisal (Volume 2 Chapters 16 and 19) the alignment proposed for the jetty has taken into account the distribution of potentially sensitive species both on the intertidal and immediate subtidal areas. The intention is that the jetty would be made up, as far as possible, of a series of individual modules which
110 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 8) Marine Development Comments EDF Energy Response would aid both construction and subsequent decommissioning and potential re-use.
Use of the jetty The jetty is proposed as a temporary structure to facilitate construction of Hinkley Point C by allowing aggregate and bulk loads to be delivered by sea. It will be used in the construction period of Hinkley Point More information was requested on use of the jetty, C, principally during the main construction phase, to bring in as much material by sea as possible. At maritime traffic, dredging and disposal activities and present, it is assumed that vessels will be able to berth 24 hours a day and details of anticipated monthly implications for firing ranges. Respondents wanted an volumes can be found in the Environmental Appraisal. Once Unit 2 becomes operational, the jetty will explanation of why the jetty cannot be used to bring in cease to be used and removed, minimising its environmental impact. The use of the jetty will remove more materials. Maximum use of the jetty to minimise significant numbers of HGVs from the road network, therefore mitigating potential increases in pollution impact on the roads was suggested, however there was associated with the construction of HPC. some concern that the extra ship movements would cause more sea pollution. A two metre deep berthing pocket will be dredged adjacent to the jetty head. The dredged material would be comprised of silts, and options for its disposal are currently being explored. Further details can be found After construction the majority of respondents wanted the within the Environmental Appraisal. structure to be removed, however others suggested that it should be permanent and used for shipping. EDF Energy is engaged in ongoing consultation with the relevant bodies regarding potential impacts to military and marine activities.
Marine works The extent of fishing in the locality has been assessed and this understanding is described in the Environmental Appraisal Amenity and Recreation chapter (Volume 2 Chapter 24). EDF Energy understand Consideration requested of safety aspects including there to be both rod fishing from the shore and recreational rod and line fishing from small vessels. There assessment of military activity on the proposed marine would be no loss of fishing grounds as a result of this proposal but restricted access to limited areas of the development and vice versa, and consideration of shore and off-shore would be required for health and safety purposes during construction. Subsequently, unexploded munitions or hazardous substances in during the jetty’s operational life there would be a need, again for health and safety reasons, for small Bridgwater Bay. Also possible loss of fishing ground which vessels to keep clear when shipping operations are actually under way. has recreational value.
Further Consultation EDF Energy has and will continue to liaise with relevant bodies in connection with these proposals, and in order to meet the expectations of these bodies. Additional consultation with relevant bodies to address the EIA matters in association with marine works was requested.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 111 STAGE 1 CONSULTATION REPORT
9) On-site Car Parking and Access Comments EDF Energy Response
Emergency access road – suitability, appropriateness and The emergency access road is intended for very occasional use in exceptional circumstances and would design therefore normally be closed with locked gates. The road will be a single track road with passing places designed to carry the weight of emergency vehicles. The specification would be for an unfenced low- Clarity was requested on the use, design and management maintenance road suitable for occasional use and with no street lighting. The road would be of the route noting the proximity of the route to nearby accommodated within the final landscaping proposals and at an elevation to avoid the risk of flooding. A residents, flood prevention works required and the bridge over Bum Brook would be designed to carry the road and a footpath and provide sufficient clear potential loss of rurality. It was commented that the access space under the bridge to avoid exacerbating any flood risk from Bum Brook. It is envisaged that the bridge roads and gate should not be lit at night and that the gate over Bum Brook could form part of the Public Rights of Way (PRoW) network incorporated in the final and fencing should be secured and kept in keeping with the landscaping scheme. rural nature of the village surroundings. It was suggested that the road should be positioned as far away from residential properties as possible and shielded by screening. Clarity was sought on use as a Public Right of Way (PRoW).
Further consultation requested on emergency access road The alignment of the emergency access road is shown in the final landscaping arrangements. An indicative drawing of the proposed bridge over Bum Brook is also presented in the Environmental Appraisal Volume 2 To discuss suitability and present further design details. Chapter 2 (Description of the Permanent Development and Construction Activities). EDF Energy will continue to consult with local residents and other stakeholders on the detailed design in advance of the application for consent.
Further understanding of car parking and number of parking Three car parks are proposed. A permanent car park in the order of 500 parking spaces for operational staff spaces will be located to the south-east of the Hinkley Point C site. During much of the construction period, much of this car park would be used as a construction work area. In addition, a permanent car park in the order of Information was requested on the number of car parking 500 parking spaces will be provided for planned ‘outage’ (i.e. maintenance and refuelling) purposes along spaces proposed and use of the outage car park. It was with an additional smaller car park for overflow purposes. suggested that parking should be provided on-site, at a level that does not encourage unnecessary trip generation. During construction, the ‘outage’ car park would be used for park and ride buses and will not be available for cars, except for a small portion associated with the training centre which would become available when the Simulator Building/Training Centre has been built.
112 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 9) On-site Car Parking and Access Comments EDF Energy Response
Any changes to the existing access road Wickmoor Drove (the C182) would be modified to incorporate a roundabout for the southern construction area entrance and a junction to serve the on-site accommodation campus area. Further north, within the Clarity requested on any changes proposed to the existing existing Hinkley Point B site, a new roundabout would be constructed to provide access to the new Hinkley access road into the Hinkley Point Power Station Complex Point C power station. No other changes are proposed to the existing roads north of Cannington. to enable use by the proposed development.
Cycle path provision Cycle provision is outlined in the Environmental Appraisal chapter in relation to the proposed development. However, there is currently no provision for cycle paths along the C182. Respondents suggested the provision of a cycle path along the existing access road, the C182.
10) Overhead Line Infrastructure Comments EDF Energy Response
Potential impact of proposed overhead lines The Environmental Appraisal chapter Terrestrial Ecology and Ornithology (Volume 2 Chapter 18) provides information on the potential impact on the local bird population of the proposed EDF Energy overhead lines Impact should be assessed on important bird populations. on-site. This chapter does not assess the potential impact on the local bird population from the proposed National Grid transmission lines. Mitigation is put forward in the Environmental Appraisal chapter based on the principles agreed with consultees. The types of birds found to use the Hinkley Point C site were found to be low flying so higher towers help to mitigate against strikes. The Environmental Appraisal section on cumulative effects provides information on the potential impacts of the proposed National Grid transmission lines connecting the proposed 400kV substation to their existing infrastructure.
Relationship to National Grid’s proposals In relation to the transmission infrastructure, the EDF Energy’s DCO application would include:
Relationship between National Grid connection and the the 400kV Gas Insulated Switchgear (GIS) substation and associated electrical plant and equipment; proposals and EDF Energy plans should the new and transmission lines from Hinkley Point C not eventuate. three double circuit terminal towers which connect to six overhead line gantries via downleads. These works would be designed, constructed, installed and commissioned by National Grid. Also included in the EDF Energy’s DCO application would be two overhead line circuits for the generating units
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 113 STAGE 1 CONSULTATION REPORT
10) Overhead Line Infrastructure Comments EDF Energy Response which would connect the GIS substation with the Turbine Hall. These two circuits would be strung across six towers in total on towers of up to 68m in height. There would also be two underground circuits for the auxiliary station transformer which would also connect between the substation and the Turbine Hall. In order to connect the proposed Hinkley Point C power station into the high voltage electricity transmission system, National Grid will be required to undertake modifications and diversions to existing overhead lines in the vicinity of Hinkley Point. These overhead line modifications and diversions will form part of a separate application for development consent by National Grid and will deal with the overhead lines from the three terminal towers to existing overhead lines east of the power station site. The overhead lines and tower positions illustrated within the Stage 2 documentation are indicative only and will be refined following further environmental studies and public consultation. EDF Energy is prepared to submit its DCO application and make financial commitments in advance of National Grid submitting its DCO application and obtaining consent. The draft NPS for Electricity Networks Infrastructure recognises that applications for new generation stations and related infrastructure should preferably be contained in a single application to the IPC. However, it also recognises that this may not always be possible due to differing lengths of time needed to prepare applications or because the works involved are strategic reinforcement required for a number of reasons. It may also be the case (as in this instance) that the networks and generating station applications will come from two different legal entities subject to different commercial and regulatory frameworks.
Comment on National Grid’s proposals regarding the route National Grid’s proposals are subject to a separate pre-application consultation process and separate DCO options, including proximity to Pixies Mound. application, as they are regarded as a Nationally Significant Infrastructure Project (NSIP) in their own right. Joint consultation with National Grid has been carried out with Natural England, English Heritage and West Somerset Council since Stage 1, specifically with respect to the overhead lines required to connect the proposed substation with the existing transmission system. National Grid’s overhead line connections have been designed taking account of feedback during consultation prior to Stage 2. However, at this stage the overhead lines are indicative only and will be refined further following further environmental studies, stakeholder and public consultation.
Further consultation was recommended Joint consultation with National Grid has been carried out with Natural England, English Heritage and West Somerset Council since Stage 1, specifically with respect to the overhead line route options coming from the
114 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 10) Overhead Line Infrastructure Comments EDF Energy Response substation and connecting into the National Grid transmission system.
11) Amenity and Recreation Comments EDF Energy Response
Public Rights of Way – potential impacts and mitigation for The Environmental Appraisal chapter on Amenity and Recreation (Volume 2 Chapter 24) sets out the public access to footpaths proposed diversions of the PRoW during the construction period and also the proposed reinstatement of a rationalised network during the operational period. Impacts and mitigation are detailed. Respondents noted that the proposed development would affect a number of footpaths and mitigation should be Currently a number of the PRoW on-site and along the adjacent Benhole Lane are unusable at certain times identified to manage any adverse impacts, during both the of year due to poor drainage. construction and operation period. Respondents requested EDF Energy proposes to address drainage issues to ensure that PRoWs are useable all year during both the maintaining as many PRoWs as possible and the provision construction and operational periods. of alternative PRoWs to mitigate closure of existing footpaths. In addition, following construction, the rationalised reinstated network would include additional bridleway and cycle access across the east-west track as well as a number of permissive paths in the southern area. It Measures should be explored to rationalise the existing is intended that interpretation boards and links with the visitors centre will enhance the experience of using PRoW network, and more information was requested the PRoW and provide benefits to both local users and visitors. regarding impacts on existing PRoW in order to understand how public access would be maintained.
Coastal Footpath The need to keep the West Somerset Coast Path open for as much of the time as possible has been noted following discussions with Somerset County Council’s Rights of Way Team and respondents to the Stage 1 Request to keep the coastal footpath open during consultation. construction and fully restored afterwards. For safety reasons, the West Somerset Coast Path will need to be closed for between 18 months and three years while the sea wall is constructed. However, EDF Energy will aim to re-open the path (which will run along the top of the new sea wall with steps down to the beach) as soon as possible and it will then remain open for the remainder of the construction period and the operational period.
Public Rights of Way to the south of the site There will be a PRoW along the southern edge of the construction site as part of the diversions necessary for the construction period. Suggestion for new PRoW in parallel to the landscape
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 115 STAGE 1 CONSULTATION REPORT
11) Amenity and Recreation Comments EDF Energy Response buffer, although some respondents were concerned about During the operational period, it may be possible to create a PRoW or permissive path in this location and the close proximity of footpaths to residential properties. views on the desirability of this are welcomed as part of the Stage 2 consultation.
Benhole Lane Discussions have been held with Somerset County Council’s Public Rights of Way Team regarding moving part, or all, of the Benhole Lane PRoW to run up the western boundary of EDF Energy’s land (this is directly Respondents suggested improvements to Benhole Lane parallel to Benhole Lane and is separated only by a hedge), or, improving the drainage to Benhole Lane and maintaining its current form with access to the coast itself so that it is useable all year round. These options are still under consideration. along the western boundary of the site from Benhole Lane to the Coastal Path.
Public access and ecological mitigation EDF Energy’s consultants on ecology, landscaping and PRoW are working together on the post construction restoration proposals. As well as the designated PRoW, a number of permissive paths, including nature A coordinated approach recommended. trails, will be provided through the southern ecology area.
Provision of on-site recreational facilities EDF Energy has developed its proposals for on-site recreational facilities and these are described in the Masterplan: Accommodation Campuses, and further consideration is provided within the Socio-economic More information sought on the provision of on-site chapters of the Environmental Appraisal. Consideration is also being given to retaining access to the recreational facilities and it was noted that the assessment footpaths at the southern edge of the Hinkley Point C Development Site. A Public Information Centre is needed to demonstrate a greater understanding of the level included within the proposals. of recreational services currently provided within the surrounding area in order to determine the requirement and No assumptions are made about the level of recreational services currently provided in the surrounding type of on-site facilities. It was also suggested that an area. amenity area to compensate for PRoW closures at the southern edge of the site should be set aside during construction. Respondents requested a viewing area or visitors centre be made available during construction.
Provision of off-site recreational facilities Recreational amenities will be included within the proposed development of accommodation campus. Further information on this can be found within the Masterplan: Accommodation Campuses. It was asked what the location would be of any off-site recreational facilities to supplement those provided on-
116 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 11) Amenity and Recreation Comments EDF Energy Response site.
Provision of cycle paths Following consultation with Somerset County Council’s PRoW Team, the east-west track will be upgraded to The establishment of new cycle routes between Williton provide cycle access following construction. and the Hinkley Point C site, and the upgrade of the coastal The Transport section of the Environmental Appraisal, Proposed Travel Plan and Transport Appraisal deal path to include provision for cyclists was requested. with longer distance cycle path provision and discussions with Somerset County Council are being held on this issue.
12) Historic Environment Comments EDF Energy Response
Further information on survey results EDF Energy has carried out extensive archaeological work on-site and in the vicinity which is summarised in Respondents requested further information on survey the Environmental Appraisal chapters Historic Environment and Off-shore and Inter-tidal Archaeology results in order to make appropriate assessment of the (Volume 2 Chapters 22 and 23). This includes: impacts. Desk Based Assessments for the Hinkley Point C Development Site and each Off-site Associated Development site; Geophysical Surveys for all sites except J23 and Bridgwater (which were not suitable for geophysical survey); and Archaeological Trial Trenching for all sites except Bridgwater (sites not suitable for trial trenching) and the Cannington Bypass (which will be investigated following IPC consent, if granted).
Impact Assessment for historic environment Stage 2 begins to look at the impacts of the Hinkley Point C development and Off-site Associated Development on heritage assets and some initial mitigation measures are proposed. Mitigation measures for the buried archaeology (as evaluated by geophysical survey and archaeological trial trenching), built heritage assets (the barns) and historic landscape features (the historic trackway) on the Hinkley Point C Development Site have been agreed with SCC. These will comprise preservation by record for the buried archaeology, the barns and any parts of the trackway that are lost. The major part of the trackway will be preserved in-situ. Mitigation of impacts on designated sites beyond the site boundary is being discussed with English Heritage.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 117 STAGE 1 CONSULTATION REPORT
12) Historic Environment Comments EDF Energy Response Consultation with SCC will continue throughout Stage 2.
Assessment of potential impact on historic environment The Desk Based Assessment for the Hinkley Point C Development Site has been extended to include assets and character of the area designated assets (excluding Grade 2 Listed Properties) within a 10km radius and Grade 2 Listed Properties within a 5km radius in response to English Heritage’s Stage 1 consultation response and subsequent Better understanding needed of historic assets located discussions between EDF Energy, SCC and English Heritage. within and around Hinkley Point C, and assessment of potential impacts on designated and undesignated Also in response to English Heritage’s and Natural England’s Stage 1 consultation responses, a meeting was features and sites. Further work required to establish visual held in April 2010, followed by a site visit around a number of cultural heritage sites in April with EDF impacts on historic assets. Energy’s Landscape consultants and Heritage consultants, English Heritage, SCC and Natural England’s landscape team (and in part the Quantock Hills AONB Service) to discuss additional heritage receptors for the Landscape and Visual Impact Assessment. A number of additional/replacement viewpoints were agreed and these are included in the updated LVIA presented in the Environmental Appraisal.
Welcomed opportunity of further consultation Consultation with SCC and English Heritage has continued between Stage 1 and Stage 2 and will be ongoing including meetings with SCC and English Heritage. In particular, several monitoring meetings have been held with SCC at each of the archaeological trial trenching sites. English Heritage’s Regional Scientific Adviser has attended some of these meetings. Meetings with SCC to discuss trench plans and potential mitigation for the Hinkley Point C Development Site have also been held. In addition, meetings and a site visit have been held with English Heritage to address the issues raised by English Heritage in response to the Stage 1 consultation. EDF Energy welcomes the opportunity for further consultation throughout Stage 2.
An appraisal should be undertaken to inform the As per the response above, EDF Energy has carried out further assessment prior to Stage 2 consultation. assessment of impacts on the historic environment Stage 2 provides initial discussion on the impacts and mitigation of heritage assets. Additional work and consultation with SCC and English Heritage will be undertaken on this throughout Stage 2. This should include the identification of appropriate mitigation measures to manage these impacts.
118 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 13) Environmental Information and Assessment Comments EDF Energy Response
Availability of technical documents The Environmental Appraisal for Stage 2 consultation reports on the environmental assessment work undertaken so far in relation to the Hinkley Point C Development Site and Off-site Associated Developments. Technical information was requested either prior to or at Technical assessments are reported in topic–specific chapters which are presented in Volumes 2 and 3 for Stage 2 consultation. the Hinkley Point C Development Site and Off-site Associated Developments respectively. Relevant technical reports that have informed the Environmental Appraisal are referenced and presented as appendices. Furthermore, technical reports have also been made available to statutory consultees prior to the Stage 2 consultation through various ongoing liaison groups.
Assessment of impacts and mitigation The Environmental Appraisal provided as part of this Stage 2 consultation includes:
Consultees wished to ensure the comprehensive and a definition of the current baseline; rigorous assessment of the potential effects of the details of the impact (or ‘effect’) assessment; project, which should also be suitable to inform the proposed mitigation measures (including monitoring) to avoid, reduce or off-set potentially significant appropriate assessment. They wished to ensure that the effects; and Environmental Statement (ES) would incorporate commitments to monitoring and mitigation measures. assessment of any residual impacts after implementation of mitigation. Assessments undertaken as part of the Environmental Statement to be submitted with the DCO application will be used to inform the Appropriate Assessment required under the Conservation (Natural Habitats &c.) Regulations (the ‘Habitats Regulations’). EDF Energy has engaged in consultation with statutory consultees who have an interest in designated sites which have the potential to be impacted through development at Hinkley Point C.
Further details on baseline, methodology, assessment As noted above, the Environmental Appraisal presented as part of Stage 2 consultation provides details on: and further studies the baseline environment informed through desk-based studies, surveys and site investigations; Detailed comments from the Councils relating to the the methodology employed to undertake the environmental impact assessment; request for further information in order to provide a the outcomes of the impact assessments to date; thorough assessment with information being made available to stakeholders as soon as possible. proposed mitigation; and potential residual effects. Any ongoing survey work together with a programme for completion of this work is identified within the
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 119 STAGE 1 CONSULTATION REPORT
13) Environmental Information and Assessment Comments EDF Energy Response Environmental Appraisal. The details described above are presented within the relevant technical chapters. Any further information, not appropriate for presentation within the Environmental Appraisal.
Baseline information and assessment The Environmental Appraisal provides details on the baseline studies and impact assessment undertaken to date. Where work is ongoing, or programmed to be undertaken outside Stage 2 due to time or seasonal Additions to baseline assessment and further information constraints, these are identified in the Environmental Appraisal and the proposed scope of works identified. or clarity on baseline material should be provided in some environmental topic areas.
Further details on proposed studies As outlined previously, the Environmental Appraisal provides details on Phase 2 intrusive investigations undertaken to date and sets out any further proposed studies required to support the EIA, including Phase 2 Including scope and timing of Phase 2 intrusive intrusive investigations. investigation.
Inclusion of references to source material and guidance Source materials and guidance referenced within the chapters of the Environmental Appraisal is provided within a reference list at the end of each chapter. Other material is included within the appendices. More detail should be provided in a number of environmental topic areas.
Further consultation recommended EDF Energy has consulted with the relevant consultees on the scope of the assessment, proposed methodology and assessment outcomes, where appropriate. An outline of all key consultations undertaken to Consultation with relevant bodies on the ES prior to date, with respect to specific technical assessments, is presented within the relevant technical chapter. commencement of the construction works was requested and details of consultation already undertaken with technical consultees, including agreement on assessment methodology and recommended further work was sought.
120 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 14) Other Environmental Issues
Hydrology , Drainage and Flood Risk Comments EDF Energy Response
PPS25 compliant Flood Risk Assessment which also For the purpose of the DCO application, a FRA will be undertaken in accordance with Planning Policy takes account of local policies and plans Statement 25: Development and Flood Risk (PPS25) and will also take into account the draft Nuclear NPS. A Ensure flood risk and surface water drainage are fully preliminary study (Flood Risk Study: Hinkley Point C and On-site Associated Development) provided at Stage assessed and appropriately managed. A PPS 25 2 is in line with PPS25. compliant Flood Risk Assessment (FRA) is required as part Further guidance documents include Strategic Flood Risk Assessments, Environment Agency maps and of the construction site lies within Flood Zone 3. documentation, regional and local development plans, and management plans. The Flood Risk Study: Hinkley Full account should be taken of the Strategic Flood Risk Point C and On-site Associated Development is presented as a standalone document for Stage 2 and is Assessment for Sedgemoor, the Local Development summarised within Volume 2 Chapter 15 on surface water in the Environmental Appraisal. Framework, Shoreline Management Plans for the area, the Steart Managed Realignment Project, and other plans or projects.
Potential contamination risks to surface water quality The contaminated land and groundwater chapters of the Environmental Appraisal (Volume 2 Chapters 13 and Potential impacts on surface water quality in relation to 14) provide details on potential contaminants and assesses the risk of contaminant pathways through the potential contamination already present on-site and use of site models. Potential effects of identified contamination on surface water resources are assessed in surface water run-off should be assessed and managed the surface water chapter (Volume 2 Chapter 15). to meet the appropriate pollution prevention guidelines.
Climate change and sea level rise Hinkley Point C will make a major contribution towards the UK’s Low Carbon Transition Plan for combating Consultees were concerned that the power station could climate change. However, the need for Hinkley Point C to be robust against the consequences of climate be under water in a few years. Additionally, that the change, particularly sea level rise, is also fully recognised. EDF Energy must justify Hinkley Point C’s proposed station would be too little too late to do resilience against sea level rise – alongside other external hazards – before being granted a nuclear site anything about climate change. licence. This justification is based on extensive data on the site together with expert advice drawing on authoritative independent sources including the UK Climate Impacts Programme. The adequacy of this safety case will then be subject to periodic review, generally every ten years, as a condition of the licence. This ensures that emerging trends and accumulating knowledge will be fully taken into account over the lifetime of Hinkley Point C. The fact that this process has been under way for many years in support of the safety case for Hinkley Point B means that EDF Energy already had a substantial body of relevant data on the Hinkley Point site, even before recent work in preparation for Hinkley Point C.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 121 STAGE 1 CONSULTATION REPORT
14) Other Environmental Issues
Ground Water and Land Contamination Comments EDF Energy Response
Scope of the impact assessment The Environmental Appraisal provides detailed descriptions of the existing baseline within Volume 2 More detail should be provided on the existing baseline Chapters 13 and 14 on Contaminated Land and Groundwater and Geology respectively. Both chapters are conditions, the scope and results of the site closely linked. Chapter 13 identifies the extent, type and likelihood of contamination within soils / land in the investigations and subsequent assessment. The study area; assesses the capacity of scheme construction and operation to cause disturbance to potentially assessment of effects should consider the construction, contaminated land; and recommends management strategies, if determined necessary, to deal with potential operational and decommissioning periods. disturbance to contaminated land and the mobilisation of contaminants. The scope of the assessment should give consideration Chapter 14 provides a decription of the existing baseline conditions, and identifies and evaluates potential to the assessment of ground gas, and potential chemical risks (or change) that may arise from activities primarily concerning groundwater resources and groundwater and radiological contamination within the Hinkley Point C quality. Consideration is given to the mobilisation of existing contaminants identified in Chapter 13. Development Site and also the potential for contaminant Investigations to date on contaminated land include chemical analyses, asbestos screening and analyses, migration from the adjacent Hinkley Point A land. radiological surveys and ground gas monitoring. A desk-based study has also been undertaken to understand the potential level of contamination within the adjacent Hinkley Point A land and the potential migration effects relating to dewatering.
Terrestrial Ecology Comments EDF Energy Response
Scope of the impact assessment and consultation with Volume 2 Chapter 18 of the Environmental Appraisal examines the potential impacts on terrestrial ecology statutory consultees and features of nature conservation interest within the Hinkley Point C Development Site and the surrounding More detail should be provided on the existing baseline area, during the construction and operational periods of Hinkley Point C. Where required, mitigation conditions including detailed maps and descriptions of measures have been identified to prevent, reduce or offset potential impacts. designated sites. The initial scope of the ecological work was defined following a detailed desk study conducted in early 2007. Recommended consultation with statutory consultees on An ecological scoping report was produced which was circulated to consultees, and agreement was survey methodology. subsequently sought from organisations such as Natural England, the Somerset County Council Ecologist, RSPB and Somerset Wildlife Trust that the scope of the proposed ecological work was appropriate.
122 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 14) Other Environmental Issues
Lighting impacts Volume 2 Chapter 18 of the Environmental Appraisal assesses potential light-related impacts on sensitive The impacts of lighting on ecological receptors should be ecological receptors such as bat and bird species, including the use of the jetty. taken into account during the construction and operational periods, including use of the jetty.
In-combination effects Information is provided on in-combination effects in relation to other consented or reasonably foreseeable Potential in-combination effects on bird populations projects, such as National Grid overhead lines and Steart Managed Realignment Project in the Environmental should consider National Grid’s overhead line entry Appraisal. modifications in the vicinity of Hinkley Point, the proposed 400kV overhead line between Bridgwater and Seabank, and the Steart Managed Realignment Project.
Marine Ecology Comments EDF Energy Response
Details on survey methdology Potential impacts on marine ecology have been assessed within Volume 2 Chapter 19 of the Environmental More detail should be provided on the existing baseline Appraisal. This chapter assesses the potential impacts of the construction and operational periods of the conditions including detailed maps and descriptions of proposed Hinkley Point C development on marine ecosystems at Hinkley Point and, where appropriate, the designated sites. Detail on survey methodology should wider Bridgwater Bay and Severn Estuary environment. The chapter provides detailed baseline descriptions also be provided and include identification of potentially on the physical environment; phytoplankton; zooplankton; benthic fauna including Sabellaria; intertidal sensitive receptors (such as Sabellaria and Corallina flora and fauna including the Coralline turf habitats; fish; and marine mammals. The assessment considers habitats) and potential sources of impact (including the potential impacts on these from construction and operation of the cooling water system; the temporary cooling water and coastal protection). jetty; the sea wall; and land-based discharges.
Designated sites Potential impacts relating to designated sites are assessed, and potential impacts on the ‘integrity’ of the Potential impacts on marine ecology and on designated designated SAC, SPA and Ramsar site is provided in the Environmental Appraisal. A Habitats Regulations sites (including the Severn Estuary SPA, SAC and Ramsar Assessment Report will be provided to inform the Appropriate Assessment undertaken by the competent site, and Bridgwater Bay SSSI) should be fully assessed. authority. Studies are in hand in order to inform the Habitats Regulations Assessment and this information is presented at Stage 2.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 123 STAGE 1 CONSULTATION REPORT
14) Other Environmental Issues
Steart Realignment Management Project Potential impacts to the Steart Flats, in particular on bird species, have been assessed in the Terrestrial Consideration should be given to the Steart Realignment Ecology and Ornithology chapter of the Environmental Appraisal (Volume 2 Chapter 18). Information on any Management Project. potential in-combination effects with the proposed Steart Realignment Management Project are presented in the Environmental Appraisal on cumulative impacts.
Marine Water and Sediment Quality EDF Energy Response
Scope of the impact assessment The Environmental Appraisal provides details on the baseline conditions based on a programme of marine More detail should be provided on the existing baseline water quality sampling and vibrocore sediment investigations undertaken in 2009. The assessment on conditions, the scope and results of the marine water and marine water and sediment quality considers potential impacts relating to surface drainage discharges to the sediment investigations and subsequent assessment. foreshore; construction, operation and dismantling of the temporary jetty; construction and operation of the This should include potential effects relating to the coastal defence; vertical drilling of the cooling water intake and outfall structures; and discharge of thermal plume, temporary jetty, dredging activities and operational cooling water. the new sea wall. Where appropriate the assessment of impacts has used modelling works to define the magnitude of potential impacts, e.g. all process chemicals, have been assessed against an Environment Agency H1 type assessment methodology.
Hydrodynamics and Coastal Geomorphology Comments EDF Energy Response
Scope of the impact assessment Volume 2 Chapter 16 of the Environmental Appraisal considers the potential effects on coastal More detail should be provided on the assessment geomorphology and hydrodynamics. The chapter describes the existing hydrodynamic regime and sediment methodology and potential sources of impacts. This transport processes operating in the Severn Estuary with an emphasis on the Hinkley Point area. Both the should include potential effects relating to the thermal effects during the construction and operational periods of the proposed development are described, and, plume, temporary jetty, dredging activities and the new where appropriate, measures that have been adopted during design in order to minimise potentially adverse sea wall. change are identified and discussed. Consideration of construction and operational activities that have the potential to influence this processes include emplacement of the sea wall; construction and dismantling of the temporary jetty; drilling of horizontal tunnels for the intake / outfall structures; drilling of vertical wells for the intake / outfall structures; capital dredging of the berthing basin for the temporary jetty; presence and operation of intake and outfall structures on the seabed.
124 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 14) Other Environmental Issues
Noise and Vibration Comments EDF Energy Response
Scope of the impact assessment and further consultation The potential noise and vibration effects relating to the construction and operation of the proposed Hinkley Baseline data collection and assessment methodology Point C development are provided in Volume 2 Chapter 10 of the Environmental Appraisal. This chapter (including details on noise levels and what constitutes a assessment covers the noise and vibration effects during construction and operation of the proposed Hinkley significant noise impact) and guidance documents Point C development, including the effects of blasting during construction. The effects examined are those on should be identified. This should include details of human receptors. Potential ecological effects are reported in Volume 2 Chapters 18 and 19 on terrestrial and potential sources of noise and vibration impacts during marine ecology. the construction and operational periods. The chapters provide information on scoping consultations with Environmental Health Officers from WSC and Recommendation is made to consult with the local SDC; details on baseline noise and vibration monitoring; the prediction of noise and vibration impacts; Environmental Health Officers on the scope of the computational modelling of noise propagation; and assessment criteria developed in accordance with assessment. relevant guidance. The potential effects assessed include on-site construction operations including the movement and operation of a wide range of mobile or stationary construction plant equipment, and specifically with regard to ground compaction, piling activities or blasting; off-site construction-traffic effects that may influence noise and vibration sensitive premises; on-site operational noise; and off-site transport-related movements.
Designations Comments EDF Energy Response
Further details on assessment and potential impacts on There are a number of designated sites in proximity to the proposed Hinkley Point C development. These have designated sites been clearly identified within Volume 2 Chapter 1 of the Environmental Appraisal which decribes the existing Designated sites should be clearly identified and site and surrounding area, and assessed within the relevant assessment chapter. Information on potential in- described. Potential impacts of the proposed Hinkley combination effects with other consented or reasonabily foreseeable plans or projects is provided in the Point C development on these designated sites should be Environmental Appraisal. assessed. This should include in-combination effects Potential effects relating to the European designated SPA, SAC and Ramsar site are provided in Volume 2 with other plans or projects which have the potential to Chapters 18 and 19 on terrestrial and marine ecology in the Environmental Appraisal. In addition to this, EDF have a cumulative impact. Energy is consulting with the key regulatory bodies on the scope of work required to inform the expected Where there are potential effects relating to European Appropriate Assessment to be undertaken by the competent authority to determine whether the proposed designated sites, these should be identified and Hinkley Point C development has an impact on the integrity of the designated site. Studies are in hand in sufficient information should be provided to the order to inform the Habitats Regulations Assessment and this information is presented at Stage 2 within the competent authority to undertake an Appropriate Environmental Appraisal. Assessment.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 125 STAGE 1 CONSULTATION REPORT
14) Other Environmental Issues
Air Quality Comments EDF Energy Response
Scope of the impact assessment and impacts on The potential air quality effects relating to the construction and operation of the proposed Hinkley Point C designated sites and ecological receptors development are provided in Volume 2 Chapter 11 of the Environmental Appraisal. This chapter assessment Air Quality baseline data collection and assessment covers the effects of emissions upon local air quality. Impacts of potential changes in air quality upon both methdology should be clearly described and guidance human and ecological receptors are dealt with in the Health Impact Appraisal and Volume 2 Chapter 11 of the documents should be identified. This should include Environmental Appraisal on terrestrial ecology. details of potential sources of air pollution during the Potential sources of air pollution are identified within the chapter and include on-site construction activities, construction and operational periods. including plant exhaust emissions and the generation and dispersion of construction dust; vehicle exhaust Further information is sought on anticipated affects and emissions; on-site power station operational emissions from both routine, test and emergency scenarios; and any management of impacts to sensitive designated emissions from off-site transport-related movements. sites/ecological sites in the vicinity of the proposed Chapter 11 is supported by an appended Air Quality Monitoring Report, which provides further detail on the scheme. baseline air quality monitoring surveys and an Air Quality Modelling Report, which provides full details on the dispersion modelling undertaken to predict potential construction and operational air quality impacts.
Consultation Volume 2 Chapter 18 of the Environmental Appraisal provides information on scoping consultations with Recommendation is made to consult with the local Environmental Health Officers from WSC and SDC, baseline data collection and assessment methodology. Environmental Health Officers on the scope of the assessment.
Air Quality Comments EDF Energy Response
Scope of the impact assessment and impacts on The potential air quality effects relating to the construction and operation of the proposed Hinkley Point C designated sites and ecological receptors development are provided in Volume 2 Chapter 11 of the Environmental Appraisal. This chapter assessment Air Quality baseline data collection and assessment covers the effects of emissions upon local air quality. Impacts of potential changes in air quality upon both methdology should be clearly described and guidance human and ecological receptors are dealt with in the Health Impact Appraisal and Volume 2 Chapter 11 of the documents should be identified. This should include Environmental Appraisal on terrestrial ecology. details of potential sources of air pollution during the Potential sources of air pollution are identified within the chapter and include on-site construction activities,
126 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 14) Other Environmental Issues construction and operational periods. including plant exhaust emissions and the generation and dispersion of construction dust; vehicle exhaust Further information is sought on anticipated affects and emissions; on-site power station operational emissions from both routine, test and emergency scenarios; and any management of impacts to sensitive designated emissions from off-site transport-related movements. sites/ecological sites in the vicinity of the proposed Chapter 11 is supported by an appended Air Quality Monitoring Report, which provides further detail on the scheme. baseline air quality monitoring surveys and an Air Quality Modelling Report, which provides full details on the dispersion modelling undertaken to predict potential construction and operational air quality impacts.
Consultation Volume 2 Chapter 18 of the Environmental Appraisal provides information on scoping consultations with Recommendation is made to consult with the local Environmental Health Officers from WSC and SDC, baseline data collection and assessment methodology. Environmental Health Officers on the scope of the assessment.
Radiological Comments EDF Energy Response
Relevance and conclusions of Radioactivity in Food and RIFE reports are produced annually on behalf of the Food Standards Agency and the Environment Agency. the Environment (RIFE) reports They combine the results of the monitoring programmes undertaken by these bodies independent of the Consultee proposed that RIFE should be included as a operators of nuclear sites, and they focus on key information showing that food is safe and the public’s technical annex. exposure to ionising radiation around the UK’s nuclear sites is within legal limits. These sites include Hinkley Point. The reports are publicly available. The most recent RIFE report (RIFE 2008) concluded that: the public’s exposure to radiation around each nuclear site in 2008 was below the legal limit; and concentrations of radionuclides in food and the environment around nuclear licensed sites were similar to previous years. The specific data referred to at Stage 1 consultation are in Tables 4.7(a) and (b) of RIFE 2008. As part of Stage 2, the RIFE reports are referenced from the Health Impact Appraisal and the Radiological section of the Environmental Appraisal (Volume 2 Chapter 20). RIFE reports are available from the websites of the participating organisations e.g. http://www.food.gov.uk/science/surveillance/radiosurv/rife/rife08/.
Radiological dose assessment in GDA Potential radiological doses to human and non-human species from the UK EPR design are estimated in Consultees sought information from the GDA on potential Chapter 11: Radiological Impact Assessment of the Pre-Construction Environmental Report (Chapter 11), doses to human and non-human species, and which is publicly available. The methodology used is that provided by the Environment Agency, and the
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 127 STAGE 1 CONSULTATION REPORT
14) Other Environmental Issues recommended that sensitive habitats considered in non- values obtained are compliant with the dose limits for members of the public as well as within the human dose modelling should be illustrated. Government’s dose constraint for a single source. The report also concludes that the impact of the radioactive discharges on non-human species can be regarded as negligible.
Methodology of EDF Energy’s radiological dose EDF Energy’s Marine Monitoring Campaign, carried out to identify background levels of radioactivity in the assessment Bristol Channel in the vicinity of the Hinkley Point C site, analysed gross alpha, gross beta, tritium and Consultees sought further information on the carbon-14, and used high-resolution gamma spectrometry to determine levels of a number of anthropogenic methodology used. This included confirmation that and naturally occurring radionuclides. This also applied to the Groundwater Monitoring Campaign carried out samples have been analysed for gross alpha, gross beta, using boreholes, the Soil Monitoring Campaign on the Built Development Areas and the monitoring of surface tritium and carbon-14 and using gamma spectroscopy / freshwater features. spectrometry. Also that critical group doses were In each case, these baseline studies were carried out in the presence of any impact from the existing Hinkley assessed to be below 20 microSievert, i.e. negligible. Point Power Station Complex. The groundwater, soil and freshwater studies involved sampling from the HPC Also sought clarification of: Development Site. whether baseline information has been assessed The Radiological Assessment concludes that doses to the most exposed persons from all Hinkley Point from the existing stations at Hinkley Point; discharges, assuming Hinkley Point A, Hinkley Point B and HPC all discharge at their maximum authorised / permitted rates, are below 20 μSv y-1 i.e. negligible. whether on-site samples were used, and comment made on their distribution; and “So-called detection limit” refers to the limit of detection of the relevant radiological parameter when using the analytical equipment actually employed. Where data has been combined from more than one source, the meaning of “so-called detection limit” in 3.6.9 each with its own limit of detection, it may be appropriate to quote a range rather than a single value. of the Stage 1 Consultation Document. Further information on radiological assessment can be found in the Radiological chapter of the Environmental Appraisal.
Completeness of sampling data presented Information is provided on sampling data in the Radiological chapter of the Environmental Appraisal. Consultees sought full detail from completed studies to be included, not just referenced.
Explanation of radioactivity in drinking water standard Drinking water standards on radioactivity are based on its tritium content and on its Total Indicative Dose Consultee sought better explanation than is provided at (TID) – the effective dose of radiation the body may receive from drinking the water. The calculation of TID Stage 1 consultation. excludes tritium (the dose from which is calculated separately), potassium-40 and radon and radon decay products.
128 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 14) Other Environmental Issues The relevant guidelines require that drinking water is normally analysed for gross alpha, gross beta and tritium. If each of these is below the relevant action levels then no further action is necessary. If any of the action levels is exceeded, then more detailed analysis is required to determine what isotope or isotopes are responsible and hence to calculate the TID. Above the guide value remedial action must be considered.
Regulatory Justification Regulatory Justification is a process required under the Justification of Practices Involving Ionising Radiation Consultee unable to comment until practice is ‘Justified’. Regulations 2004, where the Secretary of State for Energy and Climate Change, as Justifying Authority, must decide whether a new class or type of practice resulting in exposure to ionising radiation is justified by its economic, social or other benefits in relation to the health detriment it may cause. The Secretary of State has published and consulted on his proposed decision that the practice of the generation of electricity from nuclear energy from the UK EPR design is Justified. He has not yet published the outcome of this consultation. Justification is the first part of the framework for radiological protection recommended by the International Commission on Radiological Protection. Subsequent parts are Optimisation (ensuring that radiological doses are as low as reasonably practicable) and Limitation (ensuring that doses do not exceed statutory limits). These are implemented through the UK’s safety and environmental regulatory regime.
Potential health impact At the request of the Somerset Coast Primary Care Trust, the South West Cancer Intelligence Service (SWCIS) Consultees concerned at excess breast cancer mortality, and the South West Public Health Observatory examined cancer incidence in the wards around Burnham three-fold increase in infant deaths downwind (Green which had been highlighted by Green Audit study. SWCIS has found no signficant evidence of increased risk Audit) and doubling of childhood leukaemia (KiKK). of cancer linked to radiation in these wards. These results were presented to the Committee on Medical Aspects of Radiation in the Environment (COMARE). COMARE agreed that the study showed no evidence of a link between exposure to radiation from the Hinkley Point nuclear power stations and increased incidence of cancer in the Burnham area. COMARE also commented on serious flaws in the Green Audit study that prevent it providing reliable information. Following publication of the KiKK study in Germany, COMARE has requested a reanalysis of its much larger, verified UK national database of childhood cancer using, as far as possible, the same methodology as KiKK. This did not support the KiKK findings on a link between childhood leukaemia and proximity to a nuclear power station.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 129 STAGE 1 CONSULTATION REPORT
14) Other Environmental Issues
Cumulative and In-combination Effects Comments EDF Energy Response
In-combination and cumulative effects should be The complexity of the Hinkley Point C Project requires that this cumulative assessment component of the EIA considered is undertaken at a number of levels in order to ensure that impacts are fully assessed across all components The Environmental Impact Assessment (EIA) should of the project and for the project as a whole. The Environmental Appraisal provides information on the address the impact of the scheming combination with potential cumulative effects that could occur, both within the project itself (i.e. the cumulative effect of all of other projects in the vicinity. the project components) and in-combination with other projects and plans.
Sustainability Comments EDF Energy Response
Sustainability While nuclear power stations do consume uranium, the quantity required is modest: a modern reactor such Consultees were concerned that nuclear fuel is finite and as the UK EPR requires only a few tens of tonnes of fuel per year. Refuelling is only required at intervals of 12- non-renewable. Also that loss of generating potential 24 months and the fuel could readily be stockpiled if required. between reactor and turbine output, the consideration of About half the known reserves of uranium are in democratic OECD countries such as Canada and Australia. creative ways of using the waste heat and to minimise the The most authoritative assessment of uranium resources, published every two years by the OECD and IAEA, carbon footprint. concludes that currently identified resources are sufficient to meet growing world demand for a century ahead. In addition, recent rises in uranium prices have stimulated renewed investment in exploration, which can be expected to increase this resource base. In theory it would be technically feasible to divert part of the heat that is normally rejected to the sea and use it for other purposes. However, heat is normally rejected at around ten degrees above sea temperature. This is too low for most practical uses. To supply heat at a useful, higher temperature means reducing the thermal efficiency of HPC, i.e. how effectively it converts nuclear heat into electricity. Taking this penalty into account, EDF Energy has considered potential ways of using waste heat, but to date has not identified a technically and commercially viable opportunity.
130 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 15) Other Hinkley Point C Development Site Comments EDF Energy Response
On-site medical facility provision Hinkley Point C would incorporate a medical centre suitable for normal power station operations including the provision of first aid and medical decontamination. During construction facilities would be provided which Clarification sought on its use, functioning and services reflect the larger numbers of personnel on-site. available. In both cases, the medical facilities would provide first aid and non-emergency facilities similar to those provided in a community doctors’ surgery. Any cases requiring more comprehensive facilities would be transferred to local hospitals as necessary.
Risk of sabotage during construction The construction activities would be undertaken in compliance with a construction security plan as required by the security regulator – the Office of Civil Nuclear Security (OCNS). This plan would set out appropriate arrangements for dealing with relevant security risks during construction and would be superseded by the operational security plan as the power station approaches operational status.
16) Overall Associated Development Strategy Comments EDF Energy Response
Justification of the transport and accommodation EDF Energy’s transport and accommodation strategies have been developed in line with the project objectives strategies which broadly seek to manage the construction of the Hinkley Point C Project in a way that maximises efficiency and minimises disruption to the local community, make a positive contribution to the locality, and Respondents sought justification of the rationale for the minimises as far as reasonably practicable any negative environmental impacts. site locations and options of the proposed off-site associated developments. The proposals could have a For further information on EDF Energy’s transport and accommodation strategies and the rationale for their negative impact on Cannington and the surrounding evolution, see the Preferred Proposals: Explanation and Assessment document. villages.
Sustainable transport and accommodation strategies A Transport Appraisal has been developed that sets out the proposed transport infrastructure to manage the travel demand generated by the construction and operation of Hinkley Point C. The implementation of strategies which promote sustainable development was supported. EDF Energy has developed an accommodation strategy which seeks to provide facilities in strategic locations to accommodate non-home-based workers. For further details see the Transport Appraisal and Proposed Travel Plan.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 131 STAGE 1 CONSULTATION REPORT
16) Overall Associated Development Strategy Comments EDF Energy Response
Focus development in/around Bridgwater As a result of the comments received on the Stage 1 consultation, significant changes have been made to the transport and accommodation strategies in terms of the siting and sizing of the proposed development. EDF Siting of workers’ accommodation in and around Energy is no longer proposing to locate accommodation campuses in Cannington or Williton. Instead, Bridgwater was felt preferable on the basis that there is campuses will be provided on the Hinkley Point C construction site and in two locations in Bridgwater to capacity to support these facilities. accommodate between 1,080 and 1,925 workers, depending on the success of local recruitment and other factors.
For further details on the strategies, see the Preferred Proposals: Explanation and Assessment document.
Impacts to the wider area A full Environmental Impact Assessment has been undertaken to assess the impacts, both positive and negative, of all relevant issues. Respondents identified a number of issues that should be taken into account, including: increased traffic, Details of the full assessment can be found in the Environmental Appraisal. increased population and social problems, as well as impacts to the historic environment, tourism, housing, transport, medical facilities and quality of life.
Cumulative impacts As part of the Environmental Appraisal an assessment of all other development initiatives in the areas around the sites proposed for development has been conducted. This has taken into account the Building Schools It was stated that both the travel and accommodation for the Future programme and construction of the North East Bridgwater development. For further details, refer strategies should take into account other development to Volume 3 of the Environmental Appraisal. initiatives and form part of the Environmental Impact Assessment. The Transport Appraisal also considers the growth in traffic as a result of other committed developments in the areas around the sites proposed for development.
Legacy strategy EDF Energy has taken into account the responses to the Stage 1 consultation when identifying a preferred legacy strategy for each site. EDF Energy proposes to submit legacy plans to the relevant authority for Clarification of potential legacy uses was requested. It approval at the appropriate time, as set out in the Proposed Planning Requirements and Obligations was acknowledged that leaving a positive legacy benefit document. Legacy uses identified by EDF Energy (or another party) in the future would require separate is important to the local community. Suggestions for permission to be sought from the relevant authority. legacy use included affordable housing and improved transport infrastructure. For full details of the preferred legacy strategy for each site see the Preferred Proposals: Explanation and
132 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 16) Overall Associated Development Strategy Comments EDF Energy Response Assessment document.
Consenting process Section 115 of the Planning Act 2008 gives the IPC the power to grant consent for certain development that is Respondents requested further clarification of the associated with a Nationally Significant Infrastructure Project (NSIP). Guidance on associated development consent process for the Off-Site Associated confirms that associated development can be considered as measures to mitigate the impacts of the primary development. Associated Development should be necessary for the development and effective operation to Developments, i.e. whether these developments would be determined by the Infrastructure Planning Commission its design capacity of the NSIP that is the subject of the application. (IPC). All of the associated development proposals will form part of the single application and will be considered by the IPC.
Flood risk Flood Risk studies have been prepared in support of each of the proposed off-site associated developments. Respondents stated that the proposed developments The scope of each of the studies has been discussed with the Environment Agency and these form part of the should seek to reduce the local flood risk. Stage 2 consultation. For further information on flooding, refer to the site-specific Flood Risk Studies.
Ecology Desk-based ecological surveys have been completed at all the off-site associated development sites and an It was stated that an assessment of ecological impacts assessment of the impacts undertaken. and, where necessary, the identification of appropriate These surveys have identified the need for further, more detailed ecological survey work, based on the likely mitigation, should be provided for all proposed off-site potential impacts of the proposed developments. This includes surveys for breeding birds, bats, reptiles, associated developments. water vole, otter and great crested newt. The scope of the surveys for each site has been discussed and agreed with Somerset County Council’s ecologists and Natural England. Once collected, the baseline ecological information will be used to assess the potential effects of each proposed off-site associated development on biodiversity. Mitigation has been designed into the proposed developments to minimise potentially significant affects on biodiversity. For further information on ecological issues of the off-site associated developments, see Volume 3 of the Environmental Appraisal.
Police resources and law and order EDF Energy is engaged in an ongoing dialogue with the authorities concerning potential additional policing and infrastructure needs as a result of the proposed development, both in respect of the Hinkley Point C It was questioned whether EDF Energy has given any thought to the scope of additional police resources that development and the proposed off-site associated developments, particularly the accommodation campuses. will be required. Opportunities to make contributions to the existing policing infrastructure through planning obligations are detailed in the Proposed Planning Requirements and Obligations document.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 133 STAGE 1 CONSULTATION REPORT
17) Overall Accommodation Strategy Comments EDF Energy Response
Social and community infrastructure An appraisal of the socio-economic impacts of the project is included in Volumes 2 and 3 of the Environmental Appraisal. It was requested that a full assessment of social and community infrastructure requirements be undertaken. Facilities identified included: libraries; community centres and cultural facilities; social services; education facilities (of all level); emergency services; health; sports facilities, recreation and open space. It was stated that further information should be presented following consultation with infrastructure providers.
Population increase A detailed socio-economic impact assessment has been undertaken to consider the impacts of the population increase as a result of the project. This identifies a number of scenarios in terms of the potential proportions It was stated that consideration should be given to the of home-based and non-home-based workforce anticipated throughout the duration of the construction and impact of the population increase; identification of how operational phases. this will be managed; and clarification on any contingency plans for higher than expected growth. EDF Energy has responded to this anticipated increase by ensuring there is sufficient capacity within the accommodation campuses to meet the anticipated level of demand by the non-home-based workforce. This will be closely monitored and facilities will be provided to meet demand. For further information see Volume 2 of the Environmental Appraisal.
Loss of community identity EDF Energy understands the importance of community identity, especially in local villages. This, in part, has led to changes being made to the siting of the campuses and associated facilities. It was suggested that an influx of non-home-based workers could potentially result in a loss of community Proposals for accommodation campuses at Cannington and Williton no longer form part of EDF Energy’s identity, particularly in smaller settlements. It was stated accommodation strategy. that the non-home-based construction worker For further information on the accommodation strategy, see the Preferred Proposals: Explanation and population must be positively integrated into existing Assessment document. communities and that dispersing the campuses would go
134 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 17) Overall Accommodation Strategy Comments EDF Energy Response some way to achieving this.
Police resources and law and order EDF Energy is engaged in an ongoing dialogue with the authorities concerning potential additional Concerns were raised over potential issues arising from infrastructure needs, including policing, as a result of the project, both in respect of the Hinkley Point C an influx of mainly male workers. development and the proposed off-site associated developments, particularly the accommodation campuses. Proposed contributions to the existing infrastructure planning obligations are detailed in the Proposed Planning Requirements and Obligations.
Housing availability EDF Energy’s accommodation strategy meets the requirements identified in the socio-economic chapter of the It was stated that there is a need to demonstrate that the Environmental Appraisal. impact on housing can be managed in both the long- and Analysis suggests that the construction campuses on site and in Bridgwater may need to accommodate short-term, so as not to impact on the availability and between 1,080 and 1,925 workers, depending on the success of local recruitment and other factors. cost of housing on the existing community. EDF Energy will monitor closely the availability and take up of accommodation by workers from all potential sources (i.e. from the rental sector, bed and breakfast, caravan, owner occupation and new build accommodation) and may adjust the phased build out of its construction campuses accordingly. For further details of the accommodation strategy, see the Preferred Proposals: Explanation and Assessment document.
Impact on tourism EDF Energy recognises that the tourism industry is important to both Sedgemoor and West Somerset, and has Respondents requested that consideration be given to developed an accommodation strategy that is designed to minimise any adverse impact on the tourism the potential impact of the influx of construction workers industry in the short- and long-term. on the tourism industry. It was stated that workers using EDF Energy has assessed the capacity of existing tourist accommodation in the area to ascertain vacancy local bed and breakfast accommodation could restrict levels during both peak and off-peak seasons. Whilst some non-home-based workers will choose to use availability to tourists in the summer months, thereby existing tourist accommodation, EDF Energy will be providing temporary accommodation campuses for having a negative impact on the industry. between 1,080 and 1,925 workers to ensure that sufficient levels of alternative accommodation are available in order to minimise any adverse impacts. EDF Energy will monitor closely the availability and take up of accommodation by workers from all potential sources and may adjust the phased build out of its construction campuses accordingly. For further information on the proposed accommodation campuses, refer to the Preferred Proposals:
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 135 STAGE 1 CONSULTATION REPORT
17) Overall Accommodation Strategy Comments EDF Energy Response Explanation and Assessment document.
Visual impacts The proposed park and ride and freight logistics facilities, plus the refurbished Combwich Wharf, will not contain buildings which will have a significant impact on the long-distance landscape. Consideration of the visual impacts of the proposed developments, including night views, was sought, not The accommodation campuses in Bridgwater, being of up to three storeys, will be located within the urban just in the immediate vicinity of the developments, but area; therefore the visual impacts are considered to be limited and only over short distance. further afield, e.g. from the Quantock Hills. The main landscape and visual impacts associated with the proposed Cannington bypass have been assessed, and a suitable landscape strategy has been designed. The bypass would be a permanent feature, therefore permanent landscape treatments would be provided, which would mitigate the visual impact of the bypass in the long-term. The study areas for visual impact also extend to Quantock Hills AONB and Exmoor National Park, where relevant, and take into account impact of lighting. For further information on the visual impact assessments of the proposed off-site associated developments, see Volume 3 of the Environmental Appraisal.
Legacy benefits EDF Energy has taken into account the responses to the Stage 1 consultation when identifying a preferred legacy strategy for each site. EDF Energy proposes to submit legacy plans to the relevant authority for Further information was sought on the options for legacy approval at the appropriate time, as set out in the Proposed Planning Requirements and Obligations use of some of the proposed off-site associated document. Legacy uses identified by EDF Energy (or another party) in the future would require separate developments. Suggested legacy uses included: permission to be sought from the relevant authority. affordable housing, student accommodation and sheltered accommodation. For details of the preferred legacy strategy proposed for each site, see the Preferred Proposals: Explanation and Assessment document.
Traffic management A mitigation strategy is being developed to cater for the residual transport impacts of construction and operation of the Hinkley Point C development. The implementation of traffic management schemes was suggested to mitigate the existing pressure on local Further details can be found in the Transport Appraisal. roads, whilst improving the safety of the roads.
136 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 17) Overall Accommodation Strategy Comments EDF Energy Response
Sustainable travel planning A Transport Appraisal has been developed that sets out the proposed transport infrastructure to manage the travel demand generated by the construction and operation of the Hinkley Point C development. The use of non-car based transport to the Hinkley Point C site was supported. In addition, a Proposed Travel Plan has been prepared which considers the management of the movement of people involved in the construction and operation of the Hinkley Point C development. The Proposed Travel Plan provides a package of sustainable transport measures aimed at improving the availability and choice of travel modes. Further details can be found in the Transport Appraisal and Proposed Travel Plan.
Alternative locations for development EDF Energy has reviewed the alternative options proposed by various respondents in and around the local area. The locations were assessed and have been discounted as they were considered less preferable than A number of alternative locations for the siting the Off- the identified sites to meet EDF Energy requirements. Site Associated Development were suggested, including: Taunton Deane, Nether Stowey, Burnham-on-Sea and Further details of the alternatives considered for the siting of the proposed off-site associated developments Highbridge, Minehead and the possibility of off-shore are in Volume 3 of the Environmental Appraisal. accommodation. It was also suggested that only existing industrial areas and brownfield sites be used for development.
Design standards EDF Energy is targeting a BREEAM ‘Good’ rating for all accommodation campuses, with the exception of the Bridgwater C accommodation campus where ‘Excellent’ will be targeted. BREEAM considers wide-ranging Respondents stated that any temporary developments environmental and sustainability issues and enables developers and designers to prove the environmental should achieve the same design standards as any credentials of their buildings. Details of how the proposed developments will achieve this rating will be permanent development. detailed as part of the application for Development Consent. It was stated that careful consideration should be given The masterplans have been developed to ensure a high quality layout, maximising opportunities to provide to the layout in order to best serve the community. developments with the flexibility and quality for potential future use. For further information, refer to the Masterplan documents.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 137 STAGE 1 CONSULTATION REPORT
17) Overall Accommodation Strategy Comments EDF Energy Response
Consents process for workers’ accommodation The Planning Act 2008 provides for a new streamlined procedure for Nationally Significant Infrastructure campuses Projects (NSIPs) by, where possible, creating a single application process for all of the development authorisations needed for the NSIP. The applicant can therefore apply for the associated development, Clarification was sought on how consent would be including accommodation campuses, as part of the DCO application. achieved for the campus developments. Therefore, the IPC would determine the application for Development Consent for the Hinkley Point C development, including all of the accommodation campuses and other associated development required to implement the NSIP. For further details, refer to the Preferred Proposals: Explanation and Assessment document.
Off-shore Accommodation EDF Energy’s initial investigations into this option showed that the Bridgwater Bay is not suitable to accommodate workers off-shore, and such proposals could have adverse on marine ecology and cultural Respondents commented that workers could be heritage in the Bay. accommodated on a ‘floating hotel’.
18) Overall Transport Strategy Comments EDF Energy Response
Site justification – freight logistics and park and ride The locations identified for the siting of the park and ride facilities were selected as they were considered to facilities be strategically located to maximise opportunities to intercept cars at key points and provide a direct onward bus services to the Hinkley Point C site. Concerns were raised over the evidence provided to justify why those sites identified had been chosen in The location of the freight logistics facilities at Junctions 23 and 24 of the M5 and on land adjacent to transport terms, or how the proposed developments Combwich Wharf were chosen to enable the flow of freight vehicles to be controlled between the strategic road could impact the strategic road network. network and the Hinkley Point C site. Further details of the analysis undertaken to select the proposed park and ride locations is provided in the Preferred Proposals: Explanation and Assessment document.
Scale of development at Cannington and Williton As a result of the comments received from the Stage 1 consultation, significant changes have been made to the proposals at both Cannington and Williton. Developments are now, where possible, focused within The scale of development at Cannington and Williton
138 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 18) Overall Transport Strategy Comments EDF Energy Response was questioned, on the basis that temporary existing settlements, unless there are specific operational requirements which preclude this. Consequently, development on green field sites is to be avoided. park and ride facilities at Cannington and Williton of 360 and 310 spaces respectively are proposed. This is in addition to a bypass proposed around Cannington. For further details of the scale of development and rationale for siting in each location, refer to the Preferred Proposals: Explanation and Assessment document.
Siting of development – freight logistics facilities EDF Energy is proposing to locate freight logistics facilities at Junction 23 and Junction 24 of the M5 in order to intercept deliveries and control their journeys to the Hinkley Point C site. Respondents supported locating freight logistics facilities at the point closest to the source, i.e. adjacent The storage facility at the Wharf will also comprise an element of freight logistics to enable the flow of freight to the motorway. vehicles to be controlled between the strategic road network and Hinkley Point.
For further details, please refer to the Preferred Proposals: Explanation and Assessment document.
Sustainable travel plan A Travel Plan has been prepared and includes details of how it will be implemented, who will manage it and how the Travel Plan will be monitored. Targets will be set and agreed with the highway authorities against The principle of encouraging non-car based methods of which the Travel Plan will be monitored. transport was supported. However, further clarification was sought as to how these measures would be For full details, see the Proposed Travel Plan. implemented.
Legacy benefits of the park and ride facilities EDF Energy has taken into account the responses to the Stage 1 consultation when identifying a preferred legacy strategy for each site. EDF Energy proposes to submit legacy plans to the relevant authority for Further investigation was sought into the long-term approval at the appropriate time, as set out in the Proposed Planning Requirements and Obligations viability of the park and ride facilities as a legacy benefit. document. Legacy uses identified by EDF Energy (or another party) in the future would require separate Respondents enquired as to whether the proposals will permission to be sought from the relevant authority. also provide public transport opportunities to the wider For full details of the preferred legacy strategy for each site refer to the Preferred Proposals: Explanation and community. It was suggested that this could be a Assessment document. positive legacy benefit after construction for the local residents and future EDF Energy staff.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 139 STAGE 1 CONSULTATION REPORT
18) Overall Transport Strategy Comments EDF Energy Response
Benefits of freight logistics facilities The purpose of the freight logistics facilities at Junctions 23 and 24 of the M5 is to manage deliveries travelling It was suggested that the freight logistics facilities would to the Hinkley Point C site. not mitigate against negative impacts. For further details, refer to the Transport Appraisal document.
Impacts to the strategic road network A Transport Appraisal has been developed that sets out the proposed transport infrastructure to manage the travel demand generated by the construction and operation of the Hinkley Point C development. It provides Respondents questioned how the proposed an assessment of the impacts of the Hinkley Point C project and identifies any measures to mitigate the developments would affect the strategic road network. impacts.
Traffic management The focus of the Transport Appraisal has been to firstly minimise the amount of road traffic generated by the Hinkley Point C development, and secondly to use more sustainable modes of travel. Clarification was sought as to how the increase in vehicle movements would be managed. In terms of minimising road traffic, a temporary jetty is proposed at Hinkley Point to enable vessels to deliver much of the aggregates to the site by sea. In addition, Combwich Wharf will be refurbished and used for the delivery of abnormal indivisible loads and other materials to the site. The residual deliveries will arrive by road and will be managed via the freight logistics facilities to minimise the impact on the local highway network, particularly at peak periods. With regard to the movement of workers to and from the site, the Transport Appraisal focuses on providing park and ride facilities and long-distance coach services to bring people to the site by bus. This will reduce the number of single or low occupancy trips to the Hinkley Point C site. For further details, refer to the Transport Appraisal.
Inadequate road system and over reliance on the A39 A strategy is being developed, working with relevant authorities, to ensure that any impacts of the It was stated that existing roads would need significant construction and operation phases of the project are minimised or mitigated. For example, junction further investment to accommodate the increased improvements would be implemented where there are operational problems caused by the development. number of vehicles, during both the construction and Further information is provided in the Transport Appraisal. operational phases of the development. Suggested improvements included: improvements to junctions, realignment of priority junctions, widening of areas to make them suitable for heavy traffic, and the straightening and widening of Stogursey Lane. It was stated that the M5 is the only proper trunk road for the South West and heavy congestion, as a result of this
140 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 18) Overall Transport Strategy Comments EDF Energy Response traffic, affects local towns.
Site access strategy Opportunities to facilitate those using the park and ride facilities by foot or bicycle have been explored. Further details were requested on the accessibility of the For further information, refer to the Masterplan: Park and Ride Facilities and the Transport Appraisal. park and ride facilities by a range of transport modes, including alternatives to private cars.
Bridgwater bypass In Bridgwater there is an extensive road network including a number of major roads, and traffic would be dispersed across the network. The main Hinkley Point C traffic attracted to the Bridgwater bypass would be Respondents sought the justification for discounting a coming from the M5 and would comprise freight vehicles and buses because private vehicles would be Bridgwater bypass. intercepted at the proposed park and ride facilities near the motorway. A Bridgwater northern bypass would be within the floodplain and located in an area of high environmental sensitivity. It would take approximately four years to build and it would either substantially delay the operation of the power station, (and therefore jeopardise the aim of bringing new nuclear power stations on line in time to meet anticipated electricity shortages), or it would not be ready in time for the peak construction phase. In itself it would generate significant lorry movements during its construction. Taking these factors into account, EDF Energy has concluded that it would not be appropriate to provide a northern Bridgwater bypass.
Car parking strategy The focus of the Transport Appraisal has been to firstly minimise the road traffic generated by the Hinkley Point C (HPC) development, and secondly to utilise more sustainable modes of travel. Further justification was sought regarding the demand for park and ride facilities. To this end, car parking space at HPC has been limited. Instead, the Transport Appraisal focuses on providing off-site park and ride facilities, bus services and long-distance coach services to bring people to the site by Clarification was needed as to how the off-site park and bus. Parking restraints at the destination (i.e. HPC site) will act to enforce the Transport Appraisal and workers ride strategy would integrate with the amount of car will have to use the bus service that is allocated to them. parking on-site, how on-site parking would be managed and how the use of facilities by constructions workers would be achieved. It was suggested that stringent parking measures should be implemented in and around Hinkley Point to avoid people ignoring the rule.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 141 STAGE 1 CONSULTATION REPORT
18) Overall Transport Strategy Comments EDF Energy Response
Rail services A Rail Study has been undertaken in consultation with First Great Western in order to explore the opportunities for the workforce to use rail to travel to and from work. Improved rail links between Minehead, Taunton, and Williton with Bridgwater were suggested as positive A summary of the Rail Study is provided in the Transport Appraisal. additions to the Travel Plan.
Cumulative impact The Transport Appraisal considers the growth in traffic associated with the Hinkley Point C development, having regard to any anticipated changes to the road network as a result of other committed developments. Respondents requested that a cumulative impact assessment be carried out to identify any other proposed developments in the area and their potential impact on the area.
Impact on tourism The focus of the Transport Appraisal has been to minimise the road traffic generated by the Hinkley Point C development and to use more sustainable modes of travel, thereby minimising the impact to the strategic Respondents felt that tourism may be affected due to road network. increased traffic on the roads. In addition to the Transport Appraisal, EDF Energy is working with the relevant authorities to identify improvement works, such as junction improvements, which are required to be implemented where there are operational constraints as a result of the development. Further information can be found in the Transport Appraisal.
Impacts to local residents Assessments of impacts on noise, air quality and safety associated with the increased traffic from the Hinkley Point C project, including the proposed off-site associated development particularly during construction Increased noise, exhaust pollution and safety issues phase, have been undertaken. were mentioned by respondents as key concerns. Details of the likely impacts and required mitigation are provided in the Environmental Appraisal.
Pedestrian and cycle links The pedestrian and cycle connections between the proposed accommodation campuses in Bridgwater and the local amenities are currently being audited and improvements will be implemented where required. Respondents stated that improvements to existing cycle and footpaths across Bridgwater should be considered For further details, refer to the Transport Appraisal. to ensure continued safe access for the local community,
142 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 18) Overall Transport Strategy Comments EDF Energy Response particularly school children.
Journeys outside peak hours The park and ride bus services will be aligned with the shift patterns. As such, the buses will operate both during the peak hours and during the off peak hours. Traffic modelling has assessed the effects of the project Respondents requested clarification how trips outside throughout the day. peak hours would be assessed. Further information can be found in the Transport Appraisal. Clarification was also required on how construction workers would be transported outside of peak hours between the Hinkley Point C site and their park and ride facility or accommodation.
Seasonal variations Seasonal variations have been explored. August experiences more traffic than any other month in the year along the M5 between Junctions 23 and 24. However this is spread through the day and has minimal effect in Details were sought on the impacts of seasonal variation the AM peak and only a moderate effect in the PM peak period. and off-peak travel requirements. It should also be considered that the bulk of the workers’ movement would be on the motorway at times when, even in August, the flows are lower than peak values. Further consultation is required with the highway authorities on this to reach agreement on how it is considered in the final Transport Assessment, which will be submitted as part of the application for Development Consent.
Ecological impacts and mitigation Ecological impacts have informed the site selection process. Further ecological information will be gathered via a range of surveys programmed for 2010 (and tailored to reflect the likely potential impacts). Biodiversity More detailed information on the ecological impacts and mitigation will form a key part of the assessment and full details will be provided in the application for subsequent mitigation strategy was requested for each Development Consent. of the proposed off-site associated developments.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 143 STAGE 1 CONSULTATION REPORT
19) Cannington Comments EDF Energy Response
Scale of development at Cannington Having considered the comments from the Stage 1 consultation, EDF Energy is no longer proposing to locate accommodation campuses or a freight logistics facility in Cannington. The scale of development in Cannington was questioned and further justification requested. In refining the accommodation and transport strategies, EDF Energy has identified a need for a park and ride facility in Cannington. Consideration has been given to the size of this facility and it has been concluded that up to 360 spaces are required. For further details on the park and ride facility in Cannington, refer to the Preferred Proposals: Explanation and Assessment and Masterplan: Park and Ride Facilities documents.
Justification for the freight logistics facility in Cannington The freight logistics facility identified at Cannington was proposed to capture small scale freight from local suppliers from the west of Bridgwater and surrounding areas before travelling through the village of The reasoning behind the requirement for a freight Cannington. EDF Energy has now reviewed its freight strategy and considers the facilities at both Junction 23 logistics facility in Cannington was not understood, and 24 of the M5 appropriate to handle all levels of freight including local suppliers. Therefore, the facility at especially considering that there would be one in Cannington is no longer required. Bridgwater. Concerns were raised that the facility would have a negative impact on Cannington. For further information on the transport strategy, which includes freight, refer to the Transport Appraisal.
Traffic issues Having reviewed the comments received at Stage 1, EDF Energy’s proposals at Cannington will now consist of a park and ride facility and bypass. Further justification was sought as to how the developments in Cannington would resolve traffic The park and ride facility is proposed to the south of the village, with access off the A39. The park and ride issues, other than those which are localised to facility is proposed in this location for two purposes: it will cater for those workers within the immediate Cannington. catchment of the Hinkley Point C site (HPC) and will also be used by visitors to the HPC site who would travel to and from the site by a shuttle bus service. In addition to the park and ride facility, EDF Energy proposes to provide a Cannington bypass. The bypass will enable all HPC related traffic, except traffic originating in Cannington, to circumnavigate Cannington, therefore reducing the impacts of the HPC project within the village. For further information, refer to the Transport Appraisal.
144 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 19) Cannington Comments EDF Energy Response
Traffic assessment A Transport Appraisal has been prepared and forms part of the Stage 2 consultation documents. It has been prepared in accordance with the Department for Transport’s ‘Guidance on Transport Assessment’, March It was stated that all proposals should be supported by a 2007. A Proposed Travel Plan has also been prepared and forms part of the consultation documents. robust transport assessment, complimented by a robust travel plan.
Focus campuses in Bridgwater As a result of the comments received on the Stage 1 consultation, significant changes have been made to the transport and accommodation strategies in terms of the siting and scale of development. EDF Energy is no Respondents suggested that workers’ accommodation longer proposing to locate accommodation campuses in Cannington or Williton. Instead, campuses will be campuses should be focussed in/around Bridgwater. provided on the Hinkley Point C construction site and in two locations in Bridgwater to accommodate between 1,080 and 1,925 workers, depending on the success of local recruitment and other factors.
For further details of the proposed accommodation campuses, refer to the Preferred Proposals: Explanation and Assessment document.
Refurbishing existing accommodation Following comments received on the Stage 1 consultation, EDF Energy will now be focussing accommodation campuses in Bridgwater and on the Hinkley Point C construction site. Therefore, refurbishment of existing Refurbishment of existing accommodation was accommodation in Cannington will not be progressed. supported, subject to detailed designs being finalised and approved taking account of the conservation area For further details of the rationale for siting the accommodation campuses, refer to the Preferred Proposals: setting. Explanation and Assessment document.
Site access strategy Details of the proposed access arrangements to each of the proposed off-site associated development are shown on the Masterplans for each site. Further details were requested on access arrangements for all sites, including access locations and forms of For further details, refer to the site-specific Masterplan documents. junction.
Impacts to the village EDF Energy understands the importance of community identity, especially in local villages. This, in part, has Respondents identified a number of issues that should led to significant changes being made to the associated siting of the off-site associated developments. be taken into account, including a loss of village identity Proposals for an accommodation campus and freight logistics facility at Cannington no longer form part of EDF and an increased policing need, resulting from a Energy’s associated development proposals. potential influx of workers to the village. Other An assessment of all available brownfield sites within Cannington was undertaken prior to siting the park and
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 145 STAGE 1 CONSULTATION REPORT
19) Cannington Comments EDF Energy Response suggested impacts to consider included noise and light ride facility to the south of the village. The sites were assessed and have been discounted as they were pollution, devaluation of property and use of green field considered unsuitable, therefore a site outside the settlement boundary was selected. sites. Consideration has been given to the need to minimise and, if necessary, mitigate the impacts of the Respondents enquired as to whether measures and development on residents and the environment. For further information, refer to Volume 3 of the funding would be put in place to positively integrate Environmental Appraisal. workers into the community and provide extra policing Contributions to the existing policing infrastructure through planning obligations are detailed in the Proposed where necessary. Planning Requirements and Obligations document. In terms of the potential devaluation of properties as a result of the proposed development, there are a number of statutory provisions that apply. EDF Energy will notify the owners of any properties that could be covered by these provisions. However these only apply to the operation of the associated development facilities and not the period of their construction. Each potential claim will be assessed on an individual basis.
Visual impacts The proposed park and ride facility will not contain buildings of significant height, therefore long-distance Consideration of visual impacts of the proposed landscape and visual impacts would be limited. The study areas also extend to those areas of the Quantock developments, including night views, was sought, not Hills AONB and Exmoor National Park, where relevant. just in the immediate vicinity, but further afield, e.g. from The main landscape and visual impacts associated with the proposed Cannington bypass have been the Quantock Hills. assessed, and a suitable landscape strategy has been designed. The bypass would be permanent feature, therefore permanent landscape treatments would be provided, which would mitigate the visual impact of the bypass in the long-term. The study areas for visual impact also extend to Quantock Hills AONB and Exmoor National Park, and take into account impact of lighting, where relevant. For further information on the visual impact assessments, refer to Volume 3 of the Environmental Appraisal.
Social community infrastructure As part of the mitigation proposals, EDF Energy will undertake assessments of existing and future community infrastructure requirements to identify where appropriate resources should be focused. These assessments It was requested that a socio-economic study be carried consider the impacts of the workforce during both the construction and operational phases of the out to identify the social community infrastructure development. requirements in Cannington as a result of any increased demands linked to the proposed off-site associated For further information, refer to Volume 3 of the Environmental Appraisal. developments.
146 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 19) Cannington Comments EDF Energy Response
Legacy benefits On the basis that EDF Energy is no longer proposing any accommodation campuses in Cannington, the legacy proposals for this aspect no longer need consideration. Further discussions were sought regarding the possible legacy benefits of the worker accommodation. In terms of the park and ride facility, EDF Energy proposes that the development would be removed and Suggestions included: affordable housing, sports returned to green fields following cessation of use (unless otherwise agreed with the relevant authority). facilities, student accommodation residential care home For further information, refer to the Preferred Proposals: Explanation and Assessment document. and a hotel. It was stated that full restoration/legacy proposals would need to be detailed where temporary developments are proposed. It was also commented that temporary facilities on green field sites should be returned to green field following cessation of use.
Flood risk A Flood Risk Study has been prepared in support of each of the proposed off-site associated developments in Cannington. The scope of the study has been discussed with the Environment Agency and these form part of It was stated that Cannington is prone to flooding and the Stage 2 consultation. hard surfaces associated with the park and ride and freight logistics facility could increase this risk. A flood relief channel is proposed to limit flood risk to the proposed development and provide a legacy benefit Respondents requested that all proposed Off-Site by reducing flood risk through the village of Cannington. Associated Developments be subject to a Flood Risk For further information on flooding matters for Cannington, refer to the Flood Risk Study: Overarching Off-site Assessment, with drainage and pollution measures to be Associated Development, Flood Risk Study: Cannington Bypass, and Flood Risk Study: Cannington Park and investigated. Ride Facility documents. Respondents queried what EDF Energy would do to help residents affected by flooding as a result of proposed development in Cannington. It was also suggested that spoil as flood risk management should be investigated.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 147 STAGE 1 CONSULTATION REPORT
19) Cannington Comments EDF Energy Response
Ecological issues Initial ecological surveys have been completed at all the off-site associated development sites and a desk- based assessment of the impacts undertaken. It was stated that appropriate wildlife, habitat and ecological surveys should be carried out, including These surveys have identified the need for further, more detailed ecological survey work, based on the likely information on how biodiversity of Cannington Brook potential impacts of the proposed developments. This includes surveys for breeding birds, bats, reptiles, would be safeguarded. water vole, otter and Great Crested Newt. The scope of the surveys for each site has been discussed and agreed with Somerset County Council’s ecologists and Natural England.
Once collected, the baseline ecological information will be used to assess the potential effect of each proposed off-site associated development on biodiversity. Mitigation has been designed into the proposed development to minimise potentially significant effects on biodiversity.
The Cannington Brook County Wildlife Site was identified during the desk-study and this has been avoided. Additional safeguarding measures would be employed to avoid affecting the Brook during construction, operation and any removal/reinstatement phases of the park and ride facility. For further information refer to Volume 3 of the Environmental Appraisal.
Cultural heritage issues The Cannington Conservation Area (CCA) has been taken into account at all stages of EDF Energy’s assessments. The CCA is an area designated to ensure that developments nearby or within it do not adversely Further information was requested as to how the setting affect the setting and historic value of parts of Cannington. The development sites for the proposed bypass of Cannington Conservation Area would be protected or and park and ride facility are external to the boundary of the CCA. enhanced, as a result of the proposed developments. The search area shown in the Stage 1 consultation has been greatly reduced and the refined proposals now only include a park and ride facility in this location thereby increasing the distance from any sensitive historic or cultural heritage resource. For further information, refer to Volume 3 of the Environmental Appraisal.
Investigative works Initial desk-based assessments have been carried out to establish the need for site investigative works. The findings in the Environmental Appraisal process did not highlight any adverse impacts or likely issues that Further information, supported by investigative works, would require further site investigative works. However, investigations will be undertaken and the findings was sought to ensure groundwater would not be affected will inform the detailed design which will be presented in the application for Development Consent. by developments.
148 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 19) Cannington Comments EDF Energy Response Clarification was sought on what measurements would In addition to the desk-based assessments, geotechnical boreholes and archaeological trial trenches have be put in place to avoid land contamination. been dug across a number of the sites put forward by EDF Energy at the Stage 1 consultation. Further information, including any appropriate mitigation and potential measures to avoid land contamination are provided within Volume 2 of the Environmental Appraisal.
Archaeological potential A full cultural heritage assessment has been carried out and the findings reported in the Environmental Appraisal. Clarification was sought on the potential archaeological impacts of the proposed developments, or other cultural There are no major adverse effects on known archaeological resource, however a proposed mitigation strategy heritage, prior to submission of the application for exists in the event that any were to be found in the future. Development Consent.
Any new development should be proposed on An assessment of all available brownfield sites was undertaken prior to considering the siting of the park and brownfield land ride facility. The sites were assessed and discounted as they were considered unsuitable to meet EDF Energy’s requirements; therefore a site outside the settlement boundary was selected. The Preferred Proposals: Explanation and Assessment document sets out the rationale for locating a park and ride facility in Cannington.
20) Cannington Bypass Comments EDF Energy Response
Principle of need EDF Energy believes that particular considerations arise at Cannington in terms of traffic. Whilst the level of traffic anticipated could be accommodated within the capacity of the roads in Cannington – and whilst Further justification was sought on the need for a assessments suggest that no noise or air quality standards would be breached - the change in traffic levels Cannington bypass, to include traffic modelling and a full from existing flows and the nature of that traffic would be more pronounced in Cannington than elsewhere. environmental impact assessment. For further information on the rationale for the Cannington bypass, refer to the Preferred Proposals: Specific concerns were raised relating to the impacts on Explanation and Assessment document. footpaths, landscaping, the character of the area, noise and light pollution, increased traffic and possible impact to local businesses.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 149 STAGE 1 CONSULTATION REPORT
20) Cannington Bypass Comments EDF Energy Response
Route options Whilst the level of traffic anticipated could be accommodated within the capacity of the roads in Cannington – and whilst assessments suggest that no noise or air quality standards would be breached - the change in Respondents sought further consultation on the potential traffic levels from existing flows and the nature of that traffic would be more pronounced in Cannington than route options for the bypass, including a Bridgwater elsewhere. EDF Energy believes, therefore, that it would be beneficial to include a Cannington western bypass and a bypass at Sandford Corner. bypass as part of its proposals and for the bypass to remain as a permanent legacy of the Hinkley Point C It was also suggested that the bypass be completed development, diverting construction, maintenance and operational traffic away from the centre of the village. before construction begins. EDF Energy has considered whether the impact of the project’s traffic elsewhere could justify similar measures. In Bridgwater there is an extensive road network including a number of A roads and traffic would be dispersed across the network. The main HPC traffic attracted to a Bridgwater bypass would be that coming from the M5 motorway. This would comprise freight vehicles and buses since private vehicles would be intercepted at the proposed park and ride facilities near the motorway.
A Bridgwater northern bypass would be within the flood plain and located in an area of high environmental sensitivity. It would take approximately four years to build and it would either substantially delay the operation of the power station, (and therefore jeopardise the aim of bringing new nuclear power stations on line in time to meet anticipated electricity shortages) , or it would not be ready in time for the peak construction phase. In itself it would generate significant lorry movements during its construction. Taking these factors into account, EDF Energy has concluded that it would not be appropriate to provide a northern Bridgwater bypass, since the mitigation of the peak Hinkley Point C traffic effects would be minimal, whilst the impacts of the bypass construction would be considerable. The construction of the Cannington bypass would be one of the early phases of the project to ensure that it is in place in time for the peak construction period to minimise the duration that construction traffic routes through the village. There are no plans for a bypass at Sandford Corner, but road improvements will be made where they are necessary for the development. For further information, refer to the Transport Appraisal.
150 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 20) Cannington Bypass Comments EDF Energy Response
Rat-running through the village Traffic calming measures are being explored by EDF Energy for Cannington village. EDF Energy will continue to Concerns were raised about Cannington becoming a ‘rat- work with the local highway authority and other stakeholders to identify measures that may be necessary to discourage traffic passing through Cannington. run’ and information was sought what measures would be put in place to encourage use of the bypass. Further information on the proposed traffic calming measures will be provided in the application for Development Consent. Respondents suggested that traffic calming measures should be implemented to encourage use of the bypass.
Western route option Details of the environmental assessments undertaken and the further work required to mitigate any impacts Concerns were raised that the western route option could is set out in Volume 3 of the Environmental Appraisal. result in noise and dust pollution. The potential impact The Masterplan: Cannington Bypass document provides details on the proposals in the vicinity of Brymore on Brymore School was also raised as a point of concern. School, including landscaping and access.
Flood risk A Flood Risk Study has been prepared in support of each of the proposed off-site associated developments in Cannington. The scope of the study has been discussed with the Environment Agency and these form part of The completion of a Flood Risk Assessment was considered necessary. the Stage 2 consultation. A flood relief channel is proposed to limit flood risk to the proposed development and provide a legacy Respondents considered that an eastern route option could offer positive legacy benefits as it would be raised benefit by reducing flood risk through the village of Cannington. to avoid flooding. For further information on flooding matters for Cannington refer to the Flood Risk Study: Overarching Off-site Associated Development; Flood Risk Study: Cannington Bypass; and Flood Risk Study: Cannington Park and Ride Facility documents.
Ground investigation work In addition to on-going dialogue with the appropriate stakeholders, EDF Energy carried out initial desk-based It was stated that due to the proximity of both routes to a assessments to establish the need for ground investigation work. The findings did not highlight any major historic landfill feature and licensed groundwater adverse impacts that could not be managed with suitable mitigation measures. However, investigative works are being carried out to support the detailed design which will be presented in the application for abstraction, further ground investigation work would be required. Development Consent. The route options for the bypass shown at Stage 1 were in broad potential locations, therefore appeared to pass near the quarry. The actual route is now approximately 90 metres away from any features that could be considered a risk. Further information, including any appropriate mitigation and potential measures to avoid land contamination are provided within Volume 3 of the Environmental Appraisal.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 151 STAGE 1 CONSULTATION REPORT
20) Cannington Bypass Comments EDF Energy Response
Environmental surveys An Environmental Appraisal of the proposed Cannington bypass has been undertaken and details are provided in Volume 3 of the Environmental Appraisal. Detailed information on the environmental impacts and subsequent mitigation strategies was required for the bypass route.
Development and maintenance costs EDF Energy will be financing the construction of the bypass, which will be designed to an adoptable standard in accordance with Somerset County Council’s requirements. Clarification was sought on how the development and future maintenance of the bypass would be funded.
21) Combwich Wharf Comments EDF Energy Response
Design, construction and operational requirements Details of the design, construction and operational requirements of Combwich Wharf and that associated freight logistics/storage facility are provided in the Masterplan: Freight Logistics Facilities document. Further information was sought in terms of the design, construction and operational requirements for the Wharf No permanent lighting is planned for the Wharf, however, night time operations may be required, in which and the associated storage facility, including information case mobile lighting would be required. on light pollution. It was suggested that restrictions on Operations at the Wharf are already severely restricted due to the tidal range so no further restrictions are freight activity should be enforced. proposed. For further details, refer to Volume 3 of the Environmental Appraisal.
Pollution prevention Pollution Prevention Guidelines (PPGs) issued by the Environment Agency mainly deal with issues at an operation level without overlapping with other legislation for specific protection of wildlife or light pollution. Respondents stated that pollution prevention guidelines Where appropriate, PPGs have been referenced within Volume 3 of the Environmental Appraisal. should be followed when designing the working methods of the refurbishment of the Wharf. Consideration should Whilst not strictly part of PPGs remit, an ecological assessment for both marine and terrestrial species has also be given to wildlife protection. been undertaken.
For further information on the assessments, refer to Volume 3 of the Environmental Appraisal.
152 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 21) Combwich Wharf Comments EDF Energy Response
Debris management A Construction Phase Plan and an Environmental Management Plan will be prepared by the appointed contractor; this will be issued and approved by EDF Energy to ensure there is minimal impact to the existing Clarification was sought as to how EDF Energy plans to environment. reduce the suspended solid and other debris arising from the development entering into the waterway. For further information on the control mechanisms to be imposed, refer to Volume 3 of the Environmental Appraisal.
Ecological impacts Intertidal bird data for the River Parrett adjacent to Combwich has been collected between April 2009 and March 2010. A winter bird survey has also been completed between September 2009 and March 2010. Respondents stated that development which has the These identify the birds using the site and adjacent areas. potential to damage the conservation value of the area should be kept to a minimum, and In addition to the bird surveys, a breeding bird survey will also be completed in mid/late 2010 along with a mitigation/compensation measures provided. range of other ecological surveys. Clarification was sought on the timing of the proposed For further information, refer to Volume 3 of the Environmental Appraisal development to minimise disturbance to over-wintering and nesting birds.
Flood risk A Flood Risk Study has been prepared in support of each of the proposed off-site associated developments. The scope of the study has been discussed with the Environment Agency and these form part of the Stage 2 The completion of a Flood Risk Assessment was consultation. considered necessary to identify any adverse flood risk implications for the Wharf and existing developments as For further information on flooding, refer to the Flood Risk Study: Overarching Off-site Associated a result of these works. Development and Flood Risk Study: Combwich Wharf and Freight Logistics Facility documents.
Legacy benefits Combwich Wharf will be available to Hinkley Point B station and National Grid to continue to use for their purposes; reducing their need to transport freight by road. It was suggested that legacy benefits for the Wharf could include using it for commercial purposes. The Hinkley Point C station will use the facility for its construction, operational and decommissioning phases. Restrictions on the use of the facility will be imposed as a condition of the Development Consent to ensure that there would be no harm to residential amenity. For further information, refer to the Preferred Proposals: Explanation and Assessment document.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 153 STAGE 1 CONSULTATION REPORT
21) Combwich Wharf Comments EDF Energy Response
Impact on existing river users Further information is provided in Volume 2 of the Environmental Appraisal. Further clarification was requested as to how existing river users would be affected by the proposals for Combwich Wharf. It was suggested that a desk-based assessment on existing navigation should be undertaken.
Road improvements EDF Energy has undertaken a detailed analysis of the highway infrastructure between Combwich and Hinkley Point and has identified the need to undertake minor, temporary alterations to the network in identified Respondents stated that the layout of existing junctions locations. These works will form part of the application for development consent. at Combwich Wharf and Otterhampton should be improved to cope with already excessive loads using the For further information, refer to Volume 3 of the Environmental Appraisal. C182. New accesses to the C182 should be constructed to current design standards.
22) Williton Comments EDF Energy Response
Justification for a park and ride facility The analysis informing the location of the park and ride strategy indicates that there will be a number of workers, both home-based and non-home-based, who will reside to the west of Hinkley Point and will use the Further evidence was sought on the need for a park and park and ride facility. The park and ride facility will also provide an option for workers from Taunton. ride facility in Williton. Respondents commented that it was not clear why 12% of workers are estimated to be For further information on the rationale for the park and ride facility, refer to the Masterplan: Park and Ride coming from the west via Williton given that there is no Facilities and Preferred Proposals: Explanation and Assessment document. strategic road access from the west. It was suggested that the park and ride facility would be better located near Minehead, whilst other respondents stated that Williton is too far from the site.
154 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 22) Williton Comments EDF Energy Response
Alternative to park and ride facilities The park and ride strategy will be supported by long-distance coaches and buses should the demand exist.
It was suggested that a bus service to collect workers Further information on the bus strategy is provided in the Transport Appraisal. travelling from West Somerset would be preferable to a park and ride facility.
Suitability of roads The focus of the Transport Appraisal has been to minimise the vehicular traffic generated by the Hinkley Point C development and promote more sustainable modes of travel, thereby reducing the impact to the local and Respondents stated that the A39 is already unsuitable strategic road networks. and that consideration should be given to the impact of the Hinkley Point C development on this road as it is the In addition to the Transport Appraisal, a mitigation strategy is being developed to cater for the residual main route for holiday traffic into West Somerset. impacts of the construction and operational phases of the Hinkley Point C development. For example, junction improvements would be implemented where there are operational problems caused by the Respondents requested that consideration be given to movement of vehicles associated with the development. the pinch points between Williton and Cannington. Further information can be found in the Transport Appraisal.
Legacy benefits EDF Energy is no longer proposing to locate an accommodation campus in Williton, therefore legacy options only relate to the park and ride facility. Having considered the feedback from the Stage 1 consultation. EDF It was stated that the park and ride facility could Energy proposes to submit legacy plans to the relevant authority for approval at the appropriate time, as set potentially have a role in easing tourist traffic congestion out in the Proposed Planning Requirements and Obligations document. Legacy uses identified by EDF Energy along the A39. (or another party) in the future would require separate permission to be sought from the relevant authority. It was also commented that any campus accommodation For full details of the proposed park and ride facility, refer to the Masterplan: Park and Ride Facilities and could be converted to affordable housing or a care home Volume 3 of the Environmental Appraisal document. following cessation of use, providing a positive legacy for the community. Other suggestions for possible legacy benefits included: leisure facilities, recreation areas, hotel and a village hall. Respondents stated that any potential legacy options should be given further consideration with regard to suitability and sustainability.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 155 STAGE 1 CONSULTATION REPORT
22) Williton Comments EDF Energy Response
Social and community infrastructure An appraisal of the socio-economic impact of the proposed development is included in Volume 3 of the Environmental Appraisal. Respondents suggested a full assessment of social and community infrastructure requirements be undertaken, having regard to the likely demographics and composition of the workforce and the potential associated impacts.
Traffic impact Traffic models of key junctions in Williton have been developed to assess the impact of the proposed park and ride facility in Williton. The models demonstrate that there are no material traffic impacts associated with Respondents requested that a transport assessment be the park and ride facility in Williton. undertaken to establish whether the proposals for the park and ride facility are feasible in traffic terms. Further details of traffic impacts and assessments are included in the Transport Appraisal.
Visual impacts The proposed park and ride facility will not contain buildings of significant height, therefore long-distance landscape and visual impacts would be limited. The study areas also extend to those areas of the Quantock Consideration of the visual impacts of the development, Hills AONB and Exmoor National Park. including night views, was sought, not just in the immediate vicinity, but further afield, e.g. from the For further information, refer to Volume 3 of the Environmental Appraisal. Quantock Hills.
Impacts to local area Impacts on Public Rights of Way (PRoW) and terrestrial ecology have been assessed, in consultation with statutory bodies, including Natural England and Somerset County Council. Appropriate mitigation has been Loss of footpaths and green field sites were mentioned as identified to manage any perceived impacts associated with the proposed development at Williton. points of concern. For further information on the assessments and proposed mitigation, refer to Volume 3 of the Environmental Appraisal.
Alternative sites for accommodation Given the scale of accommodation that will be required for the short-term peak of workers, EDF Energy is working with a range of housing agencies and potential partners to develop the next level of detail of its Additional search areas to those proposed by EDF Energy Accommodation Strategy. This will involve the establishment of a detailed database of accommodation were put forward as alternatives for development. opportunities to match the requirements of workers. As one element of this work, EDF Energy is exploring options for partnering with local providers to bring forward new homes in the area and to use these for a
156 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 22) Williton Comments EDF Energy Response temporary period before they are released to the private and affordable markets. Such options cannot be brought forward as part of the IPC process, which precludes the inclusion of dwellings in the application for Development Consent. Any proposals developed as a result of this initiative would therefore be the subject of separate planning applications under the town and country planning process and subject to their own specific consultation.
Flood risk The site is located outside of the flood plain and therefore would not result in harm to the village. Additionally, flood alleviation ponds would manage any surface water. For further details refer to the Flood Clarification was sought on the level of flood risk as a result of the proposed developments, and details of the Risk Study: Williton Park and Ride Facility document. implications for existing developments. Respondents stated that any development within Flood Zone 3B should be avoided, unless it could be supported by flood alleviation measures, which are considered to be a worthy flood risk reduction legacy to the town.
Ecological surveys Initial ecological surveys have been completed and a desk-based assessment of the impacts undertaken. These surveys have identified the need for further, more detailed ecological survey work, based on the likely Respondents requested that a full ecological survey be carried out to assess the impacts on protected species as potential impacts of the proposed developments. This includes surveys for breeding birds, bats, reptiles, a result of the proposed development. Specific concerns water vole, otter and Great Crested Newt. The scope of the surveys has been discussed and agreed with Somerset County Council’s ecologists and Natural England. were raised over badger habitats. Once collected, the baseline ecological information will be used to assess the potential effect of each proposed development on biodiversity. Mitigation has been designed into the proposed development to minimise potentially significant effects on biodiversity. For further information, refer to Volume 3 of the Environmental Appraisal.
Archaeological surveys As a result of the comments received at Stage 1 consultation, only the site referred to as WIL-A will now be Development in Williton was questioned as both sites developed. The land area referred to as WIL-B is now not to be used. have high archaeological potential. The site on which the proposed development would be located is furthest from any archaeological resource, including the local ancient monument. Geophysical survey and trial trenching demonstrated that there is very low potential for buried archaeological remains on the site. For further details, refer to Volume 3 of the Environmental Appraisal.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 157 STAGE 1 CONSULTATION REPORT
22) Williton Comments EDF Energy Response
Principle of development Having considered the responses received at Stage 1 consultation, EDF Energy is no longer proposing to develop the WIL-B search area. It was suggested that the WIL-B search area is located in Sampford Brett, which is designated in the Local Plan as A park and ride facility in Williton is still required and it is proposed that this would be located within part of not allowing further development of infrastructure. the WIL-A search area, to the west of the village. For full details, refer to Volume 3 of the Environmental Appraisal.
23) Bridgwater Comments EDF Energy Response
Search area BRI-A EDF Energy recognises that BRI-A is a suitable location for an accommodation campus. Assessments of existing and required infrastructure have been undertaken and identified a need to provide access to the site It was suggested that BRI-A is in a sustainable location and ancillary facilities for workers, including recreational and catering facilities. with key infrastructure already in place. For full details of the proposed accommodation campus at BRI-A, refer to Volume 3 of the Environmental Appraisal.
Search area BRI-C EDF Energy has prepared a masterplan setting out the proposed uses for the accommodation campus; this includes accommodation, a canteen, administration facilities and recreation amenities. No use for the existing It was suggested that BRI-C could provide space for a club house has been identified. campus, as well as having space for supporting facilities within the existing club house. For further details on the proposed accommodation campus at BRI-C, refer to Volume 3 of the Environmental Appraisal.
Search area BRI-D EDF Energy recognises that BRI-D is poorly located in terms of accessing facilities and services; therefore this option has been discounted as a potential location for an accommodation campus. It was stated that BRI-D is a poorly located site with respect to existing facilities, and would offer poor prospects for legacy benefits for Bridgwater.
158 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 23) Bridgwater Comments EDF Energy Response
Bridgwater Vision The proposed campuses in Bridgwater conform to the principles of the Bridgwater Vision. In terms of BRI-A on the former Innovia site in north-east Bridgwater, once use of the accommodation campus ceases, it is Clarification was sought as to whether the sites would proposed that buildings would be removed, while infrastructure would remain (e.g. roads, recreational conform to the Bridgwater Vision. facilities). This would enable future development to come forward. It was stated that the proposed developments in At BRI-C, adjacent to the Bridgwater Rugby Club, EDF Energy envisages the development could be used as Bridgwater could regenerate the northern area and could student accommodation or related uses in connection with Bridgwater College. The Bridgwater Vision have positive a legacy for the areas around the identifies future development in connection with the College in this location. Therefore the proposed motorway junctions. development assists in delivery of this long-term strategy. EDF Energy proposes to submit legacy plans in respect of BRI-A and BRI-C to the relevant authority for approval at the appropriate time, as set out in the Proposed Requirements and Obligations document.
Both the construction and operation of Hinkley Point C will provide substantial inward economic investment to the local area. Bridgwater is well placed to benefit from the employment procurement and training initiatives generated by and for the development of the power station and the associated developments. Together with the legacy benefits, significant overall benefit will accrue to Bridgwater, consistent with the Bridgwater Vision. For further information on conforming to the Bridgwater Vision, refer to the Masterplan: Accommodation Campuses document.
Sustainable transport options A Travel Plan will be implemented which will seek to provide sustainable transport options for work and non- work related trips. The Travel Plans for the accommodation campuses will be in accordance with the Travel Respondents requested that consideration be given to Plan that forms part of the Stage 2 consultation documents. implementing sustainable transport links between the sites and surrounding areas. Examples given included a For further information on the Proposed Travel Plan, refer to the Transport Appraisal. new link road across the railway line to the A38, a new pedestrian/cycle link crossing the motorway and railway, and a visual improvement of the A39. Respondents commented on the potential impact on the existing road infrastructure.
Impact to road infrastructure A Road Safety study has been prepared, which examines the accident history of the local and strategic
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 159 STAGE 1 CONSULTATION REPORT
23) Bridgwater Comments EDF Energy Response Comments were received regarding the potential impact highway network. The next stage of the study is to assess what the likely impact the Hinkley Point C Project will on the existing road infrastructure, specifically regarding have on accidents and seeks to mitigate the impact where necessary. This work is ongoing and will be gridlock as a result of an accident on the A38. discussed and agreed with the highway authorities, and submitted as part of the application for Development Consent. Further information on the Road Safety study can be found in the Transport Appraisal.
Legacy benefits EDF Energy proposes to construct all accommodation campuses to BREEAM ‘Good’ standard, with the exception of development at BRI-C, which would be constructed to achieve an ‘Excellent’ standard. BREEAM Campuses should be built to a high standard with the rating considers wide-ranging environmental and sustainability issues and enables developers and designers provision of sufficient leisure and social facilities, and to prove the environmental credentials of their buildings. Details of how the developments will achieve this be suitable for conversion to alternative uses following rating will be detailed as part of the application for Development Consent. cessation of use by EDF Energy. The accommodation campuses will comprise living/sleeping with associated facilities including canteens, Clarification was sought on potential legacy uses for recreational facilities and communal lounges. each site, with comments received stating that development in Bridgwater could also bring local The proposed campuses in Bridgwater conform to the principles of the Bridgwater Vision. In terms of BRI-A on employment. the former Innovia site in north-east Bridgwater, once use of the accommodation campus ceases, it is proposed that buildings would be removed, while infrastructure would remain (e.g. roads, recreational facilities). This would enable future development to come forward. At BRI-C, adjacent to the Bridgwater Rugby Club, EDF Energy envisages the development could be used as student accommodation or related uses in connection with Bridgwater College. The Bridgwater Vision identifies future development in connection with the College in this location. Therefore the proposed development assists in delivery of this long-term strategy. EDF Energy proposes to submit legacy plans in respect of BRI-A and BRI-C to the relevant authority for approval at the appropriate time, as set out in the Proposed Requirements and Obligations document. For further details of the proposed campuses, refer to the Masterplan: Accommodation Campuses and Volume 3 of the Environmental Appraisal documents.
160 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 23) Bridgwater Comments EDF Energy Response
Flood risk There are no feasible opportunities for reducing the overall level of flood risk in Bridgwater. The Environment Agency has confirmed that the site-specific Flood Risk Studies for BRI-A and BRI-C only need to consider the It was stated that all sites fall within Flood Zone 3A and period up to 2030 as the proposed Parrett flood defence barrier will be effective from 2030 onwards. that EDF Energy should review opportunities to reduce the overall level of flooding in Bridgwater. For further information on flooding, refer to the Flood Risk Study: Overarching Off-site Associated Development and Flood Risk Study: Bridgwater Accommodation Campuses documents.
Site investigations Initial desk-based assessments have been carried out to establish the extent of site investigative works. Investigations will be undertaken and the findings will inform the detailed design which will be presented in Further clarification was needed as to which sites are the application for Development Consent. contaminated. Further information on land contamination can be found in Volume 3 of the Environmental Appraisal. It was stated that all sites would require full contaminated land investigations before development commences.
Ecological surveys Initial ecological surveys have been completed and a desk-based assessment of the impacts undertaken. These surveys have identified the need for further, more detailed ecological survey work, based on the likely Respondents requested that further ecological surveys potential impacts of the proposed developments. This includes surveys for breeding birds, bats, reptiles, and impact assessments be carried out at all sites to water vole, otter and Great Crested Newt. The scope of the surveys has been discussed and agreed with gauge the potential impact on local wildlife. Somerset County Council’s ecologists and Natural England. Once collected, the baseline ecological information will be used to assess the potential effect of each proposed development on biodiversity. Mitigation has been designed into the proposed development to minimise potentially significant affects on biodiversity. For further information, refer to Volume 3 of the Environmental Appraisal.
Archaeological interest The site on which the proposed development would be located is remote from any archaeological resource, including the Scheduled Monument. Geophysical survey and trial trenching demonstrated that there is very Further clarification was needed as to the possible low potential for buried archaeological remains on the site. impacts to locally important archaeological remains. For further details, refer to Volume 3 of the Environmental Appraisal.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 161 STAGE 1 CONSULTATION REPORT
23) Bridgwater Comments EDF Energy Response
Cumulative impact As part of the Environmental Appraisal an assessment of all other development initiatives in the areas around the sites proposed for development has been conducted. This has taken into account the Building Schools for Respondents requested that a cumulative impact the Future programme and construction of the North East Bridgwater development. For further details, refer to assessment be carried out to identify other proposed Volume 3 of the Environmental Appraisal developments in the area and their potential impact on the strategic road network. The Transport Appraisal also considers the growth in traffic as a result of other committed developments in the areas around the sites proposed for development.
Social and community infrastructure An appraisal of the socio-economic impact of the project is included in Volumes 2 and 3 of the Environmental Appraisal. Respondents requested that a full assessment of social and community infrastructure requirements should be undertaken, having regard to the likely demographics and composition of the workforce and the potential associated impacts.
24) Junction 23, M5 Comments EDF Energy Response
Bridgwater Vision The Bridgwater Vision identifies potential locations for park and ride facilities both north and south of Bridgwater. Whilst the Vision document does not identify specific sites, the identified search areas correlates Clarification was sought on how the proposed strategy with EDF Energy’s proposed locations for development of park and ride facilities. conforms to the Council’s objectives. For further information on compliance with the Bridgwater Vision please refer to the Masterplan: Park and Ride Facilities document.
Traffic impacts A computer model has been developed of the local and strategic road network to assess the traffic impacts of the HPC project. This model includes Junction 23 of the M5 motorway. A mitigation strategy is being developed It was suggested that development at J23 could to cater for the residual impacts of construction and operation of the HPC development. Junction potentially impact the flow of traffic to the M5 by improvements would be implemented at junctions where there are operational problems caused by HPC. At generating a level of trips that could detrimentally this stage it is considered that the partial provision of signals at of Junction 23 of the M5 motorway would impact the network. However other comments received
162 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 24) Junction 23, M5 Comments EDF Energy Response stated that the park and ride could help eliminate the provide positive benefits. The details of this option are provided in the Transport Appraisal. gridlock in the area. The proposed park and ride facility adjacent to Junction 23 of the M5 motorway would intercept HPC More information was requested on traffic modelling for construction workforce trips at a key route to the HPC development site and reduce impact on local highway this development. network.
Respondents suggested that consideration should be EDF Energy is proposing to import significant volumes of construction materials by sea (via a jetty on-site and given to potentially signalising J23 to improve traffic. Combwich Wharf) rather than road in order to reduce the impact of the HPC Project on the road network. It was suggested that park and ride and freight logistic Analysis has also been undertaken of proposals for a northern Bridgwater bypass. A summary of EDF Energy’s facilities be linked with Bridgwater bypass. It was also response is provided in section 20 of this table. queried whether freight could be linked in with travelling Further information can be found in the Transport Appraisal by river.
Legacy benefits EDF Energy has taken into account the responses to the Stage 1 consultation when identifying a preferred legacy strategy for each site. EDF energy believes there is a potential legacy benefit from the Junction 23 site Further information was requested on the ongoing being used, after construction of the power station is complete, to serve Bridgwater as a park and ride facility, viability of park and ride facilities post construction employment-generating use or other appropriate land use. EDF Energy proposes to submit legacy plans to the period, with a view to clarifying the potential legacy relevant authority for approval at the appropriate time, as set out in the Proposed Planning Requirements and benefit of J23. Obligations document. Legacy uses identified by EDF Energy (or another party) in the future, would require separate permission to be sought from the relevant authority. For full details of the preferred legacy strategy proposed for each site, see the Preferred Proposals: Explanation and Assessment document.
Employment benefits The Bridgwater Vision identifies a need for approximately 3.5 hectares of employment space in this location to contribute towards regional economic targets. It was suggested that any employment opportunities should be considered in line with emerging planning The park and ride and freight logistics facility will contribute towards these targets, both during and post EDF policy. Energy use of the site.
For further information on the employment benefits and policy compliance please refer to the Masterplan: Park and Ride Facilities document.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 163 STAGE 1 CONSULTATION REPORT
24) Junction 23, M5 Comments EDF Energy Response
Flood risk A Flood Risk Study has been prepared in support of each of the proposed off-site associated developments. The scope of the study has been discussed with the Environment Agency and these form part of the Stage 2 Respondents stated that both sites fall within Flood consultation. Zone 3A and should be subject to a Flood Risk Assessment. Further information was sought regarding For further information on flooding, refer to the Flood Risk Study: Overarching Off-site Associated Development the possible impacts to the strategic road network in the and Flood Risk Study: Junction 23, M5, Freight Logistics and Park and Ride Facility documents. event of flooding.
Land contamination Initial desk-based assessments have been carried out to establish the likelihood of contaminated land. The findings are reported in the Environmental Appraisal, and the need for potential investigations is Respondents stated that land contamination surveys acknowledged where appropriate. would be required due to the historic nature of this area.
Ecological assessments Initial ecological surveys have been completed and a desk-based assessment of the impacts undertaken. These surveys have identified the need for further, more detailed ecological survey work, based on the likely Respondents stated that further ecological surveys and potential impacts of the proposed developments. This includes surveys for breeding birds, bats, reptiles, habitat regulation assessments would be needed as water vole, otter and Great Crested Newt. The scope of the surveys has been discussed and agreed with both sites could potentially support protected species, Somerset County Council’s ecologists and Natural England. including Great Crested Newts and birds from the Severn Estuary SPA. Once collected, the baseline ecological information will be used to assess the potential effect of each proposed development on biodiversity. Mitigation has been designed into the proposed development to minimise potentially significant affects on biodiversity. For further information, refer to Volume 3 of the Environmental Appraisal.
Cultural heritage impacts A full cultural heritage assessment has been carried out and the findings reported in Volume 3 of the Environmental Appraisal. Respondents requested that development in this area considers the potential impact to listed buildings or There are no major adverse effects on known archaeological resource; however a proposed mitigation strategy scheduled ancient monuments. exists in the event that any were to be found in the future.
164 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 25) Junction 24, M5 Comments EDF Energy Response
Alternative sites EDF Energy has reviewed the alternative site options proposed by various respondents at Stage 1 consultation. All of the sites were assessed and discounted on the basis that they did not meet the necessary criteria and Additional search areas to those proposed by EDF Energy were considered to be unsuitable for EDF Energy requirements. were put forward as alternatives for development. For further details on the alternative sites considered please refer to Volume 3 of the Environmental Appraisal.
Bridgwater Vision The Bridgwater Vision identifies potential locations for park and ride facilities both north and south of Bridgwater. Whilst the Vision document does not identify specific sites, the identified search areas correlates Clarification was sought as to how the proposed strategy with EDF Energy’s proposed locations for development of park and ride facilities. conforms to the Council’s objectives. For further information on compliance with the Bridgwater Vision please refer to the Masterplan: Park and Ride Facilities document.
Traffic modelling A micro-simulation model, Paramics, has been developed of the local and strategic road network to assess the traffic impacts of the Hinkley Point C (HPC) development. A mitigation strategy is being developed to cater for It was stated that the proposed facility should the residual impacts of construction and operation of the HPC development. For example, junction demonstrate a reduction in traffic impacts to the improvements would be implemented where there are operational problems caused by vehicle movement strategic and local road networks. associated with HPC. Concerns were raised over increased traffic due to freight Further information can be found in the Transport Appraisal which is included as part of the Stage 2 logistics facilities proposals. consultation documents.
Highway network The design of the park and ride access has been informed by traffic modelling. It is proposed to access the park and ride facility off the Stockmoor Link Road, which forms an arm of the A38/Bridgwater Motorway It was suggested that additional works to the A38 Service Area (MSA) roundabout. roundabout would be required as a result of development in this location. For further information on the proposed highways works, refer to the Transport Appraisal.
Impact on residential amenity EDF Energy has undertaken detailed site analysis as part of the masterplanning process identifying constraints, including nearby properties. Layouts of all associated development sites have evolved ensuring Respondents requested that impacts to neighbouring that residential amenity is protected. Noise impact assessments are being undertaken and any mitigation properties be considered in the design process, to measures, if required, will be specified within this report. ensure these are minimised. For further information on the proposed developments please refer to the Masterplan: Accommodation Campuses and Masterplan: Park and Ride Facilities documents.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 165 STAGE 1 CONSULTATION REPORT
25) Junction 24, M5 Comments EDF Energy Response
Legacy benefits EDF Energy has taken into account the responses to the Stage 1 consultation when identifying a preferred legacy strategy for each site. EDF energy believes there is a potential legacy benefit from the Junction 24 site Clarification was sought on potential legacy benefits to the community arising from the developments at being used, after construction of the power station is complete, to serve Bridgwater as a park and ride facility, Williton. employment-generating use or other appropriate land use. EDF Energy proposes to submit legacy plans to the relevant authority for approval at the appropriate time, as set out in the Proposed Planning Requirements and It was suggested that J24-A presents the greatest Obligations document. Legacy uses identified by EDF Energy (or another party) in the future, would require opportunity for legacy, and J24-B the weakest. separate permission to be sought from the relevant authority. Further research would be needed into the ongoing For full details of the preferred legacy strategy proposed for each site, see the Preferred Proposals: Explanation viability of the park and ride facility post construction and Assessment document. phase.
Flood risk A Flood Risk Study has been prepared in support of each of the proposed off-site associated developments. The scope of the study has been discussed with the Environment Agency and these form part of the Stage 2 It was acknowledged that the site falls within Flood Zone 1. However, any proposal should be accompanied by a consultation. Flood Risk Assessment, to include details of surface For further information on flooding, refer to the Flood Risk Study: Overarching Off-site Associated Development water drainage. and Flood Risk Study: Junction 24, M5, Freight Logistics and Park and Ride Facility documents.
Pollution control measures The assessment acknowledges any potential impact for effects on surface water run off. General mitigation that may be suitable includes measures such as oil interceptors and rate reduction, which are in agreement Details were sought on pollution control measures to be implemented with the development to minimise risk of with the Environment Agency. contaminated surface water run-off, given the For further information on the assessments, refer to Volume 3 of the Environmental Appraisal. characteristics of the sites.
Ecological surveys Initial ecological surveys have been completed and a desk-based assessment of the impacts undertaken. Further ecological surveys would be needed as a number These surveys have identified the need for further, more detailed ecological survey work, based on the likely of protected species have been recorded in the area, potential impacts of the proposed developments. This includes surveys for breeding birds, bats, reptiles, including Great Crested Newts water vole, otter and great crested newt. The scope of the surveys has been discussed and agreed with Somerset County Council’s ecologists and Natural England. Once collected, the baseline ecological information will be used to assess the potential effect of proposed development on biodiversity. Mitigation has been designed into the proposed development to minimise potentially significant affects on biodiversity. For further information refer to Volume 3 of the Environmental Appraisal.
166 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT
26) Broader Community Issues Comments EDF Energy Response
Socio-economic issues The Environmental Appraisal chapter relating to socio-economics (Volume 2 Chapter 8 and in the separate Off- site Associated Development chapters) covers these issues. A stakeholder meeting held in February 2010 Lack of assessment and analysis describing the socio- welcomed the coverage of policies and the update on local socio-economic conditions. The main debate was economic conditions and how the socio-economic about the extent of likely local recruitment for peak construction, and there was agreement on the approach impacts correlate with planning policy. Consultees which included some alternative scenarios. suggested that the socio-economic methodology may not be the best means to assess the impacts of a project of this scale.
Tourism As above, the Environmental Appraisal chapter relating to socio-economics notes the approach which had been used to provide appropriate headroom for the local tourist accommodation needs, taking into account No information presented on the potential impact on tourist accommodation occupancy data. This has resulted in a significant provision of purpose-built tourism and that a strategy to manage and mitigate accommodation campuses being proposed in the Stage 2 consultation for the construction workforce. impacts before confirming the accommodation strategy would be necessary.
How proposals integrate with wider regeneration and The socio-economic chapters of the Environmental Appraisal provide a full assessment of potential project economic objectives impacts including employment, accommodation, social, cultural and wider economic impacts. The socio- economic chapters also identify the characteristics of the Hinkley Point C Project against relevant policies and Consultees sought further information on the ability of objectives. the development to deliver local and regional priorities. More specifically, the potential legacy value of the proposed campus development noted above would, very directly, deliver regeneration benefits for North East Bridgwater. Both the construction and the operation of Hinkley Point C would provide substantial inward economic investment to the local area and Bridgwater is well placed to benefit from the employment, procurement and training initiatives generated by and for the development of the power station and the associated development. Together with the legacy benefits provided by the accommodation sites, significant overall benefit will accrue to Bridgwater, consistent with the Bridgwater Vision.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 167 STAGE 1 CONSULTATION REPORT
26) Broader Community Issues Comments EDF Energy Response
Policing The proposed development at Stage 2 takes into account the sensitivity of a substantial extra workforce presence in the community, but also the good practice lessons from Sizewell B construction which showed Potential increase in demand on local policing services that mitigation measures can be very effective in minimising the potential for worker-related incidents in the due to rise in population and potential protest activity. local area. At Sizewell B such measures included free shuttle minibus service from the site accommodation campus to Leiston, provision of attractive facilities on-site, and site induction procedures which stressed the importance of sensitivity to the local community. Overall, representatives of the local police on Sizewell B consistently expressed the view that the construction workforce had been relatively trouble free, with few serious incidents. Hinkley Point C has the opportunity to anticipate and plan for these and other appropriate mitigation measures in a timely fashion. The provision by EDF Energy of accommodation campuses, where discipline can be strictly maintained by security staff, is particularly significant in managing worker behaviour. It should also be noted that developer drink and drugs policies/testing are now much better than for earlier developments and would be implemented on a zero tolerance basis. Current experience from Flamanville 3 also indicates very low levels of non-local worker behavioural issues, even with a major accommodation centre (c. 400 workers) within the urban envelope of the small town of Les Pieux (c. 3,500 population). A large construction project nevertheless is likely to put additional pressure on policing services. The area around Hinkley Point already has the benefit of policing both by the civil authority and by the civil nuclear constabulary. Further information on this is provided in the Environmental Appraisal chapter on Socio- economics (Volume 2 Chapter 8).
168 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 27) Jobs and Training Comments EDF Energy Response
Employment benefits and how achieved The Hinkley Point C Project will bring with it significant employment benefits to the people of Somerset, which would include the area of Burnham and Highbridge. Respondents welcomed increased wages, however, noted that this could increase local cost of living and EDF Energy will be looking to put in place skills training to support local people in Somerset to access job there appeared to be no employment benefit for the area opportunities during both the construction and operational period. EDF Energy is working with community of Burnham and Highbridge. organisations such as Bridgwater College, Job Centre Plus and the Councils to put make this happen. As part of this work, EDF Energy will be seeking out projects to support the creation of a more diverse workforce. In developing contracts respondents wished to ensure that they address issues such as equality, training and environmental considerations.
Local community development and training EDF Energy are currently in discussions with a number of the education providers including the colleges in the region and other agencies to ensure that skills training is appropriate and available to support people to seek Importance of ensuring education and training for local employment in the construction or operation of the Hinkley Point C Project. people to benefit from new jobs by providing local educational facilities for appropriate training and EDF Energy are also looking to bring some of their education programmes and STEM Ambassador programme securing jobs for the local community – particularly for to Somerset and in working with local schools encourage young people to pursue a career in construction, the young people. Further information required on engineering or the energy sectors. community development initiatives for job creation and enterprise.
Labour force and skills requirements The Environmental Appraisal on Socio-economics (Volume 2 Chapter 8) provides detail on the profile of the labour pool in Somerset and across the region as well as providing a workforce forecast with skills breakdown Better understanding of the labour force and skills for the development at Hinkley Point C. requirements needed, including the likely sourcing of labour force. EDF Energy are working with the Councils to put a detailed plan in place to maximise the opportunities for local people to access employment by ensuring that the training they require is in place to achieve this goal. It should be noted that the skills training provided will be linked to the job opportunities available. Contractors will be encouraged at mobilisation to make use of this local workforce.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 169 STAGE 1 CONSULTATION REPORT
27) Jobs and Training Comments EDF Energy Response
Development of the training strategy EDF Energy has been made aware by stakeholders of the need to support people in the community back to work. EDF Energy is developing a Construction Workforce Development Strategy which will be available to Further work recommended in order to create relevant authorities. opportunities for harder to reach groups (hard to hear groups). Information was requested on how the strategy EDF Energy is looking to support people into roles through the provision of basic skills training as a job entry can help achieve local area targets and positive route, advanced skills training and apprenticeships. EDF Energy contractors working on the development will outcomes. also invest in the continued up-skilling of their employees to national standards and in some cases the achievement of the Nuclear Construction Passport, as appropriate. Funding of education and training to include apprenticeships was considered essential. In addition to this, EDF Energy is planning to offer additional apprenticeship opportunities to local people for technician roles, as well as supporting local graduates into employment.
Workforce displacement As is always the case with a large development of this type that existing businesses will be concerned that their employees will leave them and go and work on the development. EDF Energy has discussed the Concern over potential displacement of jobs to the possibility of labour market displacement with the socio-economic managers at both county and district level. project from local employers, and the potential out This will be kept under observation and should it occur action will be taken to mitigate the impact. The migration of the workforce to other nuclear projects. Construction Workforce Development Strategy will outline the work that will be undertaken to support people into work on the development through access to skills training. EDF Energy are in the process of putting in place methods for local businesses to have access to the opportunities presented by the development, including support and information provided by the Somerset Chamber of Commerce and the availability of training at local providers for their workforce.
Consultation recommended with local education and Consultation is ongoing with local education, business providers and the local Councils to develop plans in business providers support of skills, training and jobs packages. To develop the skills, training and jobs packages.
170 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 28) Procurement Comments EDF Energy Response
Mechanisms to ensure local supply chain development EDF Energy has been working with organisations such as Business Link, The South West Manufacturing and Advisory Service, the Councils as well as the Somerset Chamber of Commerce and the South West Regional Further information requested on this to inform the Development Agency, to put in place mechanisms to support local business gain access to the opportunities procurement strategy. Assurance required about the presented by the Hinkley Point C Project. promotion of local business involvement in the supply chain and how they might become involved in gaining EDF Energy will be running a series of events for local suppliers to better understand the opportunities as they relevant skills. arise for specific packages of work. This is a rolling programme going forward linked to the letting of the major packages of work for the development. The major contractor who wins work on the development will be encouraged to engage the services, as appropriate, of local business. In addition, EDF Energy has commissioned Somerset Chamber of Commerce to establish a database for local businesses to register their interest in work and seek support in accessing the opportunities.
Securing long term legacy benefit of procurement EDF Energy have forecasted a considerable socio-economic benefit for Somerset, which includes:
Understanding required as to how this can be achieved. the construction period – will see thousands of job opportunities for local people. It is estimated that £100m a year during construction would be spent in the community via salaries and local supply contracts; and once operational, there will be 700 permanent employees and up to 200 contractors at Hinkley Point C, all of whom are expected to live within a 25 mile radius of the station. During 60 years of operation about £40m a year will be spent in worker salaries. The need for regular refuelling and maintenance outages will also inject money into the local community. EDF Energy are working with local agencies to develop a skills and employment infrastructure to support the development which will provide access to employment for local people and create a nuclear construction skills cluster. In addition, EDF Energy is developing a procurement strategy to ensure local businesses can capitalise on the supply chain opportunities.
Thousands of new, many highly-skilled, jobs will be created, directly and in the supply chain, benefiting those employed, their families and the communities in which they live. They will help to underpin and drive local economic development. In short, the impact of the EDF Energy investment on the local economy and community will be transformative and long-lasting.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 171 STAGE 1 CONSULTATION REPORT
28) Procurement Comments EDF Energy Response
Suppliers should be environmentally accredited EDF Energy will publish its preferred accreditation standards as part of its tendering materials. This will cascade through the supply chain. Information and support to achieve these standards can be sought form Details needed of the mechanism for ensuring this. local agencies such as Business Link, The Manufacturing Advisory Council and the Somerset Chamber of Commerce.
Training and procurement strategy EDF Energy is working with local agencies to put an infrastructure in place to support local business access opportunities as presented by the development. This support ranges from the establishment of a database to Ensure it recognises Local Area Agreement targets register their interest and make connections, to available opportunities, to briefing sessions on the current opportunities and with access to the buyers.
More background information on procurement strategy EDF Energy want a well trained highly skilled workforce throughout their supply chain and are investing in the needed development of skills training as well as methods to support people into work. Including socio-economic background work to deliver The procurement strategy sets out the need for major contractors and other suppliers to engage with local 50% local labour force and local business profiling. It business and access local services as appropriate in delivering the work. EDF Energy will seek to influence was suggested that this could draw on international contractors to invest in the community, so that socio-economic benefits can be realised. data from similar projects to gain better understanding EDF Energy has commissioned the services of technical experts with experience of delivery lasting community of impacts. benefits from major infrastructure projects. The experience and knowledge of these professionals will be built upon to create a well trained workforce throughout the supply chain who are economically active in the community.
Additional benefits Stage 2 consultation sets out how EDF Energy seeks to minimise the impact of the development on local people as well as provide positive opportunities for the wider area. Further information needed on additional benefits associated with the supply chain initiatives and how benefits might reduce the physical impacts associated with the development.
172 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 29) Benefits to the Community Comments EDF Energy Response
What is provided as planning mitigation and that which EDF Energy has prepared a document setting out its Proposed Planning Requirements and Obligations as part adds value to the community? of this Stage 2 consultation. The document sets out a number of proposed commitments that would accompany the grant of consent for the development of the power station and associated development. To inform its approach to these issues, EDF Energy has been greatly assisted by the response to the Stage 1 consultation and by its engagement with a wide range of stakeholders. The proposed commitments have also been closely informed by the results of environmental and other assessments. EDF Energy is bound by planning guidance to ensure that its application is considered entirely on its own merits and that any obligations or requirements are necessary, relevant to planning and directly related to the development itself and its likely effects. EDF Energy’s approach has also been guided by its determination to ensure that the development of Hinkley Point C would respect and integrate as far as possible with the local community both during the construction and operation of the power station. EDF Energy recognises the potential for the development to bring significant prosperity to the area and will strive to maximise the inherent potential of its investment to the benefit of the local economy. Its proposed planning requirements and commitments, therefore, are aimed at mitigating the effects of its development in a way which respects the interests of the local community and maximises the local benefits which the development can bring to West Somerset, Sedgemoor and Somerset as a whole.
A comprehensive package of measures should be The Proposed Planning Requirements and Obligations document sets out a wide ranging package of measures developed designed to address the effects of the development and operation of Hinkley Point C and to harness the benefits which its investment can bring to the local area. The package covers all relevant aspects of the Comment was also made on how the package would be development and touches on a wide range of investment and service provision. The commitments set out in administered and the intended distribution of provision. the document will be legally secured either as planning requirements in the DCO itself or, in a deed of development consent obligations entered into by EDF Energy prior to the grant of development consent.
Developing the package through consultation The Proposed Planning Requirements and Obligations document is intended to be further developed through discussion with all relevant stakeholders. It has already been significantly informed by consultation but EDF In order to provide positive outcomes and an Energy recognises that significant further discussion will help to improve the document and ensure that it is appropriate package which identifies local aspirations properly suited to mitigate the impacts and enhance the benefits of the development. and initiatives.
How the package would complement economic The development of Hinkley Point C is forecast to inject at least £100 million per annum into the local economy
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 173 STAGE 1 CONSULTATION REPORT
29) Benefits to the Community Comments EDF Energy Response regeneration during construction and £40 million per annum during operation. In addition, the proposed package of commitments includes comprehensive Procurement, Education and Training strategies which seek to ensure that maximum local benefit is achieved both from the capital investment and from the continuing revenue generated by the development.
Potential legacy benefits for the community from the EDF Energy expects that the development and operation of Hinkley Point C will play a significant role in project boosting the local economy and providing it with a more stable base for the future. As well as the development providing job opportunities for local people, some elements of the infrastructure and associated developments Including the use of facilities, accommodation, will remain once construction of the power station is complete. landscaping and park and ride facilities. EDF Energy is unable to provide preferential tariffs due to Ofgem regulations which have been in place since It was suggested that EDF Energy could provide cheaper July 2009. electricity tariffs for those living in the areas most affected by the proposals.
Respondents suggested a full assessment of the social The Environmental Impact Assessment has had regard to all relevant social and community issues and the and community infrastructure requirements of the Proposed Planning Requirements and Obligations set out a series of measures aimed at ensuring that all development significant impacts are addressed. Comprehensive assessments of health, welfare and housing requirements have been undertaken to inform this approach. Including: transport and road improvements; schools; leisure facilities; environmental measures (e.g. flooding, habitats creation and footpath provision); emergency services; skills and training; economic benefits; community funds; and specific mitigation for local impacts.
More detail on the package should be provided The Proposed Planning Requirements and Obligations document sets out clearly the package of commitments proposed. The package is intended, however, to inform this consultation and it will continue to be refined with the benefit of responses to the Stage 2 consultation and continued engagement with stakeholders.
174 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 29) Benefits to the Community Comments EDF Energy Response
Provision of community fund arrangements The Proposed Planning Requirements and Obligations document sets out EDF Energy’s proposals for a Community Fund which would be administered by and on behalf of the community with the intention that it would be used to progressively improve local amenities. The Fund is intended to recognise that there may be some residual impacts which cannot be addressed even by the comprehensive package that has been proposed.
Package of measures developed to offset the The Proposed Planning Requirements and Obligations document sets out EDF Energy’s proposals for a consequences of hosting the nuclear power plant and Community Fund which would be used to mitigate the residual impacts of the Hinkley Point C Project on the interim waste storage communities closest to the development. EDF Energy believes firmly that Hinkley Point C will be a major asset for the local community as well as for the country as a whole.
Need to be convinced of the advantages of community All respondents will reach their own view on the balance of advantage and impact arising from the benefits package outweighing the disadvantages of the development. EDF Energy’s Stage 2 consultation provides detailed evidence of both. Overall, the Hinkley Point project C Project is expected to contribute 6% of the UK’s electricity requirements and respond to an urgent national need for low carbon energy. At the same time it will generate very substantial economic benefits for the local area whilst fully mitigating its impacts.
ISSUES NOT DIRECTLY RELATED TO THE PROPOSALS
30) Nuclear Energy & Principle of Development Comments EDF Energy Response
Generation of energy from nuclear power and the Responses have been provided in previous sections above to address comments relating to ensuring safety, principle of developing new nuclear at the Hinkley Point sufficient environmental standards and pressures of the development. The timely deployment of new nuclear site energy is a Government-led approach. Hinkley Point C is identified in the draft Nuclear NPS as a potentially suitable site for a nuclear power station and the proposals for both the main site and associated development General support subject to demonstrating safe practice, are brought forward in line with policy and to fulfil regulatory requirements. sufficient environmental standards and addressing pressures from the development e.g. size of development required and the potential impact from associated development. Query raised regarding the role of nuclear power as a viable energy source.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 175 STAGE 1 CONSULTATION REPORT
ISSUES NOT DIRECTLY RELATED TO THE PROPOSALS
Lack of planning strategy at Stage 1 In response to this, a Preferred Proposals: Explanation and Assessment is provided as part of the Stage 2 consultation which describes the justification for development and the strategies that underpin the construction and operation of the proposals. The Preferred Proposals: Explanation and Assessment looks to the other Stage 2 documents in order to address the technical detail of the strategies outlined and pull together the proposals both on and off-site.
31) Submission Documentation Comments EDF Energy Response
Documents recommended for submission in support of Documents to be submitted to support the DCO application will meet the requirements of the Planning Act the DCO application 2008 and additional relevant documents recommended at Stage 1. Information on these topics is provided for the purposes of Stage 2 consultation. Additional provision of the following documents requested: a statement on the Transport Assessment; Travel Plan; Environmental Management Plan; Construction Environmental Management Plan; Economic Assessment; Training and Procurement Strategy and draft Development Consent Obligations. Advised to undertake an Environmental Impact Assessment and Sustainability Appraisal.
32) Stage 1 Consultation Comments EDF Energy Response
Limited level of detailed information and evidence in Stage 1 consultation outlined the proposals and options at a time when the proposals were still being drawn support of consultation up. This provided an early opportunity for stakeholders to be engaged in the development process, in line with published Government guidance. Stage 2 consultation presents EDF Energy’s Preferred Proposals which address further technical and environmental information available and makes the appropriate response to Stage 1. Consultation has been ongoing with various stakeholders on the key issues during the interim period between Stage 1 and Stage 2 consultation, and will continue through to the submission of the DCO application. There will also be a chance for stakeholders to provide their views as part of the IPC process.
176 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT ISSUES NOT DIRECTLY RELATED TO THE PROPOSALS
Underestimated significance of each individual project EDF Energy’s proposals are complex and as a result due consideration and care has been given to every element at Stage 1 element of the project in order to provide a development which meets the requirements of planning and other regulatory regimes. These are evident within the other Stage 2 documents provided, including the Environmental Appraisal and Masterplans.
Little evidence of consultation and engagement Consultation with key statutory consultees, outside the two formal stages of consultation has been ongoing and iterative. A number of consultees noted this and welcomed how the consultation process has been Particularly in relation to tourism. Some felt that the handled, including time extension due to inclement weather. consultation was held too late and was invalid due to the proposed options having already been decided on Public consultation has been extensive, as evidenced by the number of exhibitions and meetings attended by before the consultation period. members of the public. The public consultation process was widely promoted through the project website, newsletters distributed to over 35,000 households locally, through media coverage and by advertising. Community representatives were contacted directly and invited to participate in the Stage 1 consultation process, including groups representing the tourism industry. EDF Energy believes that the consultation has allowed for direct influence from consultees into the development proposals and environmental and technical assessment.
Consultation methodology and extent of engagement Independent market research was undertaken to measure the reaction of members of the public visiting the EDF Energy exhibitions. Exit interviews were conducted at all nine of the public exhibitions held during the Comments on the use of public exhibitions with limited Stage 1 consultation. The results showed a generally positive reaction with 93% of respondents saying information and unrepresentative graphics. information at the exhibitions was very or quite easy to follow. 95% of respondents considered that the Consultation was premature in advance of the Nuclear information panels/boards available at the exhibition were either very or quite useful. NPS designation. Engagement with all the local communities potentially affected by the proposals was Detailed supporting information to the summary material available on the exhibitions boards was also not broad enough. available for public inspection at each exhibition. Full consultation material was provided on the project website. Generally respondents supported the way in which consultation was handled and the team listening to local community concerns. Consultation took place across a wide geographical area stretching from Weston-super-Mare in the north, Taunton in the south and Minehead to the west. The consultation zones set out in EDF Energy’s Statement of Community Consultation (SOCC) published in November 2009 were designed to ensure that all local communities potentially affected were consulted. These zones were also the subject of detailed discussion with Somerset County Council, West Somerset Council and Sedgemoor District Council during consultation on
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 177 STAGE 1 CONSULTATION REPORT
ISSUES NOT DIRECTLY RELATED TO THE PROPOSALS the preparation of the SOCC. The consultation on the Nuclear National Planning Statement (NPS) ran from November 2009 to February 2010. Whilst EDF Energy’s Stage 1 consultation took place before the consultation on the NPS had finished, Stage 2 consultation is commencing well after the end of the NPS consultation period. There is no legal requirement or guidance that states that promoters of NSIPs (Nationally Significant Infrastructure Projects) should delay consultation in this way. The Planning Act 2008 in fact makes provision for applications to be decided where no NPS has been designated. The IPC has been open to receive energy generation project applications since March 2010.
Public Consultation Questionnaire The questionnaire was designed to provide some structure and guidance for the local community responding to the consultation. Space was provided throughout the questionnaire for respondents to give their general Comments related to format e.g. lack of ‘neither’ option comments or to elaborate on answers to the questions. response, and suggestion of language pertaining to pre- empted decisions which were being consulted on.
33) Further Consultation Comment EDF Energy Response
Further consultation and engagement encouraged The ongoing dialogue being held with key statutory bodies and local stakeholders between Stage 1 and 2 has helped to inform the development proposals. Engagement will continue informally as EDF Energy progresses Respondents requested more focused consultation with toward the DCO application and Stage 2 responses will be taken into account alongside those comments specific organisations and areas affected, and the provided at Stage 1. continued working of established liaison groups. EDF Energy believes that good levels of engagement at Stage 1 were achieved with those affected by its
proposals. Nevertheless, the Company has discussed the outcomes of the Stage 1 consultation in detail with Further consultation was also recommended with more the local Councils and identified a number of areas where engagement might be improved during the Stage 2 of the local community. consultation. These improvements are identified in EDF Energy’s Hinkley Point C: Stage 2 Consultation Strategy and Revised Statement of Community Consultation published on 29 June 2010.
No ‘new’ options should be proposed at Stage 2 The development proposals have evolved as a result of consultation. In most cases options for development consultation being proposed at Stage 2 have taken sites proposed at Stage 1 forward. However, in some cases development is proposed on alternative sites for associated development as a result of further consultation.
178 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 STAGE 1 CONSULTATION REPORT 6 CONCLUSIONS
6.1.1 In conclusion, EDF Energy has carefully considered the responses received to its Stage 1 consultation. Where EDF Energy has chosen to make possible and appropriate changes it has stated clearly where a suggestion from stakeholders has led to that change. Where EDF Energy has chosen not to adopt a suggestion in its Stage 2 proposals it has indicated clearly why this is the case. 6.1.2 It is important to note that, as EDF Energy expected, some respondents took the opportunity to make a wide range of comments on other important issues associated with new nuclear build. Whilst these comments were not directed to assist with this consultation EDF Energy has nevertheless considered them all and all of these comments are included in this document. 6.1.3 In terms of next steps once EDF Energy has fully consulted on its Stage 2 Preferred Proposals consultation it will carefully consider responses received and will compile an additional volume to this document. When EDF Energy submits its application to the IPC this coming winter it will do so along with a final Report on Consultation Document so that stakeholders can see where their views have shaped EDF Energy’s final proposals.
HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 | 179 STAGE 1 CONSULTATION REPORT
| HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 2 180 STAGE 1 CONSULTATION REPORT
Appendix A.1
STATEMENT OF COMMUNITY CONSULTATION (NOVEMBER 2009)
Plans for Nuclear New Build at Hinkley Point, Somerset
Statement of Community Consultation [Published under section 47(6) of the Planning Act 2008]
November 2009
Final Published Statement of Community Consultation November 2009
1. This Statement of Community Consultation
EDF Energy is proposing to submit an application for a Development Consent Order (DCO) for a new nuclear power station, to be known as Hinkley Point C, with two nuclear generating units and associated on and off-site development. This application will be made under the Planning Act 2008.
The Act requires us to undertake public consultation in advance of submission of the DCO application to the Infrastructure Planning Commission (IPC). A Statement of Community Consultation (SOCC) must be prepared, setting out how we propose to consult people living in the vicinity of the land about the proposed DCO application.
As required by the Act, we consulted West Somerset Council, Sedgemoor District Council and Somerset County Council about this SOCC during July - October 2009. Their responses have been taken into account in this published document. In addition, we will be consulting these authorities and other statutory consultees on our proposals in parallel under a separate process.
We have also entered into a Planning Performance Agreement (PPA) with these local authorities, which will enable them more effectively to assess our proposals and to facilitate the consultation process.
EDF Energy will carry out pre-application consultation in accordance with this SOCC and is committed to being open and transparent in all its dealings with the local community and key stakeholders throughout the pre-application consultation process.
2. Proposal Summary Document
Full details of the first stage of public consultation and of EDF Energy’s initial proposals and options for the Hinkley Point C development will be published on 16th November 2009 in a Proposal Summary Document (PSD) that will be available, without charge, from the following sources:
· All 34 public libraries and 6 mobile libraries in Somerset · West Somerset Council offices at: West Somerset House, Killick Way, Williton, TA4 4QA; Harbour Masters Office, The Esplanade, Watchet, TA23 0AJ; and Harbour Masters Office, Quay Street, Minehead, TA24 5UL · Sedgemoor District Council offices at Bridgwater House, King Square, Bridgwater, TA6 3AR · Somerset County Council offices at County Hall, Taunton, TA1 4DY · Tourist Information Offices at: Bridgwater House, King Square, Bridgwater, TA6 9ZY; South Esplanade, Burnham-on-Sea, TA8 1BU; Sedgemoor Services, M5 South, Rooksbridge, Axbridge, BS26 2UF; and Warren Road, Minehead, TA24 5BG · EDF Energy’s office at 14 King Square, Bridgwater, TA6 3DG · Downloadable from the project website at www.edfconsultation.info · By email, [email protected] · By calling our freephone information line on 0800 169 6507 · By writing to FREEPOST CONSULTATION RESPONSE (no further address or stamp required).
A similar document will also be produced for the second stage of our consultation process. Consultation events will be advertised in local newspapers and copies of the PSD will be available to the public at all these events.
2 Final Published Statement of Community Consultation November 2009
3. EDF Energy and Hinkley Point
EDF Energy nominated land at Hinkley Point, close to the existing B power station, for new nuclear power development in March 2009.
Extensive public consultation was undertaken during 2008 about this proposed nomination of land at Hinkley Point. The consultation process provided EDF Energy with valuable feedback on its proposals, highlighted key issues and options to be considered and helped with the design of the next phase of the consultation as set out in this SOCC.
Further details of the new build project, the previous consultation process and information about the European Pressurised Reactor technology that is proposed for Hinkley Point, are available on the website, www.edfconsultation.info
4. Context of the consultation
EDF Energy is aware of a number of related consultations to be undertaken by the Government, local authorities, statutory agencies and other organisations that will have a bearing on our plans for Hinkley Point C.
EDF Energy recognises the importance of ensuring that the timing and content of our consultation has due regard to other related consultation events to avoid confusing the public and local stakeholders and to minimise the risk of “consultation fatigue”.
For example, consultation on a draft National Policy Statement (NPS) on nuclear power is expected during the autumn of 2009 and this will specify where new nuclear power stations may be located. Assuming the Government sticks to this timetable, we expect to start our consultation events after local consultation events on the draft NPS have taken place.
Other relevant forthcoming consultations that EDF Energy is aware of include:
· Somerset County Council’s consultation with the local community on its waste strategy, including nuclear waste, during autumn of 2009. · The Environment Agency’s consultation, from October 2009, on the draft North Devon and Somerset Shoreline Management Plan and on the realignment of the Steart Peninsula near Hinkley Point. · National Grid’s first and second stage of public consultation on plans to reinforce and upgrade power lines between Bridgwater and Avonmouth, to accommodate a new nuclear power station and other planned new power generation facilities, during the autumn of 2009 and the winter of 2010.
A full list of consultations notified to EDF Energy is shown at Appendix 1.
EDF Energy will work closely with the three Somerset local authorities and other organisations to ensure that our consultation programme on future plans for Hinkley Point C is carefully co- ordinated with relevant local consultations.
5. What the consultation is about?
We will report the views of the public and stakeholders, whether or not these are within the scope of our consultation exercise.
3 Final Published Statement of Community Consultation November 2009
Scope of the consultation
This consultation will be about EDF Energy’s site-specific plans for Hinkley Point C and directly related associated development including, for example: proposed highway improvements; campuses providing accommodation and facilities for construction workers; potential park and ride sites; and freight concentration depots.
The consultation will cover all of the issues required by the Planning Act 2008 and its supporting regulations and guidance.
We will therefore be seeking the views of the public and key stakeholders on the following:
· Proposals for the main power station development at Hinkley Point · Infrastructure proposals away from the main site considered necessary to support the construction and operation of the power station.
We will be seeking public and stakeholder comment, first on our ‘Initial Proposals and Options’, and, at a later stage, on our ‘Preferred Proposals’.
We will be seeking views on ways of ensuring that the local community makes the most of the social and economic benefits from the development of new nuclear power at Hinkley Point, if permission is granted, including, for example, inward investment into Somerset.
The consultation will also invite views on related community benefits, for example support for local infrastructure such as schools, medical and social facilities, and how these benefits might be channelled to the affected areas.
The Act specifies that we must consult on our proposals for a minimum of 28 days. We believe that this period of time is insufficient given the scale of our plans and we will therefore allow a formal period of approximately seven weeks for each stage of our consultation process.
EDF Energy will continue to engage with the community, local authorities and other key stakeholders both before and after this formal consultation period.
Environmental information
EDF Energy’s proposed DCO application is an Environmental Impact Assessment (EIA) development.
As part of the pre-application consultation process, we propose to make available to the general public and stakeholders the preliminary environmental information that we have available in relation to the proposals. EDF Energy will publish an Environmental Status Report as an appendix to its stage one consultation document on “Initial Proposals and Options.” This report will summarise the environmental work undertaken to date, further studies proposed, and our preliminary view of the key issues. A draft Environmental Statement (ES) will be published as part of EDF Energy’s stage two consultation on our “Preferred Proposals”.
Once we have submitted our DCO application to the IPC, we will consult the public and statutory consultees on all application information, including the ES.
4 Final Published Statement of Community Consultation November 2009
Preliminary works
EDF Energy expects, entirely at its own risk, to submit planning applications under the Town and Country Planning Act 1990 and related marine legislation to prepare the site ready for the main development. West Somerset Council will consider these applications, which are outside the scope of this SOCC.
We have, however, agreed with West Somerset Council that we will consult the affected local communities and take their views into account before we finalise these preliminary works applications.
This consultation will be undertaken in parallel with stage one of our consultation on the main proposals to be considered by the IPC but will be clearly identified as part of a separate planning process. We will submit a Statement of Community Involvement with our preliminary works applications and this SCI will also be appended to our Consultation Report (CR) to be submitted to the IPC with the main application.
Other issues
The principle of whether or not there should be a new nuclear power station at Hinkley Point and health and safety issues are outside the scope of our consultation process.
The Government will specify which sites are suitable for new nuclear power stations when it publishes its NPS on nuclear power, which will be subject to public consultation and detailed Parliamentary scrutiny under sections 5-13 of the Planning Act 2008.
The safety and security of the European Pressurised Water Reactor (EPR) that we are proposing to build at Hinkley Point C will be considered under a separate approval process – the Generic Design Assessment (GDA) and the nuclear site licensing process. The GDA is currently being undertaken jointly by the Health & Safety Executive (HSE) and Environment Agency (EA).
6. Consultation strategy
Our pre-application consultation programme will be undertaken in two stages:
· Stage One: We will consult first on our ‘Initial Proposals and Options’. We will set out our broad plans for the new nuclear power station and associated development, identifying for public comment our preferred proposals and highlighting options on which will be seeking views. · Stage Two: Having considered the response to public consultation on our ‘Initial Proposals and Options’, we will then publish our ‘Preferred Proposals’ for consideration.
We will allow a period of time at the end of each stage of the consultation process to consider the responses received before moving onto the next stage of the process.
EDF Energy plans to submit its DCO application for Hinkley Point C to the IPC in July 2010.
5 Final Published Statement of Community Consultation November 2009
7. Who will we consult?
EDF Energy is required, under section 47 of the Act, to consult people living in the vicinity of the land we propose to develop, both at Hinkley Point and other land further away that may be required for associated development.
In order to fulfil this duty, we will consult the public in three broad geographic zones around Hinkley Point C, shown on the map at Appendix 2. These public consultation zones are defined approximately as follows:
· Inner zone: within approximately a 5-mile radius of Hinkley Point C including the West Somerset parishes of Holford, Kilve, Stogursey and Stringston, and within Sedgemoor District the parishes of Cannington, Fiddington, Nether Stowey, Otterhampton and Stockland Bristol · Middle zone: encompassed by Burnham-on-Sea in the north, the M5 to the east (but including Puriton), south of Bridgwater and along the Quantock hills as far as Williton/Watchet · Outer zone: stretching around Taunton to the south, Minehead to the west, Weston-super- Mare to the north and to the west of the M5.
The most intensive public consultation will be within the ‘inner zone’ in the area immediately surrounding Hinkley Point C, with slightly less intensive consultation in a ‘middle zone’ encompassing Bridgwater, and predominantly stakeholder events further away in the ‘outer zone’ covering Taunton, Minehead and Weston-super-Mare.
Our proposals may include some associated development outside the ‘inner zone’. We will hold public consultation events in the vicinity of these sites.
In line with published government guidance, we intend to take a broad view of our duty to consult under section 47 of the Act and will, therefore, also consult with:
· Parish and Town Councils, particularly within the ‘inner’ and ‘middle’ consultation zones defined above · Hard to reach groups including those in wards identified as having very high levels of deprivation, young people (via local educational establishments) and key ethnic minorities highlighted by the local authorities · Organisations representing the business community, local tourism industry and visitors to the area · Other relevant community groups or organisations with an interest in our plans.
Although outside the scope of this SOCC, we are also required to consult the following under section 42 of the Act:
· Statutory consultees as specified in regulations, including regional stakeholders such as the Government Office for the South West (GOSW), the South West Regional Development Agency (SWRDA) and South West Councils (SWC) · The three relevant local authorities – West Somerset Council, Sedgemoor District Council and Somerset County Council – within whose boundaries our development proposals fall · All neighbouring local authorities that share a boundary with these three local authorities including Exmoor National Park authority · Owners, lessees, tenants and occupiers of land within the areas we propose to develop.
6 Final Published Statement of Community Consultation November 2009
We also intend to consult with:
· Other key stakeholders including the Area of Outstanding Natural Beauty (AONB) teams for the Quantock and Mendip hills, the Somerset Strategic Partnership and Local Strategic Partnerships, the existing Hinkley Point Site Stakeholder Group (SSG), business groups, including IntoSomerset, and environmental groups. · Bristol City Council, South Gloucestershire Council and the Vale of Glamorgan Council, local authorities who do not have adjacent boundaries but who may be indirectly affected by the proposals.
A map showing the local authorities we intend to consult is shown at Appendix 3.
8. How will we consult?
EDF Energy will hold a range of consultation events and use a variety of communication techniques to ensure that the public and stakeholders have an opportunity to comment on proposals for the development of Hinkley Point C.
We will also work closely with the relevant local authorities and other organisations, such as Planning Aid South West, to identify and engage with those whose voices are rarely heard in the planning process using techniques that don’t rely solely on the written word.
Consultation methods
We are planning the following consultation methods for engaging with the public and stakeholders:
· Residents meetings: where appropriate we will invite people living in the immediate vicinity of the site, or near major infrastructure works to meet with our project team to discuss the plans at times and locations to suit their needs · Parish/Town council meetings: we will offer to attend meetings of Parish Councils near the site (i.e. within the ‘inner zone’) and selected parish and town councils within the ‘middle zone’ (including Burnham-on-Sea and Bridgwater). We will also offer to meet with West Somerset’s Area Panels and Sedgemoor District’s Parish Cluster Areas · Council/stakeholder meetings: we will offer to attend meetings of local authorities including the three relevant Somerset councils, Exmoor National Park and local strategic partnerships · Public exhibitions: we will hold public exhibitions at appropriate locations during both stages of our consultation process. These exhibitions will take place over an afternoon/evening, or on a Saturday, and will be staffed by members of the project team. We will also send invitations to these events to representatives of the business community, the tourism industry and ‘hard to reach’ groups. · ‘Drop In’ centre: we will open the EDF Energy office in Bridgwater to the public during the whole consultation period so that people can ‘drop in’ during specified office hours to view and comment on our proposals · Stakeholder meetings and workshops: during stage two of our consultation, we will invite key stakeholders to meetings and workshops to discuss in detail, with members of the project team, our ‘Preferred Proposals’ · Community Forum: we have established a Community Forum to consider issues relating to the development of new nuclear power at Hinkley Point. Local community leaders and other key stakeholders are invited to attend its meetings and we will ensure that the Forum reviews and responds to our consultation process
7 Final Published Statement of Community Consultation November 2009
· Focus groups: during stage two of our consultation, we will arrange focus groups to discuss the plans with ‘hard to reach’ groups identified by the relevant local authorities and other organisations with experience in this area.
Other communication techniques
We intend to use the following communication techniques to explain our proposals to the local community and stakeholders, advertise the consultation events, obtain feedback and publicise the outcome of the consultation process:
· Newsletters: we will distribute our newsletter ‘Hinkley Point – News from EDF Energy’ to the community and key stakeholders during both stages of the consultation process. The newsletters will summarise EDF Energy’s proposals, set out the scope of the consultation, advertise the main consultation events and report back on the outcome of the process. Distribution will be by post to households within the ‘inner zone’, by insertion in local newspapers in the ‘middle zone’ and by post to all the local stakeholders we have identified. The newsletter will also be placed on our website and we will arrange distribution through council offices and tourist information points · Website: we will continue to provide information about Hinkley Point C on our website, www.edfconsultation.info The website will explain what we are consulting about, advertise the consultation events and allow people to submit their comments on-line via an enquiry form or questionnaire linked to the public exhibitions · Questionnaire/comments form: we will provide a questionnaire or comments form for the public to record views when they attend our exhibitions or visit the ‘Drop In’ centre. They will be able to complete the questionnaire/comments form by hand at the exhibitions, return it to a ‘Freepost’ address, fill it out at a computer terminal at the exhibitions, or complete it on-line via the website · Direct communications: we will send information directly via post and email to key local stakeholders we have identified and to members of the public who have asked to be kept in touch with our plans · Summary documents: we will prepare non-technical summaries of what we are consulting about at the beginning of each stage of the consultation process. We will distribute these documents to key local stakeholders, make them available at all our consultation events and ask for copies to be displayed at public libraries, council offices and tourist information centres. They will also be available to download from the website. · Media and advertising: we will advertise public exhibition dates, times and venues for both stages of our consultation process in local newspapers and seek media coverage of the main public consultation events. We will also advertise details of the proposed DCO application in local newspapers · Freephone and freepost: we will provide a freephone information line during normal office hours to allow members of the public to find out more information and make their views known. A freepost facility will also be provided.
9. How will we respond to the consultation?
EDF Energy and its project team will consider carefully and respond to all issues raised during the pre-application consultation period.
We will publish a Consultation Report (CR) at the end of the process that will:
· Provide a general description of our consultation process · Set out how we have complied with the Act and its related guidance
8 Final Published Statement of Community Consultation November 2009
· Explain how we have taken into account any response to consultation with the relevant local authorities about the SOCC · Summarise the responses to the consultation · Describe how the DCO application has been influenced by these responses and any changes we have made as a consequence · Explain why any changes haven’t been made in response to significant and relevant comments · Explain where and why we have not followed the advice of the relevant local authorities or specific guidance published by the IPC.
EDF Energy acknowledges the importance of giving feedback to those who have contributed to the consultation. We will ensure that the outcomes of the consultation process are fed back to the local community, key stakeholders and statutory consultees by:
· Publishing the CR and submitting it to the relevant local authorities · Providing a downloadable copy on the website · Providing copies to public libraries and council information points in Somerset · Communicating directly with identified local stakeholders and statutory consultees to notify them of publication of the CR · Notifying the local media of publication of the CR · Producing and distributing newsletters that summarise and report back on the consultation process · Holding meetings of our Community Forum and meeting, if required, with local residents, Parish Councils and other local authorities.
10. Consultation timetable
A planned timetable for the two stages of the consultation is shown below. No major public-facing consultation events will be held during the Christmas and New Year holiday period. Month/period Consultation activities November - December · Formal start of stage one consultation process on 16th 2009 November · Publication of ‘Initial Proposals and Options’ summary document · Publication of ‘Hinkley Point – News from EDF Energy’, publicising the stage one public consultation programme · Meetings with local residents, Parish/Town Councils, key stakeholders and community groups · Public exhibitions at relevant locations · Community Forum meeting January – February · Formal close of stage one consultation process on 11th January 2010 · Consideration of response to stage one consultation · Publication of ‘Hinkley Point – News from EDF Energy’, reporting back on outcome of stage one consultation process · Meetings with local residents, Parish/Town Councils, key stakeholders and community groups March – April 2010 · Formal start of stage two consultation process in mid March · Publication of Proposal Summary Document · Publication of ‘Hinkley Point – News from EDF Energy’, publicising the stage two consultation programme · Public exhibitions in ‘inner’ and ‘middle’ consultation zones · Stakeholder workshops
9 Final Published Statement of Community Consultation November 2009
· Focus groups · Community Forum meeting May – June 2010 · Formal close of stage two consultation process in mid May · Consideration of responses to stage two consultation · Publication of ‘Hinkley Point – News from EDF Energy’, reporting back on outcome of stage two consultation process · Meetings with local residents, Parish/Town Councils, key stakeholders and community groups · Community Forum meeting July 2010 · Publication of Consultation Report (CR) and submission of application to the IPC taking into account responses to consultation.
The dates of consultation events will be publicised at the start of each stage of the consultation process and will, wherever possible, be co-ordinated with other relevant local consultation activities.
11. Further information
Further information on EDF Energy and our pre-application consultation process on plans for Hinkley Point C can be obtained:
· From the EDF Energy office in Bridgwater: 14 Kings Square, Bridgwater, Somerset, TA6 3DG, Tel: 01278 444600, Fax: 01278 445983 · On the website www.edfconsultation.info · By calling our freephone telephone 0800 169 6507 (during normal office hours)* · By writing to Freepost Consultation Response (no stamp or full address is required)*.
*These contact details will put you in touch with PPS who are managing the public consultation programme on behalf of EDF Energy
10 Final Published Statement of Community Consultation November 2009
Appendix 1: Related Consultations
The table below shows related consultations that EDF Energy is aware of and will take into account in the detailed planning and presentation of its pre-application consultation for the DCO application for new nuclear development at Hinkley Point C.
Dates Consultation subject Who is being Consultation owner consulted? To November Sedgemoor District Council Public/stakeholders/ Sedgemoor District 2009 Core Strategy Preferred statutory consultees Council Options To November Waste Strategy Preferred Public/stakeholders/ Somerset County 2009 Options (including nuclear statutory consultees Council waste issues) To December National Grid Consultation Public/stakeholders/ National Grid 2009 on Route Corridor Options statutory consultees for Overhead Line Connection between Bridgwater and Avonmouth To December North Devon and Somerset Public/stakeholders/ North Devon and 2009 Shoreline Management Plan statutory consultees Somerset Coastal Advisory Group/Environment Agency To February The Government’s Nuclear Public/stakeholders/ Department of Energy 2010 (estimated) National Policy Statement statutory consultees and Climate Change (Office for Nuclear Development) January-March National Grid Consultation Public/stakeholders/ National Grid 2010 on Preferred Route statutory consultees Corridor/Route Alignment for Overhead Line Connection between Bridgwater and Avonmouth
11 Final Published Statement of Community Consultation November 2009
Appendix 2: Hinkley Point Consultation Zones
12 Final Published Statement of Community Consultation November 2009
Appendix 3: Local Authority Consultation Map [To be consulted under section 42 of the Act]
13
Appendix A.2
EXHIBITION BOARDS
Hinkley Point C: Consultation on Initial Proposals and Options
Why Nuclear?
The Government has decided that new nuclear power stations should have a role generating low carbon electricity for the UK in the future.
All but one of the UK’s existing nuclear power stations are due to close by 2023 and some coal and oil fired power stations will have to shut down due to stricter environmental regulations.
Why Hinkley Point?
The Government’s recently published draft National Policy Statement on nuclear power identifies EDF Energy’s site at Hinkley Point as suitable, in principle, for a new nuclear power station. Hinkley Point C architect’s indicative image
Other considerations include the following: Related Consultation • There have been nuclear power stations at Hinkley Point since 1965 • The Government has identified Hinkley Point • In 1990 permission was granted to build a as a potential site in the draft National Policy new nuclear reactor on part of the EDF Energy Statement (NPS) for nuclear power. site Consultation on the draft NPS will close on • EDF Energy consulted local communities in 22 February 2010. 2008 about its plans to nominate land at • In order to connect Hinkley Point C, Hinkley Point, close to the existing power National Grid needs to build a new 400,000 station, as part of the Government’s Strategic volt overhead line between Bridgwater and Siting Assessment. Seabank (Avonmouth) Substations. It also needs to modify the existing overhead lines A new nuclear power station at Hinkley Point in the immediate vicinity of Hinkley Point. could provide more than 6% of the UK’s National Grid is currently in the process of Hinkley Point A and B stations electricity. consulting on route corridor options (broad widths of land in which an overhead line could be routed). The closing date for comments is 8 January 2010.
www.edfconsultation.info This Consultation
We are seeking the views of people living in the vicinity of Hinkley Point and surrounding Potential area for cooling water communities on plans to build a new nuclear tunnels and associated infrastructure Potential area for power station. temporary jetty
This stage of the consultation is on the Initial Proposals and Options for Hinkley Point C and includes: Hinkley Point C development site: • Proposals for the main power station indicative boundary development • Associated development necessary to support the construction and operation of the power station • The local impacts and potential benefits for the community • Preliminary site works.
In addition to the information on these exhibition boards, an Initial Proposals and Aerial photograph of Hinkley Point Options Summary Document has been prepared to provide more detailed information on the Pre-Application Consultation Timetable for Hinkley Point C proposals outlined above. This document will also help you fill in the questionnaire. 9 November 2009 Publication of Statement of Community Consultation 16 November 2009 to Consultation on Stage 1: Initial Proposals and Options Copies are available at this exhibition or you 11 January 2010 can download it from the project website: www.edfconsultation.info/hinkleypoint. 16 November 2009 to Consultation on Preliminary Site Works 11 January 2010
February 2010 Submission of applications for Preliminary Site Works to West Somerset Council and the Marine and Fisheries Agency
Mid March to mid May 2010 Consultation on Stage 2: Preferred Proposals
July 2010 Submission of Development Consent Order application to the Infrastructure Planning Commission (IPC), including consultation report
www.edfconsultation.info Hinkley Point C Power Station
The Power Station
The proposed site is immediately to the west of the existing Hinkley Point power stations.
The key permanent components of the power station are:
• Main station buildings including the reactor buildings, fuel building, nuclear auxiliary building, turbine halls and ancillary buildings • Supporting infrastructure including cooling water tunnels and pump houses, fuel and waste management facilities, staff facilities, administration and stores Key • A public information centre to provide educational and visitor facilities A Reactor building G Turbine building • Access from the main Hinkley Point road and B Four safeguard buildings H Power transmission platform C Fuel building I Operator building on-site parking D Nuclear auxiliary building J Pumphouse building • A secondary emergency access road to the E Radioactive waste processing building K Outfall structure power station connecting to the Shurton Road F Emergency diesel generator building L Conventional electrical building to the south. Cut away drawing of a single UK EPR (illustrative layout) National Grid will be responsible for providing Technology Waste Management overhead power lines to connect a new on-site sub-station to transmission lines near Hinkley Hinkley Point C power station will incorporate New nuclear fuel will be handled in a fuel Point. two UK EPRs (pressurised water reactors) each building adjacent to each reactor. The spent fuel capable of generating around 1,630 megawatts removed during refuelling will be stored The power station will be bounded by security of electricity. Together, these units will supply underwater in a fuel pond, which will provide fencing and lighting. A new sea wall will be enough electricity for approximately 5 million cooling and radioactive shielding. constructed, incorporating the existing coastal homes. footpath. The spent fuel and higher-level radioactive Safety, environmental protection, technical and waste will be stored safely on-site, pending economic performance are at the forefront of despatch to a national disposal facility. the UK EPR design.
www.edfconsultation.info Hinkley Point C Power Station
(continued)
Construction Landscaping and Wildlife after Construction Footpaths
During construction, additional land at Hinkley Options for the long term use of some of the land Plans for the footpaths that cross the site are Point will be needed temporarily for: used temporarily during construction include: still being considered although some rights of • A campus for up to 700 construction workers • Earth embankments with planting to screen way will need to be closed or diverted. • Contractors’ working areas the development • Storage of spoil • Woodland and other planting to protect long Overall EDF Energy will: • Roads, fencing, lighting and security distance views and create new habitat • Maintain a coastal path during the majority of • A jetty. • Reinstatement of grass meadows the construction period • Reinstatement of streams • Provide new rights of way to the south of the • Creation of grass meadows and wetland areas. power station after construction.
Indicative architect’s image of new power station from public footpath near Shurton
Hinkley Point C completed development and restoration areas
www.edfconsultation.info Associated Development
The construction of a new nuclear power development to enable the construction and and a potential bypass for Cannington. station at Hinkley Point will require off-site operation of the new power station. development to facilitate the build programme Your views on these proposed locations and and future operation of the power station. Locations are being considered within the options will help us determine the best solutions identified search areas for worker accommodation, for the development we think is needed to build EDF Energy is proposing a package of associated park and ride, freight handling/storage facilities and operate a new nuclear power station.
Map showing proposed power station and indicative off-site development
www.edfconsultation.info Associated Development
(continued)
Cannington Bypass Options Initial Assessment Western route Eastern route • Approximately 1.5 kilometres in length • Approximately 3.5 kilometres in length The village of Cannington is on the main route • Junctions to connect into existing roads • Junctions to connect into existing roads and to Hinkley Point and we believe that a bypass • Speed limit of 40 mph farm tracks will be needed. Two options are under • Landscaping and planting possible to screen • Speed limit of 60 mph consideration to link with the A39 from the road. • Road would need to be on an embankment existing Hinkley Point road. as it is in the floodplain.
Proposed Cannington bypass options
www.edfconsultation.info Associated Development
(continued)
Workers’ Accommodation We are also looking at ways in which the off-site • In Cannington accommodation might be utilised after the • At Junction 24 of the M5 on the southern Due to the number of people needed to construction period and welcome your views outskirts of Bridgwater construct a new nuclear power station, EDF and suggestions. • At Junction 23 of the M5, on the northern Energy is looking at areas in which to provide outskirts of Bridgwater workers’ accommodation. Park and Ride • In Williton.
Initial proposals are for: To help reduce the number of cars travelling on We have identified a number of possible locations • A 700-bed temporary campus with amenities local roads to and from Hinkley Point, EDF Energy for these sites. We will present the preferred at the Hinkley Point C site is proposing a total of four park and ride sites: options at the next stage of consultation. • A 200-bed campus with amenities near Cannington • Accommodation for up to 120 workers at Cannington College • Accommodation for up to 200 workers near Williton • Accommodation for up to 500 workers in Bridgwater • Existing owner-occupied and privately rented accommodation, including guesthouses and caravan parks.
Cannington – search areas M5 junction 23 – search areas
M5 junction 24 – search areas Bridgwater – search areas Williton – search areas
www.edfconsultation.info Associated Development
(continued)
Freight-Handling Facilities Handling/storage for freight by road: Handling/storage for freight by sea:
We are proposing a number of freight-handling A total of two facilities, one at Cannington and One facility near Cannington or at Combwich facilities to help reduce the amount of road another at a motorway junction (either junction deliveries to the site. Site options are being 23 or 24 of the M5) considered as part of this consultation process.
Cannington – search area J23-A – search area J23-B – search area J24-A – search area
J24-B – search area J24-C – search area Combwich – search area
www.edfconsultation.info Associated Development
(continued)
Combwich Wharf The Wharf was originally built to support the Combwich to Hinkley Point road to allow the existing Hinkley Point developments and will be transportation of abnormal loads EDF Energy is planning to use Combwich Wharf used for the delivery of abnormal loads and • Strengthening culverts along this section of to deliver bulky and abnormal loads during the bulky goods by sea. the road construction period. This will help reduce heavy • Possible improvements on the highway goods loads through Cannington and Road Improvements and Other Works network to accommodate increased traffic Bridgwater. and improve safety A number of road improvements and other • Potential removal and disposal of surplus We need to: works may also be required and EDF Energy is spoil from the site. • Strengthen and upgrade the existing Wharf currently discussing the need for these with the • Provide some storage areas for goods before local authorities. We are considering: Early studies indicate that a Bridgwater bypass they are transferred to the site. • Improvements which may be necessary to the is not necessary for the proposed development.
Indicative computer- generated images of upgraded Combwich Wharf
www.edfconsultation.info In The Community
EDF Energy recognises the contribution of the • Around 700 permanent jobs at Hinkley Point C community in hosting a new power station. We • Opportunities for local people for the will aim to provide a package of measures to thousands of jobs during construction minimise the impact and maximise the • Increased demand for local goods and benefits of development for the local services. community by ensuring: Skills and Training • A beneficial long term use for temporary developments where possible We are working with the relevant authorities to • That local people and businesses can take full develop: advantage of employment and commercial opportunities. • Training and recruitment policies to make it easier for local people to secure jobs EDF Energy project team The development of a new nuclear power • A procurement strategy to help local firms get station will have several potential benefits: involved in the supply chain and make a positive impact to economic development. • A legacy of improved infrastructure including the proposed Cannington bypass
Summer view from Quantock Hills with indicative montage of proposed buildings
www.edfconsultation.info Preliminary Works
Before construction can start on the new nuclear power station at Hinkley Point we need to prepare the site.
We therefore propose to apply for planning permission to undertake preliminary works before submitting our main application to the Infrastructure Planning Commission.
Planning and consents applications, as Indicative image of proposed temporary jetty looking west appropriate, will be made to the relevant authorities in early 2010 for these preliminary works. We are inviting views at this stage to inform our detailed plans before they are submitted. The local authority will carry out public consultation before deciding whether or not to give consent.
Should our applications be successful, all the preliminary work will be carried out at our risk. If permission for the new power station is Indicative image of proposed sea wall looking east refused then we will fully comply with any conditions to remove the works and restore On-Site Work Sea Wall the land. We propose undertaking on-site preliminary work In order to provide additional coastal protection Temporary Jetty to prepare for the development. This includes: we propose extending the sea wall in front of • Removing three existing barns the existing Hinkley Point power stations. We plan to bring in bulk materials required for • Removing existing hedgerows, woodland and construction by sea, docking at a temporary some grassland The existing coastal path will be incorporated jetty and connecting to an on-site storage • Undertaking drainage work into the new sea wall and access to the beach facility. • Fencing off the site for preliminary works will be provided. • Re-routing existing underground services This will reduce the number of vehicles on local • Diverting or closing some rights of way across The sea wall will be retained as a permanent roads during the construction process. the land feature of the construction. • Providing a site access road and internal The temporary jetty will be dismantled and roads suitable for construction traffic materials recycled at the end of its life. • Undertaking earthworks to form a series of terraces for the main construction.
www.edfconsultation.info Making Your Views Known
EDF Energy is seeking your comments or views Bridgwater Office on any aspects of our Initial Proposals and THE CLINK W
Options for the development of Hinkley Point C. You can drop in anytime during normal office QU AY C SE hours (9am to 5pm, Monday to Friday excluding LO How to Respond public holidays). You can find us at 14 King Square, Bridgwater, TA6 3DG. E T
A E
You can complete a questionnaire based on the G Q CAR W
TH OFFICE U R
key consultation questions set out in the Initial If you are interested in job opportunities in PARK O Q A N Y NDOS ST U CHA A Proposals and Options Summary Document. relation to this project, or are a potential Y K supplier of goods and services, please get in CA IN S G CASTLE ST ANGEL T S You can do this by: touch with the Bridgwater office. LE Q
M T
OAT S
• Completing the questionnaire here using the
CRES G’S PL computer terminals available Please remember that the deadline for you to KIN QUEEN • Taking home a paper copy and sending it back respond to this first stage of our public to us at “Freepost Consultation Response” in consultation is Monday, 11 January 2010. EDF Energy Bridgwater office the envelope provided (no further address or stamp is required) • Logging onto our website and completing it Timeline for related activities online: www.edfconsultation.info • Calling the EDF Energy Consultation line – 2007 2008 2009 2010 2011 2012 0800 169 6507 – and completing the questionnaire by speaking to one of our team. Government Consultation on White Paper on Draft Nuclear Nuclear National Policy the Future of Nuclear Power National Policy National Policy Nuclear Power Statement (and Statement Consultation on other energy designated SSA process NPSs)
EDF Energy Preliminary Nomination of Final Proposals Decision on Power Station consultation Hinkley Point and application development proposal and scope of to IPC consent environmental Initial impact proposals and options
National Grid Consultation on Consultation on Final proposals Decision on Network route corridor route alignment and application development Reinforcement options for new and preliminary to IPC consent 400kV environmental IPC = Infrastructure Planning Commission overhead line information NPS = National Policy Statement Cannington public meeting, September 2009 SSA = Strategic Siting Assessment
www.edfconsultation.info
Appendix A.3
QUESTIONNAIRE
Hinkley Point Initial Proposals and Options Questionnaire
EDF Energy is seeking your comments or views on any aspects of the Initial Proposals and Options for the development of Hinkley Point C.
This questionnaire is designed to be answered with the information in the Proposal Summary Document or at the exhibitions. There are a total of 12 questions but you do not need to answer all of these and if you would rather just submit a comment please go straight to question number 12 (page 10).
All comments for this first stage of consultation need to be received by 11 January 2010.
1. Do you agree that EDF Energy’s proposal to provide a landscape buffer on the southern boundary of the site is the best way of minimising the potential impact of the construction site for nearby local residents?
Yes No Don’t know
If yes, should this be retained as a permanent feature once construction is completed?
Yes No Don’t know
Any other ideas or comments?
EDF Energy Hinkley Point - Initial Proposals and Options Questionnaire Page 1 of 10 2. There are a number of options for the restoration of the site at the end of the construction phase. How would you rate the following options?
Potential benefit Very important Important Not important Not at all important Don’t know
Return land to its previous use
Creation of wildlife habitats
Grassland
Woodland
Any other ideas or comments?
3. Do you have any comments on the strategy for rights of way across the site during and following construction?
EDF Energy Hinkley Point - Initial Proposals and Options Questionnaire Page 2 of 10 4. What is your view on EDF Energy’s initial proposals for managing transport and accommodation during the construction phase?
Proposals Very satisfied Satisfied Not satisfied Not at all satisfied Don’t know
Transport
Accommodation
Any other ideas or comments?
5. We are proposing a bypass for Cannington. Do you think the road is needed? If so, should it go to the east or the west of the village?
Cannington bypass options East of the village West of the village Not required Don’t know
Transport
Please give reasons for your preference
EDF Energy Hinkley Point - Initial Proposals and Options Questionnaire Page 3 of 10 6. We are proposing a mix of solutions for accommodating construction workers. Please click below to indicate your preferences.
Option/site In favour Not in favour Don’t know
Temporary campus on-site for up to 700 workers
Campus accommodation on a site to the south of Cannington for up to 200 workers with potential long-term legacy uses including student accommodation, hotel or other
Additional campus accommodation at Cannington College for up to 120 workers, with long-term legacy benefits for the College
Campus accommodation at Williton for up to 200 workers, with the potential for long-term legacy benefits including a care home, hotel or other
Accommodation for up to 500 workers at one of several campuses in Bridgwater, with potential long-term legacy uses including student accommodation, hotel or other
Use of existing owner-occupied and privately rented accommodation, including guesthouses and caravan parks
Please give comments on your preferences and any suggestions about the future use of these facilities.
EDF Energy Hinkley Point - Initial Proposals and Options Questionnaire Page 4 of 10 7. What are your views on the four locations EDF Energy is proposing for the new park and ride sites? Please indicate your preferences below and with reference to the maps:
Cannington:
To the south of the village To the north-west of the village Neither and adjacent to the proposed workers’ campus
Junction 24 of the M5 on the southern outskirts of Bridgwater:
Location A Location B Location C
None of these
EDF Energy Hinkley Point - Initial Proposals and Options Questionnaire Page 5 of 10 Junction 23 of the M5 on the northern outskirts of Bridgwater:
Option 1 Option 2 Neither
Near Williton:
To the west of Williton To the east of Williton Neither
Do you think it would benefit the local community for these park and ride facilities to continue to operate once construction is complete and, if so, on which sites?
EDF Energy Hinkley Point - Initial Proposals and Options Questionnaire Page 6 of 10 8. What are your views on proposed freight handling facilities adjacent to some of the proposed park and ride sites and at Combwich? Please indicate your preferences below and with reference to the maps:
On the outskirts of Bridgwater:
North - near Junction 23 of the M5 South - near Junction 24 of the M5 Neither
Near Cannington:
North-west of the village South of the village adjacent to Neither adjacent to the C182 the A39
EDF Energy Hinkley Point - Initial Proposals and Options Questionnaire Page 7 of 10 At Combwich Wharf:
In favour Not in favour
What do you think of our proposals for the use of Combwich Wharf?
9. What are your views on EDF Energy’s general approach to community benefits and do you have any specific suggestions about what should be included in the package?
EDF Energy Hinkley Point - Initial Proposals and Options Questionnaire Page 8 of 10 10. Do you have any comments on our proposals in relation to training and business opportunities?
11. What are your views on our proposals for undertaking, at our own risk, preliminary works to get the site ready for construction?
Proposed development Very satisfied Satisfied Neither satisfied Not very Not satisfied Don’t know nor dissatisfied satisfied at all
Construction of temporary sea jetty
Construction of sea wall
Site preparation and earthworks
Any other ideas or comments
EDF Energy Hinkley Point - Initial Proposals and Options Questionnaire Page 9 of 10 12. Do you have any other comments about EDF Energy’s initial proposals for the development of a new nuclear power station at Hinkley Point?
Your Details
First Name:
Surname:
Email address:
Address:
Postcode:
If you would like to track your comments through this consultation process please enter your email address and a receipt with your reference number will be forwarded in due course.
If you do not have an email address but would like to track your comments, please tick here and we’ll post you a receipt.
Your comments will be analysed by PPS (Local & Regional) Ltd on behalf of EDF Energy. Copies may be made available, in due course, to the relevant planning authority so it can note your comments. We will, however, request that your personal details are not placed on the public record. Your personal details will be held securely by PPS and EDF Energy in accordance with the Data Protection Act 2000, will be used solely in connection with the consultation process and subsequent planning applications and, except as noted above, will not be passed to any third parties.
EDF Energy Hinkley Point - Initial Proposals and Options Questionnaire Page 10 of 10
Appendix A.4
EXHIBITION EXIT INTERVIEW REPORT
John Groves-Hill Managing Director 2 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 3 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Background and objectives
4 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Background and objectives
5 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Method
6 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Method
7 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Location of interview
Cannington, Village Hall 30%
Stogursey, Victory Hall 15%
Otterhampton, Otterhampton Village Hall 11%
Williton, Danesfield School 18%
South Bridgwater, Community Centre 5%
North Bridgwater, The Exchange 9%
Burnham-on-Sea, The Princess Theatre 6%
Base: Total sample (276) Bridgwater, EDF Energy Office 9%
8 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 9 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Key summary
10 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Age group and gender of respondent
16-24 0.4%
Male 25-34 3% 60%
35-44 9%
45-54 19%
Female 55-64 34% 40%
65-74 24%
75+ 10% Base: Total sample (276)
Refused 0.4%
11 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Q1: Length of time spent at exhibition today
Less than 10 13% minutes
11-15 minutes 9%
16-20 minutes 12%
21-30 minutes 20%
31-40 minutes 5%
41-50 minutes 7%
51-60 minutes 18%
More than 1 hour 15% Base: Total sample (276)
12 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Key summary
13 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Q2: How did you get to hear about this whole public consultation process? | Prompted
Significantly higher at Cannington, Newsletter/ mailing to home 42% Stogursey and Otterhampton
Local press - article 25% Significantly higher at Williton
Council office 11%
Word of mouth 11%
Local press - advert 6%
Brochure 4% Main mentions Website 4%
Other media - TV/ radio etc. 2%
Just passing 2%
Base: Total sample (276) Other 6%
14 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Q3: Overall, was the information you saw or heard at this exhibition today……. | Prompted
Very easy to follow (4) Quite easy to follow (3) Not very easy to follow (2) Not at all easy to follow (1) Mean Score (4-1) (Based on all those who No opinion were able to give a rating)
Was the information you saw or heard at 54 39 321 3.47 this exhibition today…..
% of respondents
Base: Total sample (276)
15 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Key summary
16 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Q4: How useful did you find each of the following areas or items of information? | Prompted
Very useful (4) Quite useful (3) Not very useful (2) Not at all useful (1) No opinion Did not view this Mean Score (4-1) (Based on all those who were able to give a rating)
The information panels or boards 44 45 8 121 3.36
The printed paper material such as 28 25 51 28 13 brochures and newsletters 3.36
The computer animated film 20 15 6 5 7 48 3.11
The scale model 26 28 18 7 6 16 2.93
% of respondents Base: Total sample (276)
17 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Q5: You said that you did not view one or more of the information areas or items that I’ve just read out, why was this? | Unprompted
Was not interested 33%
Not enough time 29%
Did not notice this/ them 10%
Had already seen this information 7%
No reason 6%
Too crowded 5%
Will look later/ at home 5%
Prefer to talk to people 3%
My questions were answered by the staff 3% there
Got information I needed from other areas 1% Base: All those who did not view any of the information areas/ items (157) Other 5%
18 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Key summary
19 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Q6: Did you complete a questionnaire about the EDF proposal here today and if so, was this online (using a laptop) or did you fill in a paper copy?
No 82%
Yes - laptop 4% Yes - paper 12% Will do it at home 3%
Base: Total sample (276)
20 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Q7: Do you plan to complete a questionnaire about the EDF proposal at some point in the near future? | Prompted
Yes, paper 65%
Yes, online 20%
No, do not plan to complete a 9% questionnaire
Yes, but not decided on method fo 4% filling it in
Not yet decided if I will complete 2%
Base: All those who had not completed a questionnaire Yes, phone in 0% about the EDF proposal (225)
21 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Q8: Did you talk to any members of the EDF Energy Project Team here today to get any information or help?
Yes 85%
No 15%
Base: Total sample (276)
22 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Q9: Overall, would you rate the EDF Energy staff that you spoke to…. | Prompted
Very helpful (4) Quite helpful (3) Not very helpful (2) Mean Score (4-1) (Based on all those who Not at all helpful (1) No opinion were able to give a rating)
Would you rate the EDF Energy staff that 70 20 6 13 3.64 you spoke to….
% of respondents
Base: All those who spoke to any members of the EDF Energy Project Team today (234)
23 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Key summary
24 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Q10: Overall, do you feel that as a result of your visit to the exhibition today you are ….. than you were before you visited? | Prompted
Much better informed about the proposals (3) A little better informed about the proposals (2) No better informed about the proposals (1) Mean Score (3-1) (Based on all those who No opinion were able to give a rating)
As a result of your visit 32 46 21 1 today, are you … 2.10
% of respondents
Base: Total sample (276)
25 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Q11: Finally, is there anything at all about this exhibition or the way that EDF Energy has been consulting with you so far that you would like to see changed or improved in some way? | Unprompted
Nothing 49%
Keep on consulting us 4%
To have more details 4%
Too many people at the exhibition - difficult 4% to see things/ talk to people All Cannington
It's not a consultation, they have already 3% Main decided mentions They are doing a good job 3%
Do not agree with it! 2%
Know about it already 2%
Answer questions honestly 2%
Concerns about roads/ traffic 2% Base: Total sample (276)
26 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 27 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Conclusions
28 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Conclusions
29 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 Conclusions
30 MR4704 PPS Group EDF Energy Hinkley Point C public consultation exhibitions Nov Dec 2009/Jan 2010 End of presentation Thank you
Appendix A.5
TABLE OF COMMENTS ON THE HINKLEY POINT C DEVELOPMENT SITE
EF APPENDIX A.5: Table of Comments on the Hinkley Point C Development Site
Appendices A.5 to A.8 summarise the statutory and non-statutory bodies’ comments based on the themes outlined in Sections 4.4 to 4.6 of this Stage 1 Consultation Report.
1) Preliminary Works
Consultee Comments
English Heritage Expect to be consulted by determining authority on the setting of the Scheduled Monument and the marine Historic Environment. English Heritage request further details of preliminary works, given that these should be at a relatively advanced stage. This is of concern given how far behind archaeological investigations on the site are. Findings should be fully understood before any application is made for levelling the site. If treated as elements in their own right, English Heritage require more details on these aspects including construction of jetty, sea wall, cooling water intake and outfall, and refurbishment of Combwich Wharf. This information should be provided and discussed with English Heritage prior to submission of preliminary works applications. Particularly concerned about preliminary application to level and terrace the site given the potential significance of terrestrial archaeological deposits in this location. Destruction of archaeology in advance of the IPC application could set an inappropriate precedent for other similar NPS sites. Will object to preliminary works applications on grounds that archaeology cannot be remediated.
Highways Agency The Agency requires further details to determine if construction of the preliminary works will impact on the Strategic Road Network. Request notification as a statutory consultee for preliminary works.
Marine and Fisheries Agency Potentially significant legal issue may arise in terms of how various regulators proceed with applications for the preliminary and subsequent works, and thereby ensuring compliance with their EIA directive. This is yet to be rectified. Details of the construction of Combwich Wharf, Jetty, sea wall and cooling water tunnels have not been included at this stage and MFA have not been consulted on a scoping opinion on the proposals within the 2008 Scoping Report. MFA did provide a scoping opinion to EDF Energy on jetty in November 2009.
Sedgemoor District Council and Concern is expressed over the lack of information available on the extent of soil/spoil storage proposed to take place. Further West Somerset Council consultation is required with West Somerset Council, Stogursey Parish Council and the West Hinkley Action Group. Concern is expressed regarding the lack of information available on the extent of rights of way closures and diversions. Further discussions required with the authorities and the County Council as Highways Authority. A plan illustrating the rerouting or closure of rights of way within and adjacent to the site should be provided.
1) Preliminary Works
No options for the preliminary works have been presented. There has been no proper justification regarding need for these elements of the project other than notional commentary on EDF Energy’s programme. Further details are expected to be provided on the preliminary work aspects of the proposals. This information should be provided and discussed with local authorities and the relevant statutory bodies prior to submission of any applications. The authorities require further information on the planning strategy for the preliminary works applications. This includes the consultation activities programme for all elements of preliminary works, the relationship between technical information and the mechanisms to evaluate cumulative effects of the development in its entirety. Whilst the broad approach to site terracing is described there is no information on the potential need for excavating rock by blasting. There is limited information on the mechanism for managing excavating material. No information is provided on how to ensure that effects associated with air quality and noise are managed, nor the potential requirement for removal of material from site (and associated traffic issues). No commitment is made to generation of visualisation material (including photomontages) to demonstrate the expected effects on nearby residential receptors. Reference is made to the rerouting of surface drainage and the commitment to control sediment. However, no reference is made to the potential effects on the SSSI. There is relatively limited information on proposed utility connections and no commentary on expected wayleave implications. Reference is made to the requirement for a new access road and a new roundabout to link the existing site road network. A plan showing these proposals is required. Full details of the proposed restoration strategy should be provided. There is a complete absence of any detail on the form of the sea wall. Complete design details (including plans and photomontages) should be provided so that an assessment of this feature can be made. There is complete absence of any design detail for the jetty and associated storage facility. Justification should be provided for the expected HGV movement offset quoted in Stage 1 consultation document. It is understood that a Harbour Empowerment Order will be made during 2010. It is expected that full details of the proposal will be made available in advance. The submission of separate applications for the preliminary works raises potential problems with respect to how the EIA is to be conducted and any appropriate assessment that may be necessary.
EF
1) Preliminary Works
Somerset Wildlife Trust An appropriate mosaic of habitats should be created on site post construction and connected to the wider landscape to form a coherent ecological network in the area. EDF Energy need to demonstrate that site clearance will not adversely affect statutorily protected species, such as bats. A mitigation strategy should be prepared and off-site habitat creation commenced in a timely manner. Short term biodiversity impacts need to be clarified and restoration of the site should be addressed if IPC consent is not obtained.
Somerset Wildlife Trust The delivery of mitigation and compensation for anticipated biodiversity losses should not be left until Hinkley Point C is operational. A mitigation strategy should be devised and initiated as soon as clearance and construction operations commence.
2) Construction Activities and Restoration
Consultee Comments
Avon and Somerset Constabulary Concerns about impacts of actual site, associated works, bypass and temporary accommodation sites construction and rise in local population by incoming workforce during construction which would lead to increase in demand for policing services.
Devon County Council Need to submit a Construction Environment Management Plan. Should include details/target for the proportion of locally sourced/recycled materials used in the construction of Hinkley Point C.
English Heritage A Construction Strategy needs to be prepared to take account of sustainability and environmental objections such as minimising the impact of development on the historic environment. Green Lane – pleased that initial design seeks retention of feature, question how this will be achieved given the intention to strip the site of its top soil. Concerned about retention of its current setting after landscaping. Restoration – wish to see the natural landscape undulations reinstated so that historic landscape is maintained. Question the need to include a large area of land within the site.
Environment Agency There should be a presumption against any spoil disposal in the floodplain of any watercourse where it would result in a net loss of floodplain storage volume.
Forestry Commission Should consider Richard Davies from the Forest of Dean comments and should consult with the Forest Authority (Forestry Commission) as they may have some comments as the licensing and grant making body which may apply to the screen planting.
2) Construction Activities and Restoration
Highways Agency Supports package of measures and encourage construction time limits and phasing. Sustainability - welcome approach. The Agency acknowledges the duration of construction period proposed for each of the two reactor units will result in a peak in construction activity expected in 2015. The Agency, during the pre-application process to date, has expressed concern over the potential impact on the SRN during this period and expects to see the applicant set out a series of mitigation measures and management strategies to offset any potential impact. In response to the key issues identified by stakeholders as part of the pre-application negotiations, the Agency agrees with the identification of transportation, specifically during the construction phase of development and the need to ensure that it does not produce significant congestion on the strategic road network (SRN) and local road network. The primary objective of the Agency is to ensure the safe and efficient operation of the SRN. Therefore the Agency needs to be assured that the SRN can continue to operate safely and efficiently with the additional trips generated during the construction period primarily but also during the operational life of the nuclear development including outages and the decommissioning phase.
Natural England Restoration concept design (fig. 10.8) does acknowledge the pattern of landscape features in the area. On-site restoration should seek to reflect those characteristics together with pre-existing features. A landscape management plan for the area should be prepared on how the landscape will be managed in the future. Restoration options cover an area containing existing landscape features and wildlife habitats and whilst some can be recreated any archaeology in the area cannot and this should be taken into account. There may be some flexibility with the location and height of earth bunding in order to accommodate landscape features. Benefit of bunding and planting will be very localised and it may be more appropriate to create copses that reflect local character. Welcome enhancement of wildlife corridors and sensitive hedge management, and this approach can be encouraged in any off- site mitigation measures.
RSPB Welcome that the foreshore area of the European site will not be identified for 'laydown' during construction. Important that any terrestrial habitat restoration works take full account of existing interest. Aware of good range of arable habitats on farmland to the west which RSPB wish to see maintained and enhanced, especially for farmland birds. Require a comprehensive site management plan which incorporates agreed mitigation and operating protocols on and off site is put in place before commencement of works.
Sedgemoor District Council and Preliminary works - Concern is expressed over the lack of information available on the extent of soil/spoil storage.
EF
2) Construction Activities and Restoration
West Somerset Council Preliminary works - Whilst the broad approach to site terracing is described there is no information on the potential need for excavating rock by blasting. Preliminary works - There is limited information on the mechanism for managing excavating material. Preliminary works - No information is provided on how to ensure that effects associated with air quality and noise are managed. Recommend preparation of such a construction strategy. Submit a Construction Logistics Strategy as part of DCO application.
Somerset County Council Clearly a significant amount of construction waste. Stage 1 made no reference to management of waste and recognition of value. Requirement for a Site Waste Management Plan. Full consideration to be given to the management of waste generated and the need for it to be transported, stored and disposed of.
Somerset Wildlife Trust Create mosaic of habitats to connect to wider landscape. The Trust believes that delivery of mitigation and compensation for anticipated biodiversity losses should not be left until operational phase.
South West Regional Agency keen to understand the measures to be put in place to ensure the sustainable construction of the power station. Development Agency
Stop Hinkley The scale of the project should be cut back to one reactor built over a much longer timescale thus reducing the weight on local communities of so many outside workers. Spoil from excavations should be built up not just on the south side of the station but in each compass direction.
Stogursey Parish Council As the spoil initially excavated would naturally be placed furthest away i.e. to the southern end of the site nearest to the dwellings in Shurton, that this could be the first area to be recovered. This could happen sooner than originally planned and a new east to west right of way could be installed at that stage with a temporary fence to be put in place.
The Crown Estate Query whether environmental impact of the transportation-distance and sourcing of construction materials is being considered as part of this consultation process?
West Hinkley Action Group Minimise destruction of hedges, trees, copses, old buildings throughout the site and re-use/recycle materials from barns – e.g. create habitat for swifts, owls and bats in the bund. Planting should take place immediately and not at the end of the project. Limiting hours of work which cause a noise nuisance.
West Somerset Council Recommended further consultation with West Somerset Council, Stogursey Parish Council and West Hinkley Action Group on site layout and landscaping proposals.
3) Southern Landscape Buffer
Consultee Comments
English Heritage Issue of impact of the scheme on historic landscape. Wish to see the undulating landscape reinstated to the southern part of the development site in order to restore visual quality to the site and to land belonging to Fairfield House. English Heritage do not consider the bund would meet this requirement.
Environment Agency Where possible the buffer should be multifunctional providing an opportunity for habitat creation and screening of the construction site from nearby residents. Option of leaving it as a permanent feature and planting trees. Matured trees will provide additional barrier and increase diversity of environment.
Fiddington Parish Council Land at Hinkley Point should be used for freight logistics.
Sedgemoor District Council and In order to understand whether the proposed buffer is appropriate it is important to understand scale to assess the impacts of West Somerset Council the proposed development on residents living in the vicinity. More detail of the proposal and wider landscape plans required. Further consultation with the authorities, Stogursey Parish Council and West Hinkley Action Group is recommended in relation to the proposed site layout and landscaping proposals.
Somerset County Council Suggested that EDF Energy undertake consultation with local community and key stakeholders (e.g. AONB service) to ensure design takes account of their views.
Somerset Wildlife Trust Landscape buffer could create short-medium term mitigation for habitat losses on site if appropriately constructed. Trust supports short term wildlife provisions into the overall long term ecology mitigation plan. Habitat creation should be retained and managed in situ for the long term.
Stogursey Parish Council Keep bund as far north of Shurton as possible.
West Hinkley Action Group Bund or southern site boundary to be moved further north (to the line of latitude 144750, roughly coinciding with the crest of the southernmost ridge) to lessen the adverse visual effects on nearby properties and leaving access for walkers to the south. The bank should be planted without delay, be environmentally friendly and visually appealing in ways that lay the groundwork for future use by the community. A screen of trees should be planted along the ridge from Benhole Lane on the west to the C182 on the east to provide visual screening and to compensate for the destruction of habitat which will take place north of the line. This screen will also contribute to the provision of biodiversity and new habitats to replace those lost.
EF
3) Southern Landscape Buffer
West Somerset Council Important to understand whether buffer will assist in mitigating the impacts of the project. The bund should be located as far north as possible to maximise potential mitigation and minimise impact on Shurton properties.
4) On-site Accommodation
Consultee Comments
Highways Agency For workers’ accommodation, the Agency supports the provision of accommodation on-site for up to 700 workers which would reduce the need to travel. The Agency would welcome a further increase in the provision of worker accommodation on-site.
Parish of Stockland Bristol We suggest that all accommodation for the workforce should be ‘on site’ as Hinkley B was during its construction.
Sedgemoor District Council and The 700 bed provision on-site does not align with the authorities' preferred distribution for residential development. A robust West Somerset Council examination of the exact worker numbers and service requirements is required. Concern over numbers of workers proposed on-site. Site lies in isolated position away from amenities required to support such a drastic increase in population. The campus offers very limited legacy gains to the local community and is considered to be an inefficient investment in infrastructure.
Somerset County Council Should provide more reasoning and justification for 700 workers on the main development site. Location of workers accommodation on site is of significant public concern. If necessary, then should state how the potential social issues of locating a significant number of workers will not have a negative impact on local community.
Stogursey Parish Council Against a hostel for workers being built on site at Hinkley Point.
West Hinkley Action Group Residents do not want a hostel to be located on site, but if there is no alternative then they wish the number to be limited to 700 beds. The campus should be located as far to the north-east of the site and as far away from Shurton as possible. Effective measures needed to prevent unofficial short-cuts from the entire site to Shurton and Stogursey.
West Hinkley Action Group If campus is built then after-use needs to be subject to consultation with local people – e.g. use as an outage car-park is considered to be susceptible to misuse and abuse.
5) Operational Considerations and Design
Consultee Comments
Avon and Somerset Constabulary Potential impact in the event of a critical incident at the proposed site.
Bridgwater Town Council Will the new nuclear plant be safe? Issues have been reported with the development of a reactor in Finland, on which the UK (meeting notes) one is based.
CABE Encouraged by masterplan being developed and design shows promise, however, scheme still abstract and unable to judge impact on views and site visitor experience. Masterplan design needs to be developed further to establish whether the concept of striations (parallel bands) work to generate a legible working landscape. Take into account technical constraints for a meaningful masterplan organisation. Concept of reflecting coastal striations to generate organisational strips is potentially interesting and graphically elegant. Further work needed on how strips will end and the relationship with the site perimeter and existing landscape features. Where it meets the coast, the relationship of the secure site boundary to the coastal path and the potential for retaining the new jetty should be considered. The result of the design needs to be a working landscape organised by the masterplan with logic needed in placement of buildings, interrelationships and massing which are missing at the moment. Masterplan should be directly related to the operation of the site. Masterplan should inform the legibility of the routes through the site, reinforce the activities taking place and enhance the experience of working on or visiting the site. Disappointed that not yet seeing any architectural principles emerge. Keen to see large buildings on site treated as powerful industrial objects drawing on precedents set by Battersea and Bankside Power Stations as landmark buildings. Urge EDF Energy to invest in design to ensure exemplary high quality architecture and landscape. Not yet convinced that the masterplan is responsive to the cumulative impact with the existing station.
Civil Aviation Authority Protective airspace – existing Hinkley Point stations have an established Restricted Area (RA). A similar or amended RA around the proposed facility is needed. This would have a potential impact upon airspace availability to aviation. The scale of any such impact needs to be assessed and detailed within associated environmental documentation which should describe the mitigation of any related concerns. Need to consider any aerodrome related operations, aviation activity associated with the power station itself and current usage of airspace (both civil and military, including MoD activity in Danger Area 119 (Bridgwater
EF
5) Operational Considerations and Design
Bay)). Aviation warning lighting – structures over 150m or more to be equipped with aviation warning lighting. Structures less than 150m may also need lighting if, by virtue of their location and nature are considered a significant navigational hazard. As there are helicopter operations anticipated with the power station, recommend lighting of some scale. Gas venting and/or flaring – if to occur and cause a danger to aircraft then needs to be known. Aviation promulgation – any structure over 300 feet high will need to be charted on aviation maps.
English Heritage Have not seen masterplan yet. Would like to provide guidance on the design principles. Question amount of land take up for this development and ask that any new build is kept to the minimum necessary in this location. Investigate the possible reuse of the existing Hinkley Point A and B site in order to reduce the area of land take. If this option has already been discounted then need further information to understand reasons for not reusing the site, including the existing sub-station.
Environment Agency More detail on design for associated infrastructure which demonstrates sustainable construction solutions.
Greenpeace HSE’s GDA has raised significant issues on EPR design for Hinkley Point and released a Joint Regulatory Position Statement. NII reiterated that design changes need to be made. EDF Energy cannot prove that design meets basic reactor safety standards.
Health Protection Agency Information is required on the nature of operations including the extent of any waste arisings and discharges into the environment. Information is also required on the likely radiation exposures for individuals and population as a whole for both public and workers. Information is also required on the radiation doses from other nearby sources of radioactivity. HRA is unable to comment as there is insufficient information.
Highways Agency Need further information on how planned outages for Hinkley Point C will be managed and how trip generation, distribution and assignment will impact on the strategic road network.
Ministry of Defence Subject to confirming heights of structures, may need to fit air navigation warning lights to maintain safety of military air traffic and additionally for the fixed tower cranes for construction and overhead line towers. It is anticipated that the new facility will require an air exclusion zone comparable in size to that above the existing power station. A new exclusion zone would extend further across Bridgwater Bay Danger Area and could inhibit access for aircraft using this Danger Area. Important to not impede aircraft movement in any new zone. An assessment of likely impacts of establishing an exclusion zone upon military aviation using the Danger Area is recommended. An application for the exception allowing helicopters to pass through a new exclusion zone to access the Danger Area should
5) Operational Considerations and Design
be in place. MOD should be consulted. Consultation document does not recognise Lilstock Range and incorrectly identifies the site as not in proximity to military activity. MOD investigating possibility of moving the actual firing target area within the existing Danger Area which will necessitate that the MOD completes a Sustainability Appraisal and a HRA. MOD may seek to recover costs associated with implementing any mitigation options and asks EDF Energy to undertake environmental surveys and data to complete impact assessments necessary to relocate the range area.
Quantock Hills AONB Service Wish to see details of assessment of ‘appropriate’ in relation to levels of security.
Sedgemoor District Council and The impression and desire lines of the masterplan will only be effective from a very limited view point. From all other areas the West Somerset Council design will not have any positive impact within the wider landscape setting. The overall design and impact on the landscape of West Somerset is of concern. Further consultation with the authorities, Stogursey Parish Council and West Hinkley Action Group is recommended in relation to the proposed site layout and landscaping proposals.
Somerset County Council Stage 1 would have benefited from more information relating to GDA process. Fully explain safety of the development and provide more information on the Generic Design Assessment at Stage 2 as of paramount concern to the community. Want assurance that the UK EPR design meets the requirements of the regulators through the GDA process.
South West Regional Agency keen to understand the measures to be put in place to ensure the sustainable operation of the power station. Development Agency
Wessex Water Need to understand requirement for water and waste water services during construction and operation to ensure service delivery. Discussions have commenced with EDF Energy and undergoing appraisal of need for improvements to meet increased demand. EDF Energy will provide private foul water drainage and treatment, and surface water disposal.
6) Landscape and Visual
Consultee Comments
CABE Masterplan design needs to be developed further so that it responds to the key views from the surrounding landscape and it is not merely an abstract graphic intervention.
EF
6) Landscape and Visual
Not yet convinced that the masterplan is responsive to key views. The cumulative impact of the two existing power stations, the existing power lines and the new power station on the distant views should be considered. Visual assessment of views from Minehead, the Glamorgan Coast, the Quantocks and others should be considered. Preparation of the masterplan and visual assessment should be an iterative process. Form and colour of off-site planting will be important for mitigating views. Suggest revisiting the planting schemes at the existing power station site.
English Heritage LVIA – is not comprehensive enough and omits many viewpoints considered essential in assessing the full impact on the historic assets in the vicinity. Query the criteria of what constitutes primary or secondary viewpoints. Landscape mitigation cannot be fully assessed without full assessment detail. A lack of supporting drawings and plans. Can Green Lane actually be retained? Support use of Zones of Visual Influence (ZVIs), however, need to take account of the historic landscape and significance of its contribution. Advocate need to provide baseline of the landscape and how the various historic assets fit in the landscape and how the development may impact upon this context. No direct reference made to the historic landscape character and the part it plays in shaping the current landscape, although reference made to historic features. Any landscape impact assessment should identify where there would be zones of visibility in relation to the new power station and to then undertake an impact assessment on the setting of heritage assets within those areas. This will require production of photomontage images “before” and “after”.
Mendip District Council Potential minor landscape impact to Mendip from views on administrative boundary. Visual impact on local community is important.
Natural England ES to include LVIA on the outstanding land at Fairfield and East Quantoxhead estates. Request additional agreed viewpoints with Natural England and English Heritage. Welcome aim to minimise visual impact from masterplan as proposed buildings increase magnitude of change in views, in addition to existing buildings (taking into account the reducing size of the decommissioned HPA). Design considerations should include use of appropriate materials and finishes to reduce visual impact and reflection, and reinforce simplicity. Baseline does not stress the local landscape character to the west is very distinctly undulating with ridges and valleys that
6) Landscape and Visual
afford variable visibility across the wider area, and the coastline includes low cliffs with land dipping away to the south. These subtle variations affect the potential visibility of the development at a local scale. Fig 10.11 shows how the development will draw the eye as it will punctuate the coastline at the end of the Quantock skyline. Fig 10.12 shows the scale of the development and the more complex profile in relation to the existing structures. Distinction between primary and secondary viewpoints may not be helpful at this stage as the evaluation of impacts for each viewpoint should be the deciding factor on sensitivity and significance of impacts. Views from the historic parkland at Fairfield are secondary, and in view of the proximity and historic importance of the site and the permissive public access, there is a case that the viewpoints are primary. Request nine additional photomontages and viewpoints to those shown in OX4537 in LVIA which should be included in the LVIA analysis. Locations relate primarily to land exempt from inheritance tax. Details on additional viewpoints given include public access, landscape and visual factors to take into account and suggested mitigation measures. Consultation document does not make adequate reference to the four photomontages or why they have been selected.
Nether Stowey Parish Council Visual impact from the southern part of the village.
Quantock Hills AONB Service No indication is given on how the masterplan proposes to minimise visual impact to the AONB. AONB has concerns that the masterplan will build on the predominant character of the existing complex and seeks clarification on this. No mention of removal of HPA and HPB buildings. HPC added to these existing structures would have an enormous cumulative impact on views from the Quantock Hills AONB. Are there any plans for removal of the existing towers in the future? Proximity to AONB should be given in geographical context. Hinkley Point lies predominantly within Landscape Character Area 146 (Vale of Taunton Deane and Quantock Fringes) not 142 (Levels and Moors) as stated in Appendix 1 3.14.2. The boundary slices through the site with a much smaller proportion falling within 142. A localised more detailed assessment of landscape character should form part of the baseline. Table 5.1 states AONB is 7.5km from Hinkley Point C it is approximately 3.9km from westernmost boundary – considerable inaccuracy. There is no evidence that a visual baseline for the southern construction area has been undertaken or planned. This is needed for the LVIA of the construction area. Not accurate to state Quantock Hills is mainly wooded. AONB provide description in response. Important the baseline is accurate to reflect contrast between low-lying Hinkley site and visibility from the hills. Only character of landscape to the east of Hinkley Point is similar to Somerset Levels not the area. The old red sandstone
EF
6) Landscape and Visual
referred to in 3.14.3 is typical of the vale not the landscape levels. As part of mitigation to reduce or eliminate impacts, should identify nationally protected landscapes. No reference made to visual impact on AONB in discussion on site selection. Figure 10.9 should be referenced as Woodland Hill, not just Quantock Hills as it is not representative of entire AONB views and Figure 10.10 is a view from the AONB but this is not mentioned and should be included in the text. Inconsistent to not provide information on construction activities landscape and visual impact as have done for the permanent development. Further consideration should be given to the landscape character baseline. No evidence that a visual baseline for the southern construction area has been undertaken. This is needed for the LVIA of the construction area.
Sedgemoor District Council and The impression and desire lines of the masterplan will only be effective from a very limited view point. From all other areas the West Somerset Council design will not have any positive impact within the wider landscape setting. Full landscape and visual assessment should be made available. The overall design and impact on the landscape of West Somerset is of concern. In order to understand whether the proposed southern buffer is appropriate it is important to understand scale to assess the impacts of the proposed development on residents living in the vicinity. More detail of the proposal and wider landscape plans required. Further consultation with the authorities, Stogursey Parish Council and West Hinkley Action Group is recommended in relation to the proposed site layout and landscaping proposals.
Somerset County Council Clearly a significant impact from the development of the site. Appearance of station presents a significant risk to the perception of the coast and its rural setting. Not clear what attempts can be made to mitigate against the inevitable impacts. More needs to be done to ensure a better ‘fit’ into landscape.
Taunton Deane Borough Council Supports local community views.
West Hinkley Action Group The woods to be removed currently enhance the landscape and minimise visual impact. A screen of trees should be planted along the ridge from Benhole Lane on the west of C182 on the east to provide screening and compensate for the destruction of habitat on site. Effective measures to prevent light pollution.
7) Spent Fuel, Waste and Decommissioning
Consultee Comments
Bristol City Council Site may be licensed in the future to store high-level nuclear waste for over 100 years. Potential risks associated with such storage on the local population. An acceptable solution to high level nuclear waste should be agreed and implemented before additional reactors are built.
Burnham-on-Sea and Highbridge The possibility of a rail link from Hinkley to Bridgwater for the removal of waste fuel has been discounted and that waste fuel Town Council would be managed on site. Want assurances about the safety of storing the fuel on site and the measures that would be in place to guard against possible terrorist attacks.
Devon County Council Should minimise waste generated and maximise recycling.
Environment Agency Not clear how long the spent fuel store will remain operational for but it will be more than the 70 years stated and the operational period is too short. Sustainable approach to waste management incorporating all developments. Site waste management plans (SWMPs) should be provided. Must still comply with duty of care for waste. A record of all waste movements is required in one document.
Greenpeace Information on spent fuel is inadequate. EDF Energy have no idea how the spent fuel arisings will be dealt with. A senior regulator from EA conceded that firm plans would not be known until 2012/3. Greenpeace also refer to HSE report noting request for information on spent fuel disposal and environmental impacts being acceptable. No assumption can be made on disposal of waste. Addition of new build waste could create many more problems. Comments refer to NDA record of no guarantee that geological disposal is guaranteed in Cumbria. AREVA noted that that there is no disposal site operational anywhere in the world for spent fuel. EDF Energy should be honest to public that there is no environmentally acceptable and proven solution for disposal. Huge danger posed by spent fuel to people and the local environment, EDF Energy’s actions are entirely unacceptable and on this alone the development process for Hinkley Point C should be stopped. Greenpeace asks a number of questions regarding plans for spent fuel management.
Health Protection Agency More information is required on the extent of any waste arisings and discharges into the environment.
NHS Somerset Concerns at Burnham about the storage of waste on site and the associated health impacts. Will EDF Energy be carrying out a HIA?
RSPB Must fully assess the environmental consequences of on site storage of nuclear waste and, in relation to the European site, storage must be sufficient to ensure no leakage of any material into local watercourses or estuary.
EF
7) Spent Fuel, Waste and Decommissioning
Sedgemoor District Council Concerned about waste storage.
Sedgemoor District Council and Need to provide consideration of non-radioactive and radioactive waste and long term impact on human health and the West Somerset Council environment of waste and waste transfers. Needs to be considered in terms of land contamination and waste. Anticipated that more information will be provided on decommissioning. In particular, the arrangements for long term monitoring and its relationship to the future decommissioning strategy should be included with provisions for long term custody and environmental responsibility. Identification and consideration of radioactive and non-radioactive waste and long term human health and the environment impacts as part of a Health Impact Assessment.
Somerset County Council Radioactive waste is key concern for community. On-site storage of radioactive waste represents a departure from current practice at Hinkley Point. First nuclear proposal where on-site storage of this material will be developed. It has not been demonstrated that the site is an appropriate location for the management, treatment and storage of waste. EDF Energy to state whether they intend to manage waste that is only generated at the site or whether the development of a regional facility. Need for a Site Waste Management Plan.
Stop Hinkley Concerned about the prospect of highly radioactive spent fuel being stored at Hinkley Point during and for a long time after the operation.
8) Marine Development
Consultee Comments
Burnham Boat Owners Sea Possible loss of fishing grounds, during and after the construction of the jetty, outfalls and intakes. Possible loss, disruption of Angling Association fishing due to an exclusion zone around sensitive areas. Loss of fish stocks available to be fished from sensitive areas. At the end of its life can the jetty be used as an artificial reef? Possible disruption to our club, as the maritime areas in question are very good fishing grounds for Bass, Cod, Ling, Thornback and Spurdog.
CABE Potential for retaining the new jetty should be considered.
Countryside Council for Wales A number of elements of the proposals could have an impact on CCW’s remit including disposal of spoil to off-shore sites, the construction and operation of the cooling water tunnels, jetty and flood defence works. Wish to work with EDF Energy and
8) Marine Development
stakeholders to address these matters in the EIA.
Environment Agency More detail required on the cooling water system before agreement can be reached on conclusions. More detail needed on the options considered and difficulties of implementation of mitigation and design before agreeing with conclusion. Need detail of construction – are the tunnels sealed? Can sea water or groundwater get into the tunnels? How will the sea wall terminate at the east and west boundaries?
Highways Agency Welcome use of jetty to offset HGV movements as a sustainable transport method. Need further information on proposals to determine if construction will have an impact on the strategic road network.
Marine and Fisheries Agency Any dredge/disposal activities would require the analytical testing of sediment samples by Cefas. These results would determine suitability of materials for sea disposal. This may only apply to part of a proposed dredging area which can be defined and excluded from disposal at sea. Expect EDF Energy to investigate use of the material within small scale beneficial (alternative) use schemes through CEDA and the investigation of other available disposal options rather than at sea. The nearest offshore disposal ground is Cardiff Grounds (LU 110) if dispose at sea. Details of the Combwich Wharf, Jetty and Sea Wall and cooling water tunnels have not been included at this stage.
Ministry of Defence The potential area for cooling tunnels extends directly through Lilstock Range. The location may permanently affect firing activities by introducing hardened surfaces which projectiles might hit and ricochet off. Jetty occupies the MOD Danger Area – this will infringe the target zone of the range. Use of the range should not be impeded or compromised. The jetty’s structure, ships and associated personnel will obstruct operationally important air gunnery practice. Water intake and outfall pipes for the new power station could also be located in the range. MOD is receptive to modifying the range area to accommodate the proposed jetty due to national importance of constructing new nuclear development. To achieve this, it may be necessary to move the actual firing target area within the existing Danger Area or expand or relocate the entire range Danger Area – entailing a modification to regulated UK air space subject to extensive consultation and impact assessment process by the Civil Aviation Authority which requires a Sustainability Appraisal and HRA which may determine that relocation is not permissible. A full assessment of the routes that maritime traffic using the jetty will take and expected volumes of traffic will need to be completed. No assessment has been made of the likely impacts of proposed marine developments upon military activities or the potential impact of military activities on proposed development.
EF
8) Marine Development
ESR does not consider impacts and hazards associated with undertaking marine development works in this area that might occur as a consequence of disturbing unexploded munitions or other hazardous substances that may be present in Bridgwater Bay.
Natural England Concerned over potential significant impact of the outfall tunnel and associated thermal plume and chemical deposition on the Severn Estuary SPA, SAC and Ramsar site. Detailed modelling and assessment work important to inform HRA.
RSPB Potential impacts of cooling water need to be fully assessed (direct & indirect impacts). Potential impact of coastal protection needs to be fully assessed (direct & indirect impacts). Any upgrading or extension of coastal protection is likely to have significant coastal squeeze implications. Any upgrading or extension of coastal protection is likely to have significant coastal squeeze implications. Concerned about potential direct and indirect impacts of jetty on European site. Wish to see a full assessment of impacts. Welcome relocation of the proposed marine berthing facility to Cannington where existing facilities already exist. Any potential impact on the Parrett Estuary will need to be fully assessed.
Sedgemoor District Council and Further details are expected to be provided on the temporary aggregates jetty and preliminary work aspects of the proposals. West Somerset Council This information should be provided and discussed with local authorities and the relevant statutory bodies prior to the submission of any preliminary work applications. There is a complete absence of any detail on the form of the sea wall. Complete design details (including plans and photomontages) should be provided so that an assessment of this feature can be made. There is complete absence of any design detail for the jetty and associated storage facility. Justification should be provided for the expected HGV movement offset quoted in Stage 1 Consultation document. It is understood that a Harbour Empowerment Order will be made during 2010. It is expected that full details of the proposal will be made available in advance of such an application in order to allow public consideration and comment. Potential impact of lighting the proposed jetty on important bird populations should be evaluated.
Somerset County Council Diagrams in Stage 1 document appear to show the sea wall separated from the main station development by a large lagoon. EDF Energy should clarify its intentions for the sea wall as there could be impacts in terms of SPA and SAC features and how it will interact with the jetty, intake and outfall pipes etc. Consent may be needed separate to the IPC. As jetty projects into the Severn Estuary, there is a potential impact upon the SPA and/or SAC features.
8) Marine Development
Spaxton Parish Council Pleased to see proposals to use transport by sea for aggregates to a temporary jetty on site.
Stop Hinkley Concerned about the effect that the heat plume from cooling water discharges into the Bristol Channel would have on life in the Channel.
The Crown Estate Careful consideration should be given to the sea wall and any contribution it may have to coastal squeeze in light of changing sea levels and lack of spreading room for the foreshore and associated loss of designated European sites. Consider impact of hard defences on the shorelines affecting land owners of contiguous property. Note sensitive and highly protected marine environment around the Hinkley Point C site through designations plus a candidate SAC.
Trinity House Will consider marking requirements once MFA applications made.
West Somerset Council Further details requested on construction of cooling water tunnels. Further details requested on construction of sea wall. Further details requested on construction of jetty.
9) On-Site Parking and Access
Consultee Comments
Devon County Council Further detail on how the proposed Park and Ride Scheme integrates with car parking provision on the EDF Energy proposal site and in the rest of Bridgwater and the wider sub-regional transportation and movement strategy.
Highways Agency Further clarification on the number of car parking spaces proposed on-site (i.e. is access restricted, how, spaces and car sharer spaces?). Further clarification on the use of outage car park (i.e. is access restricted, how, spaces and car sharer spaces?).
Nether Stowey Parish Council Further details on how the alternative/emergency access to the site via Stogursey Lane is requested – how this road will be improved/managed to ensure adequate access at all times for homes off Stogursey Lane.
NHS Somerset Question suitability of emergency access to the site.
Sedgemoor District Council and Not stated if there are any changes to the main site access. Concern on appropriateness of the Alternative Site Emergency Access/Egress Road. The proposed road is off an extremely
EF
9) On-Site Parking and Access
West Somerset Council narrow lane that cannot accommodate anything other than minor traffic. Need to consider the suitability of the emergency access, the C182 and junctions for their future role (serving Hinkley Point A and B site, the construction site for Hinkley Point C etc). Further discussions required between EDF Energy, the authorities and the County Council Highways Authority. Preliminary Works - Reference is made to the requirement for a new access roads and a new roundabout to link the existing site road network. A plan showing these proposals is required.
Somerset County Council Parking should be provided on-site at a level that does not encourage unnecessary trip generation and linked to forecasts. Suitability of emergency access road is queried and further design details requested.
Stogursey Parish Council Reconsider emergency route via Shurton – unless major works are undertaken to prevent flooding this emergency route would be unusable.
West Hinkley Action Group Concerns about the emergency access and its proximity to houses. It should be guaranteed that the road is for emergency use only. The gate should be secured. The road and the gate should not be lit and the gate and the fencing in keeping with the rural nature of the village surroundings.
10) Overhead Line Infrastructure
Consultee Comments
Comments in Relation to EDF Energy’s Overhead Lines Below
Sedgemoor District Council and Preliminary Works - There is relatively limited information on proposed utility connections and no commentary on expected West Somerset Council wayleave implications nor a commitment to evaluate the environmental implications of works to secure these connections. There is also no plan accompanying the utility strategy. Potential impact of proposed overhead power lines on important bird populations should be assessed. Only limited detail provided on works required to connect the new 400kV substation to existing powerlines. Further discussion required between EDF Energy and National Grid. Area of study includes areas potentially very close to properties in Hamlet of Wick. Further consultation is required with West Somerset Council and Stogursey Parish Council.
10) Overhead Line Infrastructure
Comments in Relation to National Grid Transmission Infrastructure Below
English Heritage Transmission lines – routes have been altered and an option is being shown that will take the route closer to Pixies Mound. EH request that this aspect of the scheme is revisited.
Friends of Quantocks Query about pylons and route corridor (referred to National Grid consultation).
Greenpeace What are EDF Energy’s plans are should the new transmission lines from Hinkley Point C not eventuate.
Highways Agency The Agency provided a formal response to the National Grid consultation on the proposed overhead electricity lines dated 14 December 2009
Ministry of Defence The proposed routes for overhead line development will not affect defence interests. However, MOD will assess the precise location and dimensions of overhead line towers when these have been finalised to verify whether any air navigation warning lights will be needed and to update air navigation charts accordingly.
Sedgemoor District Council and Details of works required are very limited and note that the study area is potentially very close to properties in the Hamlet of West Somerset Council Wick. Further consultation with West Somerset Council and Stogursey Parish Council is required when more detailed proposals available.
11) Amenity and Recreation
Consultee Comments
Burnham Boat Owners Sea Possible loss of ecology (tubeworm beds in construction areas; plus an impact on fish that feed on the tubeworm). Angling Association
NHS Somerset Suggested cycle paths from Williton to site be established. Suggested to make the coastal path a cycle path too.
Sedgemoor District Council and Concern is expressed regarding the lack of information available on the extent of rights of way closure and diversion (either West Somerset Council temporary or permanent) as part of the preliminary works and the main site works. Further discussions required with the authorities and the County Council as Highways Authority.
EF
11) Amenity and Recreation
A plan illustrating the rerouting or closure of rights-of-way within and adjacent to the site should be provided.
Somerset County Council High number of PRoWs affected. Development should mitigate negative impacts upon PRoWs. Encourage EDF Energy to consider how the development can provide an opportunity to rationalise and improve the network. Ensure no overall negative impact on availability.
Somerset Wildlife Trust EDF Energy should provide sustainable development which is accessible. Address PRoWs at same time as designing ecological mitigation. Important that disturbance is avoided. Opportunities to create public access to green spaces around the site should be examined.
Stogursey Parish Council Would like at least three parish councillors security checked and issued with passes to walk and monitor the works being carried out on footpaths. Immediate installation of a new right of way along EDF Energy’s western boundary from the top of Benhole Lane to the coastal footpath. Also improvements could be made to the southern end of this path. Question legality of the proposed closure of the affected rights of way, however, it may be that compromise could lead to a solution which, although not ideal, could be the best that we could expect in these difficult circumstances.
West Hinkley Action Group Provision of alternative routes to closed Public Rights of Way.
12) Historic Environment
Consultee Comments
English Heritage High potential for terrestrial archaeological deposits within the development site and for archaeological structures and deposits in both the intertidal and subtidal areas close to the site. As final reports on non-intrusive field surveys are not included, assessment of adequacy of results and interpretations could not be made. These should be included at Stage 2. Unable to respond on archaeological field evaluation as this had not started when report drafted. It is anticipated the results for significance of buried remains will be made available. Lack of consideration of other aspects of historic environment outside the main site. Sensitivity should be given on siting of infrastructure, especially the new roundabout, car parks and buildings in respect of impact upon the setting to Pixies Mound.
12) Historic Environment
Concerned by potential impact of major development on West Somerset and Sedgemoor and its broad range of designated and undesignated features. Recommend that assessment of the impact of any development upon the setting of these historic assets either as individual components within the landscape, or as compositions made up of multiple assets. A wide definition of setting is recommended when considering any historic assets and their context. The understanding shown towards other historic assets in the vicinity of the site has been poor. A robust and transparent visual impact assessment on all the assets listed in the response (Appendix A.1) should be undertaken. A large number of historic buildings in the vicinity of the site that need to be fully assessed in terms of the impact upon them and their settings. Of these Fairfield House, which also has a designated Historic Park and Garden attached to it, and East Quantoxhead are the most notable. Other designated sites are located in and around this part of Somerset and will need to be fully assessed either as part of the on-site or off-site associated works. Of particular note are the Conservation Areas of Cannington and Stogursey, the large number of historic buildings within them and immediately around these settlements including Brymore School and Gurney Manor. In the case of the proposed NPS site itself, English Heritage have particular regard to protecting and enhancing the management of the Scheduled Monument known as Pixies Mound and its setting that is located just to the south of Hinkley Point B. There is also known to be high potential for terrestrial archaeological deposits within the identified development site and for archaeological structures and deposits in both the intertidal and subtidal areas close to the proposed NPS site. Landscape impact assessment should identify where there would be zones if visibility in relation to the new power station and then assess impact on the setting of heritage assets within those areas, particularly building types vulnerable to significant development within their setting. Need photomontages of ‘before’ and ‘after’ the development. Recommend that a map is produced which identifies the zones of visibility in relation to the development and consultation with English Heritage is undertaken to agree which historic sites require photomontages to further assess visual impact, and subsequent forms of mitigation measures proposed. English Heritage has particular regard to protecting and enhancing the management of the Scheduled Monument. Increased traffic generation and severance of land to historic estates can also be factors affecting the setting of heritage properties. Need to fully assess other designated sites as part of the on-site and off-site works: Conservation Areas of Cannington and Stogursey; large number of historic buildings within them; and immediately around these settlements including Brymore School and Gurney Manor.
EF
12) Historic Environment
Scheduled Monuments – advise that these are properly considered in and around the site including: The Scheduled Monuments of Cannington Park Hill Fort and Stogursey Castle. In the Williston area, the historic building of Orchard Wyndham to the south and the tumuli complex to the west are also of particular note. There are in addition three separate sites including Fairfield House that are subject to Inheritance Tax Exemption rules due to their outstanding historic importance. Although not a statutory planning designation these are nevertheless of high heritage value and must be treated accordingly. Details of the form and methodology of the impact assessments for these historic assets are set out in more detail in Appendix A.1. Environmental initiatives that cover the wider landscape and historic assets in the area may be sought. Welcome opportunity of working with EDF Energy and Councils to achieve positive legacy benefits to historic environment. EIA – historic environment should be given weight to other environmental considerations. Advice given on identification of environmental issues, opportunities and problems English Heritage expect to be taken into account in the SEA/SA process (see response for further details). English Heritage will be looking for evidence that the Strategic Environmental Impact Assessment/Sustainability Appraisal process informs the development of this proposal, justifies case for any damage to historic environment and provides for the mitigation of adverse impacts and potential enhancement benefits. All designated assets should be considered as well as non designated features of local historic and archaeological interest, landscape character and unrecorded archaeological interest in the River Severn intertidal area. Area of study should be consistent with other IPC projects. Recommends data sets available for assessment.
Natural England Any potential archaeology in the area cannot be reinstated once disturbed. Therefore the operational areas during construction and the area of restoration should take this into account.
Sedgemoor District Council and All relevant archaeological data should be provided to understand existing historic environment. West Somerset Council
Somerset County Council Until information is complete on trial trenching and surveys it is not possible to make any reasoned decision concerning the archaeological resource on the site.
13) Environmental Information and Assessment
Consultee Comments
Countryside Council for Wales Welcome commitment to providing information in the EIA to allow the impacts identified to be fully assessed and commitment to provide details of construction and operation phases, together with possible conditions or restrictions to ensure adverse impacts are avoided.
The Crown Estate Welcome baseline data studies proposed and outlined, especially in relation to marine water and sediment, presuming these are available on request.
Devon County Council Need to submit a Construction Environmental Management Plan.
English Heritage LVIA is not comprehensive enough and omits many viewpoints considered essential in assessing the full impact on the historic assets in the vicinity. Query the criteria of what constitutes primary or secondary viewpoints. Landscape mitigation cannot be fully assessed without full assessment detail. A lack of supporting drawings and plans. Can Green Lane actually be retained? The understanding shown towards other historic assets in the vicinity of the site has been poor. A robust and transparent visual impact assessment on all the assets listed in the response (Appendix 1) should be undertaken.
Environment Agency Require access to studies and technical documentation prior to Stage 2.
Marine and Fisheries Agency Expect information to be presented about the methods and surveys conducted to inform the EIA. ES should be a standalone document and comprehensive and rigorous on the nature and potential effects of the project and is a suitable mechanism for Appropriate Assessment. Expect to see any relevant monitoring and mitigation measures for the scheme proposed in the EIA and are allowed to comment on any subsequent Environmental Statement before commencement of works.
Ministry of Defence Environmental Status Report (ESR) does not consider impacts and hazards associated with undertaking marine development works in this area that might occur as a consequence of disturbing unexploded munitions or other hazardous substances that may be present in Bridgwater Bay.
Natural England Prior to or at Stage 2 all made available for reference and comment.
Quantock Hills AONB Service Quantock Hills AONB missing from list of national designations – clarification is sought.
EF
13) Environmental Information and Assessment
Sedgemoor District Council and The submission of separate applications for the preliminary works raises potential problems with respect to how the EIA is to be West Somerset Council conducted and any appropriate assessment that may be necessary. No detail provided on scope and timing of further Phase 2 investigations in order to comment on adequacy. Technical documents should be provided prior to Stage 2.
14) Other Environmental Issues
Consultee Comments
Bristol City Council Ecology Impact of the proposed use on the environment of the Severn Estuary with in-combination effects which could not be mitigated.
Burnham Boat Owners Sea Ecology Angling Association Possible loss of ecology (tubeworm beds in construction area; plus an impact on fish that feed on the tubeworm.
CABE Landscape and Visual Impact Not yet convinced that the masterplan is responsive to the cumulative impact with the existing station.
Civil Aviation Authority Potential impact upon airspace availability to aviation. The scale of any such impact needs to be assessed and detailed within associated environmental documentation which should describe the mitigation of any related concerns.
Countryside Council for Wales Ecology Coordination with the relevant Shoreline Management Plans and compliance with the Water Framework directive are relevant to the proposals. Unable to say whether development has significant effect on sites. It will be necessary for competent authority/ies to carry out an Habitats Regulations Assessment (HRA). More detail on the European nature conservation sites is required before further detailed comment can be provided. May be necessary for a HRA of the proposals to be carried out to assess the implications of the development on the conservation objectives of the European conservation sites.
14) Other Environmental Issues
The Crown Estate Query if any noise study or assessment is to be carried out in relation to non-human receptors in the marine environment in respect of noise, especially in relation to works impacting The Crown Estate. Query whether environmental impact of the transportation-distance and sourcing of construction materials is being considered as part of this consultation process. Consideration should be given to the proposed sea wall and any contribution it may have to coastal squeeze in light of changing sea levels and lack of spreading room for the foreshore and any associated loss of a designated European site. Should also consider the impact of the hard defences on the shorelines affecting landowners of contiguous property.
Environment Agency Hydrology and Drainage Require an appropriate FRA as construction site and access roads within Flood Zone 3. This also needs to include the decommissioning and spent fuel storage phases and sea protection scheme. Need to comply with PPS25 in the matters of flood risk management, sequential approach, new development should be directed to sites at the lowest probability of flood risk. The sequential test has been undertaken as part of the SSA for the power station location, however, still expecting a sequential approach to the site development itself, including temporary development. Any development over a hectare or in Zone 2 or 3 will require an appropriate site specific FRA. Culverting Holford Stream – EA has policy opposed to culverting watercourses to facilitate development. Would prefer Holford Stream and buffer corridor to be retained as a ‘no working area’ albeit with access bridges/causeways across it as necessary. Culverting would have an adverse impact equal to or greater than the perceived water quality impact on Wick Moor – as stated in 3.3.12. Culverting may require a separate consent and only consented if the need was proved exceptional and there would be no adverse impact on flood risk, third party land drainage and environmental quality. Groundwater and contaminated land – aware of potential significant source of contamination in the Built Development Area East. Adequate assessment needed for potential dewatering operations during construction to move radiological and non- radiological contaminants on the HPA site. Need discussions with Magnox South or the NDA on this. Expect a desk study to be carried out including details of previous uses which might give rise to contamination. If identifies contamination then further investigation and possible remediation required. Expect a detailed scheme to dispose of surface water run-off and demonstrate protection of controlled waters as part of each detailed application. Where possible developments should be multifunctional. Pollution prevention – risk of pollution reduced in development and construction and to meet appropriate pollution prevention guidelines. No vehicles in watercourses and to install bridges in the dry. Fuel containers/vehicle storage areas should be sited away from the watercourses and bunded where appropriate. Land drainage consent required where work carried out within 8m of a main river. Inspection manholes shall be provided. Facilities storing oils, fuels or chemicals shall be sited on impervious
EF
14) Other Environmental Issues
bases and surrounded by impervious bund walls (further detail provided). Sewerage infrastructure should be in place to cope with maximum potential volume. Need to consult with Wessex Water to check if adequate space in the network. Hydrology – has recent data on average rainfall been taken into account? SUDS may not be mandatory for the power station if discharge direct to Bridgwater Bay, however, still need to meet water quality requirements. The Breach Scenario should represent worse case and when breaching the defence overtopping should be allowed to take place in the modelling at the same time. Provide detail to EA of extreme sea levels to compare to other studies. Hydrodynamics and coastal geomorphology – out of date climate change data, need to consider UKCIP09. No mention of impacts from the sea wall on coast down drift, is it assumed that there are no detrimental effects on the wider environment? EA want studies/surveys on this area. Assessment appears adequate. Would be helpful if there was a better explanation of the criteria for radioactivity in the Drinking Water Standard. Define what is meant by “so called” analytical detection limit in para. 3.6.9.
Health Protection Agency Information is required on the nature of operations including the extent of any waste arisings and discharges into the environment. Information is also required on the likely radiation exposures for individuals and population as a whole for both public and workers. Information is also required on the radiation doses from other nearby sources of radioactivity. HRA is unable to comment as there is insufficient information.
Highways Agency Transport No reference made to proposals at Oldbury. Potential for cumulative impact on the SRN in particular during peak periods of construction. Wish to see a strategy between EDF Energy and E-on on appropriate management and mitigation.
Marine and Fisheries Agency Noise and Vibration
Noise and vibration – expect any works on noise and vibration in the ES to include information on the impact on marine mammals, fish and any other large mobile species. Ecology Cumulative – in order to address cumulative impacts the EIA needs to assess impact of the scheme in combination with other projects in the vicinity.
Natural England Ecology
14) Other Environmental Issues
Impacts from lighting for the development, including outer car parks should be minimised through use of appropriate techniques including directional lighting and shielding to reduce glare at night.
North Devon Council Proposals should consider perceived impact on the wider environment and region.
North Dorset District Council The Council does not consider there to be likely material impacts upon the interests of the district.
Parrett Internal Drainage Board Hydrology and Drainage Main site located outside Parrett Drainage Board area but some surface water generated may discharge into area. Ensure that flood risk and surface water drainage are managed effectively. Ensure that main site permanent or temporary works do not increase flows into the watercourses in the Stockland area. The Board wishes to be consulted where work is undertaken within 9 metres of any watercourse within the Board’s area. This may impact upon proposals to the south of the site in the area of Wickmoor and Westbrook.
Quantock Hills AONB Service Landscape and Visual Impact Wish to see details of assessment of ‘appropriate’ in levels of lighting and there should be a lighting assessment undertaken to ensure light emission from the site is kept to a minimum given the increase in light pollution anticipated. Figures being used for distance between AONB and Hinkley Point C are wrong. Designations – should refer to AONB in full throughout ‘Quantock Hills Area of Outstanding Natural Beauty’ not ‘The Quantocks’ or ‘Quantock Hills’. Ecology There is no mention of the Quantock Hills SSSI.
RSPB Ecology Important to assess the combination impacts of new transmission lines in relation to the Steart managed realignment scheme and potential bird collision risk with lines, particularly in relation to local waterbird flyways between the Severn Estuary and inland wetlands. RSPB considers that it is likely that there will be significant effects on the SPA and consequently a full appropriate assessment will be necessary. Proposals to minimise impact on the European sites. Potential impact of cooling water and coastal protection needs to be fully assessed (direct & indirect impacts) on European
EF
14) Other Environmental Issues
sites.
Sedgemoor District Council Concerns about exacerbation of flood risk. Concerned about health impacts. Inadequate consideration of planning mitigation.
Sedgemoor District Council and Geology, Soils and Land Use West Somerset Council In general terms, the baseline description is adequate for the Stage 1 Consultation process. Would be beneficial to include comment on the anticipated thickness of the geological strata and include a summary of the geological data and geophysical investigations which have taken place. Need to provide information on consultation activity undertaken. Further detail needs to be provided on the planned geological and geotechnical intrusive investigations. A figure needs to be provided to illustrate the alluvial deposits in the Valley. Recommend inclusion of a list of geological maps, a reference list of reports and sources of information used, and a list of regulations, legisltation and other relevant documentation. Outline information regarding proposed mitigation measures needs to be provided. Detail on the impacts during the construction phase in terms of contamination is sought. Land Contamination and Waste
Whilst the baseline section is adequate and appropriate for this stage of design, a commentary on ground gas would be expected. The section is entitled “Land contamination and Waste”. However waste matters are not addressed in this section. This oversight should be corrected. A list of all source data used should be provided. An exploratory location map should be provided showing existing and proposed ground investigation points. Section 3.2.6 should include the depths of the trial trenches and a summary table of the chemical analysis. Section 3.2.8 would benefit from the inclusion of a summary of the radiological levels including a range of levels recorded and background levels. A list of references including previous investigations, radiological walkover and baseline data sources should be provided.
14) Other Environmental Issues
There is very limited detail provided in relation to the consultation that has been taking place in relation to land contamination and waste. Details regarding the scope and timing of Phase 2 investigations should be provided. There is no reference to identifying potential contamination created during the construction, operational and decommissioning phases of the proposed development. Consideration of non-radioactive and radioactive waste needs to be addressed. Long term impacts of waste transfers have not been identified and the cumulative contamination and waste issues have not been identified. Decommissioning of the proposed power station is not mentioned in section 3.2. Outline information regarding mitigation measures is not provided for this section. Hydrogeology
The baseline is judged to be adequate. However, further details regarding long term monitoring should be included in this section. It is strongly recommended that reference to geological sources is included. It is recommended that the consultation which has taken place should be detailed in full. The report states that intrusive site investigations are in progress or planned. These should be detailed in full. Disposal of discharged waters from the dewatering process is not listed as a key issue. Hydrology, Drainage and Flood Risk
This section should be supplemented with accompanying drawings. There is no baseline description of ground water. This is a significant omission. There is no reference to Stogursey in the baseline section although it is identified as requiring specific flood protection. There is limited information on the scope and methodology of the Flood Risk Assessment. Full account should be taken of the strategic Flood Risk Assessment for Sedgemoor and the Local Development Framework, and the agreed strategic flood defence solution (The Parrett Barrier). Account should be taken of the Shoreline Management Plan, the Environment Agency studies on the Parrett, and notably the Steart Managed Realignment Project. The graphical material provided in support of this section is considered inadequate.
EF
14) Other Environmental Issues
Freshwater Quality
There would be considerable benefit in a closer narrative between this section and the section on hydrology, drainage and flood risk. The freshwater quality description would be enhanced through the addition of more detailed drawings. There would be value in including reference to Planning Policy Statement 23: Planning and Pollution Control; CIRIA C697: The SUDs Manual and a full reference for the Tier 1 Ground Water Risk Assessment. There is limited information on how the consultation undertaken has shaped the understanding of baseline conditions and established the approach for future studies. A ground water monitoring and sampling campaign is necessary addition to the baseline information. Marine Water and Sediment Quality
The baseline section is only partially complete as the results for the chemical (non-radiological) determinants for sediment quality are outstanding. There is limited commentary on the temporary aggregates jetty, dredging and new sea wall. Further details should be provided on the thermal plume modelling. The baseline description refers to current and historical studies in the area. Without a definition of ‘studies’ and ‘area’ this suggests a desk based assessment approach, which limits collection of real data and quantitative analysis. This would represent a significant omission. Further details are required in the baseline section on the assessment methodology, particularly relating to the jetty, dredging and sea wall. It is strongly recommended that a future programme of numerical modelling of coastal processes be undertaken. More detail is required on sediment disturbance and contaminant mobilisation contribution to overall water quality. Further reference should be made to the documents to be developed in parallel with the Stage 1 Consultation. No specific consultation is detailed. There is currently very limited data on the description and assessment methodology of the construction of the jetty, new sea wall, cooling water intakes and outfalls and refurbishment of Combwich Wharf. Proposed water quality modelling does not appear to be examining changes in sediment quality and how existing (potentially contaminated) bed material will be raised into suspension and transported.
14) Other Environmental Issues
Confirmation is required as to whether consideration has been given to monitoring suspended sediment levels from pre- construction through to post construction of jetty (including dredging), sea wall and cooling water infrastructure.
Hydrodynamics and Coastal Geomorphology Whilst the description of the baseline is generally adequate, there is currently very limited detail on the assessment methodology used to derive this baseline. The approach to modelling should be confirmed. Further detail is required on the hydraulic models identified in Section 3.7.8. There is also uncertainty on how the wave data acquired from the Waverider buoy would be utilised. The description of the proposed jetty construction and operation is inadequate. While the description of climate change effects is generally adequate, this assumes that the parameters identified in Section 3.7.3 will be addressed. EDF Energy should also consider wave climate (direction) changes, including angle of approach to the shore line, wave reflectivity and overtopping. Further detail is required in the parallel environmental information to support the planning process for the various elements of the scheme. The effect that individual consultation processes has had on the baseline and future proposed studies should be stated in full in this section. The Stage 1 consultation document does not indicate that any further studies are proposed at this time. It would be expected that more detail be provided on preliminary works aspects of the proposals. Terrestrial Flora and Fauna Limited information has been provided on the national and local designations, and neither Blue Anchor to Lilstock Coast SSSI, nor Bridgwater Bay SSSI are described in sufficient detail. Information should be included on the Steart Managed Realignment Project and the planned habitat creation for the provision of bird populations. A brief description of the Bridgwater Bay National Nature Reserve should be added. In addition, a brief description of the qualifying inter-tidal habitats for the Severn Estuary Special Area for Conservation, adjacent to the built development area should be included and cross-referenced. The potential impact of lighting the proposed jetty on important bird populations should be evaluated and the potential impact of the proposed overhead power lines on the important bird population should also be assessed. It is currently unclear as to how the findings of the badger survey will be made available.
EF
14) Other Environmental Issues
The report needs to state whether the statutory consultees agree that no further surveys are required to inform the assessment. The survey reports should be made available in full. A drawing should be prepared to include non-statutory designated nature conservation sites, including Hinkley County Wildlife site. Marine and Coastal Flora and Fauna No information has been provided on the national and local designations particularly the Blue Anchor to Lilstock Coast SSSI and the Bridgwater Bay SSSI. Furthermore, no information has been provided on local statutory designations. The geomorphological value of the shore platform also needs to be recognised (specifically relating to the SSSI designations) and the potential effects of lighting upon bird species should be evaluated. The purpose of the consultation document, in the context of the approach to planning documentation needs to be clearly stated. The baseline surveys should confirm all locations of Sabellaria and Corallina. Within Figure 10.3 it would be useful to have the sites named of the international statutory designations. Furthermore, in Figure 10.4 it would be useful to have the sites named of the national designations. Confirmation is required from statutory consultees that the numerous marine and coastal ecology surveys completed to date adequately cover the baseline assessment. Transportation In general terms the description of transportation is inadequate with limited reference to supporting data. There is limited information on transport network performance/congestion and safety related issues. The information and cross referencing to Section 4 in section 3.10 is inadequate or incomplete. Section 3.10.16 states that preliminary modelling has indicated that a bypass around Bridgwater is unlikely to be warranted. There is no justification given for this assertion. Sensitivity testing will be required using different modelling assumptions from the socio-economic model. In Section 3.10.23 there is an uncertainty as to whether the journey time assumptions underpinning the socio-economic work by Oxford Brookes has been agreed. Section 3.10.24 describes the use of Sizewell in Suffolk and Flamanville in Normandy as an appropriate basis for assessing construction vehicle movements for Hinkley Point C. There is no confirmation that this has been agreed as an appropriate reference case.
14) Other Environmental Issues
Under the suite of transport measures proposed at Section 3.10.27 there is an omission of shuttle buses from the accommodation centres to Hinkley Point C, and public transport, cycling and walking enhancements to cater for recreational trips from accommodation centres in Bridgwater and Cannington. Information on existing junction performance and accident analysis should be presented. Information on permitted development and programmed transport schemes should also be included. It is not clear which additional M5 junctions the Highways Agency has requested to be included in the assessment. There is limited reference to the role that consultation has played in the review of transportation data. There is a general lack of information about when further analysis will be completed. There is no mention of an assessment of local transport needs (e.g. transport, cycle and pedestrian enhancements to provide for leisure/recreation trips generated by staff in the accommodation campuses). There is no mention of how the proposals will integrate with the delivery of the Bridgwater Vision and its transport proposals, or integrate with the Local Development Framework Infrastructure Delivery Plan. A map should be included in this section showing the extent of the highway assessment area and the areas of coverage by the transport models. The primary issues on the adequacy of the data relate to the off-site associated infrastructure. This includes the rationale for a 200 capacity accommodation campus at Cannington South, and the rationale for a Freight Consolidation Centre at Cannington South. There is limited information on what this location offers that is not available next to the M5 Junction 23 or Junction 24. There is also no rationale provided for a campus or park and ride facility at Wiliton. The Hinkley Point C proposals could result in increased traffic along the A39. Noise and Vibration There is no graphical indication of the location of the receptor at Riverside, Combwich. The inclusion of single figure noise levels (rather than a range) for evening and night at three locations suggest single measurement or small measurement samples which should be addressed further on-site evaluation/monitoring. It would be appropriate to agree the methodology with the Local Authority Environmental Health Officers. A table showing what noise levels constitute an impact and how the severity is determined would be helpful. There is no information as to how the operational noise emissions have been calculated. There is no information on how the consultation has resulted in agreements regarding the approach. The table at Section 3.11.12 states that modelling of noise sources during the operational phase of the development is planned
EF
14) Other Environmental Issues
or is in progress. It is not clear what modelling has been undertaken to carry out the assessment. Section 3.11.11 discusses controlling construction noise through Section 61 consent and discusses potentially agreeing permissible noise levels. However there is no indication that this approach has been agreed with Local Authority Environmental Health Officers. Whilst there is nothing to suggest that there would be any errors in the assessment there is currently insufficient information to understand how the assessment has been carried out and how the conclusions have been reached. Air Quality There is no information provided on anticipated effects and any management of impacts to sensitive designated sites/ecological sites in the vicinity of the proposed scheme. The main sources of air pollution in the study area have not been identified and there is currently limited context of other sources of air pollution within the vicinity of the proposed Hinkley Point C. It would also be beneficial to include more detail about on-site sources of pollution. More specific information should be provided to clearly identify what guidance has been followed (e.g. Environment Agency guidance). More detail should be provided on the outcome of the consultation that took place with local Environmental Health Officers. The construction assessment considers that dust nuisance after mitigation would be minor. More detail is required to understand how this conclusion was derived. The report states that effects from exhaust emissions will be assessed once the construction programme is available. No information is given on how this will be assessed. Cumulative effects should be considered. There is some uncertainty as to why PMN and PM 2.5 are not mentioned as being pollutants of concern during the operation of the plant. A plan illustrating monitoring locations and sensitive receptor locations and main construction haul roads should be provided. Radiological
The Radioactivity in Food and the Environment (RIFE) Study should be provided in full as a technical annex. Information from the Generic Design Assessment (GDA) process on potential doses to human and non-human species from operation of EPR should be provided. There is limited reference to methodology or reference criteria within the Baseline Section. Information on the results of sampling is referenced as being included in Sections 3.2, 3.5 and 3.6 although only limited data is
14) Other Environmental Issues
included in these respective sections. Reference to public dose limits should be included within the Baseline Section as well as Sections 3.2, 3.5 and 3.6. The information derived from on-site sampling should be detailed in full in addition to RIFE data. Discussions to be held with the Nuclear Installations Inspectorate/Health and Safety Executive should be detailed in full. The completed studies section makes reference to an assessment of radiological impact of transport of radioactive materials; human radiological impacts and non-human radiological impacts. These studies are welcomed but the results should be made available in full. It is recommended that drawings be provided illustrating sensitive habitats considered within the non-human dose modelling. Whilst the data provides a degree of confidence that surveys completed and ongoing will provide sufficient information on radiological effects it is recommended that the output from these studies be included in full and confirmed at dose (critical group) limits. Landscape and Visual Amenity The addition of more drawings would be useful to help set out baseline conditions and context. It would be useful to see the ZTV (Zone of Theoretical Visual influence) that was used to help identify suitable and appropriate view points in the initial assessment. It is expected that sensitivity will be assessed using the Guidelines for Landscape and Visual Assessment. Further detail is required on the level of initial assessment which has been carried out to enable the estimated residual affects. More information should be included on the landscape character context to the west of the Hinkley site which on Figure 3.11 is hard up against the edge of the map. Figure 10.11 Viewpoint C appears to show the same photograph for both summer and winter views. This should be amended. There appears to be a description of mitigation and residual effects without the full assessment having been detailed. Archaeology and Cultural Heritage Previous non-intrusive field surveys are discussed within the assessment. These reports should be included in the Stage 2 Consultation document. A labelled map of baseline data is essential for the clarity and understanding of this type of report. Amenity and Recreation Given that up to 700 workers are due to be accommodated on-site it would be useful to understand what recreational and amenity services will be provided on-site.
EF
14) Other Environmental Issues
Information showing travel times and locations of off-site facilities which would be used by on site workers due to the absence of a like provision on-site is currently absent from the Stage 1 Consultation document and is required. Discussions have taken place with Natural England, Community Sport in Somerset and Bridgwater Swimming Club. Details of the topics which were discussed should be provided. A leisure audit of the entire Sedgemoor District and the coastal strip of West Somerset is also being undertaken but is not referenced within the Stage 1 Consultation document. Greater understanding is needed on the level of services currently provided in the town, any existing deficit, amenity and recreational provision required to serve construction workers, and the permanent 700 workers for a period of 60-80 years. Considerably more information is required to characterise the patterns of movement associated for workers off-site engaged in amenity and recreation. Considerably more information is required on the closure and diversion of public rights-of-way. Additional photographic/representational material of the types of recreational facilities to be provided on-site is required. This could include site reference data from Sizewell. Socio-Economic There is a propensity in the Stage 1 consultation document to reference peak work force which may potentially skew an assessment of the scale of effect. The Stage 1 consultation document relies on the transferability of experience gained from longitudinal studies of socio- economic impacts created by UK Nuclear Power Stations. Whilst this is a reasonable starting position there is little evidence that this data has been contextualised for the proposed Hinkley Point C project. Further context should be provided on the similarities and differences between the Flamanville site and the proposed construction at Hinkley. The assessment of economic impact during the construction phase is dependent on assumptions from other studies. These assumptions require sensitivity testing. Measures aimed at enhancing opportunities for females during the construction and operational stages should be addressed. More clarification could be provided on the occupational profile of the projects job demand especially in relation to the potential displacement of jobs from the local economy. A copy of the evaluation material for Flamanville 3 should be provided. The labour demand likely from major developments in proximity to the project should be identified in terms of phasing and cumulative effects. Local labour content in more recent studies is substantively below the 50% assumption level. It is recommended that further
14) Other Environmental Issues
sensitivity testing be undertaken in relation to a lower local labour assumption and its effects on the distribution of the workforce arising from a lower percentage. Validation of the 90 minute daily commuting zone (paragraph 3.17.14) in relation to different occupational groups should be provided. Clarification should be provided on the basis of the 20% contingency margin. There is no evidence that suggests that accommodation requirements for Hinkley B outages have been factored into the overall impact considerations. There is limited information on the effect that the consultation has taken place has had on the approach to the Stage 1 document. Clarification is needed concerning “work on local/regional area assessment indicators, wider effects and more detailed mitigation and enhancement measures”. A latent accommodation study may help establish whether there are any additional capacities within the local economy to absorb migrant workers without harming the tourism sector. This is strongly recommended. The emerging Overarching National Policy Statement for Energy states that applicants should provide the existing socio- economic conditions in the areas surrounding the proposed development and could also refer to how the development socio- economic impacts correlate with the local planning policy. This analysis is absent from the Stage 1 Consultation document. The chapter should assess the implications of the project on the tourism industry both during and after the construction phase. A full assessment of the social and community infrastructure requirements of the proposals should be undertaken. Objectives should be set to control and manage the consequences of alcohol use, drug misuse and so forth. Other Issues It is recognised that the potential need to prepare an appropriate assessment will be determined during the Environmental Impact Assessment process. It is recommended that EDF Energy identify the list of projects which it intends to evaluate as part of the cumulative assessment, including the elements of the project. Reference to the potential cumulative effects of decommissioning of the B Station and construction of Hinkley Point C is welcome. However, all aspects of the decommissioning should be considered in detail with the construction process. Given the proximity of the proposed Oldbury Power Station to the Hinkley Point C development it is recommended that the cumulative effects be considered in full. It is recommended that significance criteria be developed by which cumulative affects may be evaluated.
EF
14) Other Environmental Issues
The EMMP should provide a mechanism to record commitments/agreements carried through from the Environmental Statement produced for all aspects of the development and including all aspects of consultation. Arrangements for long-term monitoring and its relationship to the future decommissioning strategy should be included in full. Provisions for long-term custody of the site and environmental responsibility should be set out as guidelines to underpin the future decommissioning strategy for the site.
Somerset County Council Geology, Soils and Land Use Findings of soil sampling not reported at Stage 1. There is potential for abandoned containers of lead arsenate. Ground gas monitoring results not reported at Stage 1. Depending on types of contaminants, there could be implications for health and safety, construction materials, water pipelines, utility trenches and landscaping scheme and further study is required in a number of areas. During construction, precautions needed to prevent contaminative water run-off from stockpiles. Ecology In order for the ES to address overall impact of the development (power station and associated development), it will require considerably more work to include identification of the precise combination(s) of options (AD sites) to assess overall ecological impact. SCC satisfied that sufficient data is now available in relation to the power station site to inform the EIA. Should permission be granted, there may be the need to carry out periodic surveys during the life of the project. Further information should be provided on in-combination and cumulative effects. Development has potential to affect designated sites. The ES should contain sufficient information to satisfy EIA and other UK legislation requirements, including Habitats Regulations. Any proposal must be considered in light of possible in-combination effects e.g. power station and Combwich Wharf on the SPA and/or SAC. Other proposals/projects may need to be taken into account. Historic Environment Site investigations of the archaeological resource have included a Desk Based Assessment and a geophysical survey. These surveys have identified a number of buried archaeological features including a small Roman settlement and potential prehistoric/early medieval occupation. The site is currently subject to a trial trench evaluation based on the results of the surveys. The results of this evaluation will be used to determine the nature, character, date and extent of remains on the site. The non-intrusive surveys show that the site has potential for remains in the form of settlements and associated activities so the information from the trial trenching is integral to formulating a statement of significance. Until this information is complete it is not possible to make any reasoned decision concerning the archaeological resource on the site.
Somerset Wildlife Trust Ecology:
14) Other Environmental Issues
EDF Energy should provide sustainable development which protects and enhances the rich natural heritage. Lack of strong environmental commitment and development will cause a wildlife deficit as no commitment to providing a comprehensive landscape-scale mitigation strategy to address all biodiversity impacts on and off site, short to long-term, and demonstrate project will benefit people and wildlife and demonstrate a true commitment. Strategy should be provided at start of construction to allow for habitats to establish, otherwise substantial biodiversity losses could accrue through direct destruction (particularly connective features) and disturbance. Should mitigate short to medium term impacts to local wildlife and generate a net gain for biodiversity through networked habitat creation around the extent of all new infrastructure development. A Biodiversity Mitigation Strategy should be prepared. The Trust seek assurance that BAP species and habitats (not statutory) will be conserved and mitigated – inconsistent treatment within the ESR. Approach habitat fragmentation through strategic mitigation and work with projects within the area as part of the new Regional Delivery Plan. Ensure other developments (Severn Barrage, housing development, transmission lines and other major projects) will inform the assessment. An examination of the cumulative impacts of this development with others proposed for the West Somerset and Sedgemoor Districts is important. The in-combination effects of housing development tidal energy schemes in the Seven Estuary, overhead electricity connection and other MIPs should be considered.
West Hinkley Action Group Hydrology and Drainage: Flood prevention measures at Newnham and Water Farm.
15) Other Hinkley Point C Development Site Comments
Consultee Comments
NHS Somerset Sought clarification on use, functioning and services available from the on-site medical facility and how this links to the existing Hinkley Point B facility. Will there be laboratories on site? To what extent will people based off-site use the on-site medical facility?
EF
Appendix A.6
TABLE OF COMMENTS ON ASSOCIATED DEVELOPMENT
Appendix A.6: Table of Comments on Associated Development
16) Overall Associated Development Strategy
Consultee Comments
Avon & Somerset Constabulary Concerned that the rise in the local population by the incoming workforce, might increase the demand for local policing services.
CABE Before the DCO is submitted, CABE would welcome the opportunity to review the auxiliary infrastructure development along side the developed proposal for the main reactor site.
Civil Aviation Authority Due to the anticipated potential for helicopter operations the authority recommends the use of aviation warning lighting.
English Heritage Strongly advise that the off-site associated development facilities are concentrated within a smaller number of sites, possibly in or around Bridgwater in order to avoid dispersing construction activity over a wider area. Require further information to appropriately assess the impacts of the proposed developments. Prepare a development strategy to assist with the understanding of the number of off-site associated developments and to minimise the impact on the historic environment. Issues relating to the impact of any designated and non-designated historic assets should be fully identified within each of the off-site options in addition to the presence of maritime and estuarine deposits and features. The off-site associated developments should maximise the potential for long-term legacy benefits, but only where it is in a sustainable location and accords with local and national policies. Housing should be designed to the highest standards and reflect the local vernacular.
Highways Agency Clarify any cumulative impacts of the Hinkley Point C development, which includes all of the proposed on and off-site associated development. Evaluate the impacts on the Strategic Road Network. Require further clarification on planning applications for the off-site associated development. Confirm whether all of the off-site associated development can form part of the main application to the IPC or whether such developments will need to be applied for separately under the Town & Country Planning Act 1990.
Minehead and District Chamber Would welcome worker accommodation in Minehead but have concerns about supply shortage and what effects this will have on of Trade and Commerce rental and house prices. Concerned that any short term economic gains will go to other areas and the long term legacy will be a defunct tourism industry,
EF
16) Overall Associated Development Strategy
housing that can only be afforded by people from outside the area, a worse quality of life for residents in the area and an inadequate transport network.
Natural England Assess each proposed development in relation to its impact on protected/designated sites, biodiversity, landscape, access and land management. Incorporate appropriate mitigation strategies for each development proposal, in the DCO application.
Parish of Stockland Bristol Concerned that the off-site associated development will have a devastating effect on Cannington and the surrounding villages.
Parrett Internal Drainage Board Any off-site associated developments should seek to reduce local flood risk, in accordance with the PPS25. Any outline proposals for works at the off-site associated development should be subject to early consultation to determine any design criteria or conditions that the Board may wish to apply to their construction.
Royal Mail Concerned that the increase in traffic and activity will place heavy reliance on the A38 and A39 and on J23 and J24 of the M5. Registered an objection to the proposals on the grounds that increased congestion could interfere with its day-to-day operations.
Sedgemoor District Council and The document should set out the purpose of the Consultation document in the context of the approach to planning applications West Somerset Council and the Development Consent Order processes that will be required for each element. It is not clear how the planning permission will be secured for the residential campus development. The associated development strategy that has informed the overall distribution of associated development proposed by EDF Energy has not been fully explained or justified. The Consultation document lacks clear justification of the scale and nature of individual proposals. Legacy uses seem to be a by-product of the Area of Search in terms of the need to find a future use for the site once it is no longer required to support the Hinkley proposals. The EDF Energy estimate that just under half of the total peak construction workforce will be local (defined as living within a 90 minute commute) is questioned. It is unclear whether Combwich Wharf will be dealt with by a separate Environmental Statement or whether it will be assessed as part of the main development site.
Somerset Chamber of Support the company’s approach to manage the impact of the off-site associated development and its desire to leave a positive Commerce and Industry legacy for Somerset.
Somerset County Council Very little information presented within the Consultation Report about developments associated with the new nuclear build.
16) Overall Associated Development Strategy
Require further justification of the proposed off-site associated development sites. Consider the impacts that the proposed developments may have on the wider area. Require a comprehensive strategy establishing the need for the off-site associated development. Explain how the proposed developments will be brought forward effectively. Provide an overall phasing strategy to show how the delivery of associated development coincides with the predicted level of people and goods movements during the construction and operational phases of HPC.
Somerset Wildlife Trust Support the delivery of a sustainable transport and accommodation strategy. Devise a mitigation strategy that focuses on tackling biodiversity loss across all sites.
South West Regional Support the need for off-site associated development and advise that they are provided in a sustainable manner, appreciating Development Agency other development initiatives being progressed in the area in terms of cumulative impact.
Taunton Chamber of Commerce Support for measures that reduce the impact of construction, workers traffic, impacts on the road network etc.
Wessex Water Concerned that the rate of growth in Sedgemoor and West Somerset may increase as a result of the proposed developments and therefore some infrastructure schemes may need to be promoted earlier than originally planned under the Local Development Framework Core Strategy. Further discussions may be required to understand the requirements for the project.
17) Overall Accommodation Strategy
Consultee Comments
Bridgwater College Support the proposal to disperse the workforce as it would provide opportunities for integration.
Burnham-on-Sea and Concerned that the proposals do not reflect the accommodation opportunities Burnham and Highbridge have to offer. Highbridge Town Council
Fiddington Parish Council Before large campus accommodation blocks are considered, explore the potential of using local accommodation.
Minehead and District Chamber Support a new build hostel in Minehead and feel that it would be a more suitable location than Williton. of Trade and Commerce Concerned that tourists may abandon the area if they have difficulty finding B&B accommodation. The Chamber fears that an increase in occupancy during the winter months will not compensate for the loss of bed space during the summer months.
Nether Stowey Parish Council Concerned that increased demand for residential property will exacerbate current problems of affordable homes for young
EF
17) Overall Accommodation Strategy
people. Concerned about loss of community identity and anti-social issues, as a result of a large influx of mainly male workers. Request traffic management plans in the area to increase safety and support the existing pressure on local roads. Consider further (limited) development in Nether Stowey, to the north and east of the existing settlement. Concerned about the long term impact on villages, including increased pressure on public services, e.g. medical centres and schools.
Parish of Stockland Bristol Concerned about loss of community identity and anti-social issues, as a result of a large influx of mainly male workers. Concerned about the long term impact on villages, including increased pressure on public services, e.g. medical centres and schools.
Quantock Hills AONB Consider the impact on views from the Quantock Hills AONB, including night views.
Sampford Brett Parish Council Support both Taunton Deane and Nether Stowey for accommodation development.
Sedgemoor District Council and No explanation is provided on how planning permission will be secured for the residential campus development proposed. West Somerset Council It will be necessary for EDF Energy to provide a fuller explanation and justification of the accommodation strategy during the Stage 2 consultation phase. Proposed legacy uses should be central to the overall strategy and a key consideration in site selection. Accommodation for construction workers should achieve the design standards expected by the Council’s for any permanent development. Opportunities for accommodation to help meet identified housing needs in the District should also be investigated. Bridgwater represents the greatest opportunity in Sedgemoor for accommodating construction workers in the most sustainable way. There is a greater availability of brownfield sites and regeneration is actively promoted. The quantity of bed spaces currently proposed for Cannington should be significantly reduced. The Council would welcome further dialogue with EDF Energy around legacy uses for accommodation and the potential for distributing construction worker housing to a series of sites in Williton, Watchet and Minehead. EDF Energy estimates that just under half of the total peak construction workforce will be local (defined as living within a 90 minute commute), local labour content in more recent studies is substantively below this assumption level, this could result in a possible need for testing a higher accommodation bed space requirement. Should it be found that there is a higher proportion of migrant workers than currently expected the Council’s preference is for the majority of additional worker accommodation to be provided in Bridgwater. West Somerset Council would also be willing to
17) Overall Accommodation Strategy investigate further construction worker accommodation options in Watchet and Minehead. Survey work undertaken by EDF Energy to understand the availability of different accommodation types is not referred to in the Consultation document, this should be set out in further detail in the Stage 2 Consultation. Particular areas that must be covered are as follows: Tourism accommodation types – an EIA Socio-Economic Chapter should assess the implications of the project on the tourism industry both during and after the construction phase. Private rented – there is concern that relatively high earners will displace existing residents by driving up the cost of privately rented accommodation. Owner occupation – consideration should be given to the impacts of the projects on affordability. Campus development – clarification is required as to how the campus development requirements have been calculated. Outages for Hinkley B – increasing outages for Hinkley B are not taken account of within the accommodation strategy. Management arrangements – no detail is included on how the accommodation strategy is to be managed. The existing accommodation strategy is in fact a temporary accommodation strategy and does not extend to any wider impacts. Legacy use and design of residential campus development Consideration of suitable legacy uses will need to be informed by in depth understanding of the following factors: The anticipated proportions of family and single person accommodation. Affordable housing provision which is seen as a priority legacy use. Provision of student accommodation in appropriate quantities and locations is supported by Sedgemoor District Council, evidence should be submitted on the on-going viability of this. Provision of sheltered housing in appropriate quantities and locations is supported by the Councils where the need for a facility and on-going viability of accommodation can be demonstrated. The design of accommodation to provide for flexibility of use is an important consideration, this will provide the greatest scope for legacy use strategies. Whilst no evidence has been submitted to support the creation of additional hotel accommodation or hostel development the shortage of good quality hotel provision in Bridgwater is recognised and a higher value facility consistent with the Bridgwater Vision would be considered. Social and community infrastructure
Full assessment of the social and community infrastructure requirements of the proposals should be undertaken for the sectors
EF
17) Overall Accommodation Strategy
listed below: Libraries, community centres and cultural facilities Social services Education Emergency services Health Sports facilities, recreation and open space Further information should be presented around consultations undertaken with infrastructure providers such as Avon and Somerset Constabulary and Somerset NHS Trust. Social cohesion
The objectives set for the accommodation strategy should differentiate between different issues impacted upon by the influx of a large migrant population which includes both substantive and perceptual effects. It should be demonstrated that the strategic planning context for Bridgwater presented in the emerging RSS and Core Strategy Preferred Option has been considered. Cannington Village has been identified as a potentially suitable location for the siting of a campus for 120 construction workers through refurbishment of existing college accommodation or new build accommodation. Account should be taken of the Conservation Area setting. Consideration should be given to the further site in the Bridgwater area that would be suitable for the development of accommodation for construction workers. The suggested sites are: Redevelopment of former Gerber factory at Wembdon Road, Bridgwater Chiltern Road Caravan Site, Chiltern Trinity Redevelopment of Hayegrove School Land east of Taunton Road Bowerings Mill, The Docks Land at Monmouth Street Former Bigwood and Staples, Church Road The rationale for providing a park and ride facility and residential campus at Williton is understood to be:
17) Overall Accommodation Strategy
A park and ride will capture construction workers travelling from the west minimising the number of vehicle movements along the road network to the Hinkley Point C site although there remains questions regarding the large capacity of the park and ride facility. New development will contribute to the provision of services, employment opportunities, infrastructure and transport in and around the town. The areas of land have potential to accommodation development in locations that promote greater self-containment of the settlement.
Somerset County Council Support the promotion of non-car based transport to and from the accommodation sites. Provide a travel plan for each campus development detailing parking and access arrangements. More information required to offer justification for locating 700 workers on the main development site. There is no robust evidence base that establishes the need for this development. If it is necessary then the company should state how potential social issues will not have a negative impact.
Somerset Leisure Support plans for sustainable buildings and request the opportunity to discuss the proposals with the company.
Somerset Wildlife Trust In order for accommodation to be sustainable, the company needs to offer an end purpose for the local communities.
Taunton Chamber of Commerce Believe that Taunton Deane is a good area for people to settle in and has a number of exceptional skills, both public and private.
Taunton Deane Borough Suggest development of accommodation within Taunton Borough. There are a number of sites with planning permission which Council could deliver workers' accommodation quickly and to a high standard. There is already an existing need for affordable housing or nursing/student accommodation which can be considered for future use, following the company’s cessation of use.
Wembdon Parish Council Concerned about increased demand for residential property, loss of community identity due to influx of temporary and permanent workers, increased pressure on public services including the primary school and anti-social, law and order problems from a large influx of unaccompanied male workers. There is limited potential for the development of workers accommodation blocks in Wembdon. There has been the suggestion that such blocks may be built on the old Gerber Fruit Juice factory site and whilst this may appear to be an attractive legacy opportunity for low cost housing, the impact in the community and associated traffic would need to be carefully considered. Suggest that any accommodation in Wembdon should be in small developments of up to 10 dwellings and should be for the family segment of the workforce, as they would be more likely to contribute to village life. Past experience suggests that the influx of large numbers of contract workers on a Friday and Saturday night might create certain tensions.
EF
17) Overall Accommodation Strategy
Concerned about the impact on schools in the local area.
Williton Parish Council Explore the option of a campus at Nether Stowey.
18) Overall Transport Strategy
Consultee Comments
Avon and Somerset Concerned about the increased volume of traffic on the local roads and infrastructure. Constabulary
Bridgwater Education Trust Concerned about the transport strategy and use of the A38. Clarify whether EDF Energy will be creating cycle paths. Request improved transport links from Bridgwater to Hinkley Point C, such as shuttle buses or a rail link.
Bridgwater Town Council Require further information in terms of transportation and traffic modelling. Such modelling should include traffic from Little Sydenham Farm development, the new Bridgwater Hospital development and the current South Bridgwater development. Also require an enhanced level of survey work to give a coherent transport investment package. Not convinced by arguments that the park and ride facilities and freight logistics are sufficient without additional highways infrastructure over and above a Cannington bypass.
Building Schools for the Future Ensure continued safety of the new Haygrove and Penrose site and Chilton Trinity College. Both schools are adjacent to the A39 Somerset and consideration will need to be made to cycle and footways across the town.
Cannington Parish Council Request the implementation of traffic calming methods in Cannington.
Cannington Woman’s Institute Concerned about the developments’ potential impact on the safe and efficient operation of the A39 west of Bridgwater. The A39 between Bridgwater and Cannington is already overloaded and dangerous – extra traffic will increase road danger to children, noise and exhaust pollution.
Devon County Council Outline as part of the sustainable travel plan, the importance of providing walking/cycling measures and facilities, alongside other more innovative measures (e.g. bus vouchers, cycle training, bicycle users group, car sharing, and car clubs). Provide a traffic mitigation strategy and distribution logistics strategy, ensuring impacts of the facilities on local roads is fully mitigated. Clarify how the proposed park and ride strategy will integrate with car parking provision on site, in the rest of Bridgwater and
18) Overall Transport Strategy
within the wider sub-regional transportation and movement strategy. Consider the possible effects of the development on Mendip District, in terms of traffic generation and impact on transport routes.
English Heritage Support a green transport strategy. Encourage the development of a master plan of transport issues and would welcome the opportunity to be involved in the consultation of it.
Fiddington Parish Council Opposed to all off-site associated development due to the traffic implications.
Haygrove School The current EDF Energy proposal does not include the link road from Dunball and has the freight yard at Cannington rather than the Express Park – both of which have the effect of more traffic along this stretch of highway.
Highways Agency Concerned that the transport proposals will not mitigate against the negative impacts. Support the provision of a transport strategy which seeks to keep construction traffic to a minimum, particularly during peak hours. Expect an objective dedicated to minimising any detrimental impact on the local and Strategic Road Network. Support the measure to move workers outside peak hours. The company should demonstrate that the development proposals will have a significant negative impact on the local and Strategic Road Network at other times of the day. Request to see a strategy in place between the company and E.ON to identify any potential cumulative impacts to the Strategic Road Network and any peak periods in the construction programme. Consider how this can be properly managed and if necessary, mitigated. This could include phasing the construction periods and/how materials and employees will be sourced. This approach is in line with the draft Nuclear NPS which is currently out for consultation and to which the Agency will be providing a formal response in due course. Support the promotion of sustainable modes of transport by promoting non-car modes of transport through water freight logistics. Clarify how the company plans to maximise opportunities for walking, cycling and public transport to the proposed park and ride facilities. Disappointed to note that rail services are not considered to be a practical solution of transporting construction workers to Bridgwater and then to site. Need further information on why rail services are not being enhanced to minimise travel by road. Support the implementation of a Travel Plan with ongoing monitoring and management strategies. HA to continue to advise on mitigation measures for the Travel Plan but largely supportive of existing measures (although further detail is requested). Ensure that there is not a significant negative impact on air quality in close proximity to and including the Strategic Road Network.
EF
18) Overall Transport Strategy
Request a copy of the air quality assessments undertaken to date. Support a staggered approach to construction at J23 and J24 and would seek to ensure that the construction periods do not coincide in order to minimise any cumulative impact. Request further information from the traffic modelling and transport strategy. Ensure that the Strategic Road Network can continue to operate safely and efficiently with the additional trips generated by the power station. Provide further details on how changes in workforce origin will impact upon the Strategic Road Network. Provide further information on likely worker travel patterns (arrive Sunday/Monday, leave Friday) and the effects on the Strategic Road Network. Assess other junctions on the Strategic Road Network within the identified 90 min commute zone. Collate and analyse personal injury accident data at any point where the development results in an impact on the Strategic Road Network. Acknowledge that the form of the spoil is not yet known and as a consequence the company is considering several options for its disposal. As one of these is 'off-site via road to other designated waste management facilities in the south west', the Agency will require further information to highlight if this will result in an impact on the SRN.
Landowner Bridgwater College Transport infrastructure from the M5 through Bridgwater and Cannington to Hinkley is already very stretched especially during the summer holidays.
Mendip District Council Consider the possible effects of the development on Mendip District, in terms of traffic generation and impact on transport routes.
Minehead and District Chamber Request improvements to the A39 from Williton to Minehead. Immediate improvements to West Somerset Railway and the of Trade and Commerce potential for sea travel could, in the short term, help compensate the issues by drawing tourists to the area. Concerned about impact of additional workers on the road system.
Nether Stowey Parish Council Request traffic management in the area to increase safety and to support the existing pressure on the local roads. Concerned that the proposals will impact on the safe and efficient operation of the A39 west of Bridgwater. The A39 between Bridgwater and Cannington is already overloaded and dangerous – extra traffic will increase road danger to children, noise and exhaust pollution.
Parish of Stockland Bristol The freight consolidation depots should be placed near to the motorway junctions 23 and 24, and then to the proposed power station via a new road suggested by CEGB. A link could then be made into Combwich Wharf.
Passenger Focus Welcome the provision of additional public transport facilities for the local community through the use of the park and ride
18) Overall Transport Strategy
facilities. Clarify whether there will be periods where shift changeover times mean that workers will have to access the local bus service. If so, negotiations with local bus operators will be necessary to ensure adequate capacity is provided. Concerned about plans to use rail shuttle buses from the station to site, as the current train service is already running to capacity at peak periods and any additional influx of people could create serious issues. Buying more carriages or trains is not the solution as there is a national shortage.
Sedgemoor District Council and A fuller explanation and justification of the transport strategy will be required during the Stage 2 Consultation phase. West Somerset Council If EDF Energy’s estimates that just under half of the total peak construction workforce will be local are incorrect, it is possible that further purpose built accommodation would be required, which would also have additional transport implications that would need to be modelled. If tourism accommodation types are considered to house workers these may be in remote locations and the impact of traffic movements should be considered. Comments On Transport Strategy
The broad thrust of EDF Energy’s transport strategy which seeks to minimise disruption to the local community and promote sustainable modes of transport is therefore welcomed. A strategic transport investment package for Bridgwater will be sought as part of the planning obligations. Ongoing transport modelling to inform transport proposals should take account of the cumulative impact of other development proposals and reference should therefore be made to the strategic planning context.
Freight consolidation strategy
The Stage 1 Consultation document does not explain the need and reasoning behind the scale and the distribution of the freight sites and in particular the requirement for a road freight consolidation facility at Cannington is not understood. The Councils make the following comments: Freight Storage and consolidation should be dealt with at the point closest to source, road freight would therefore be dealt with at an M5 junction location while water borne freight and abnormal loads would be managed at Combwich Wharf. The refurbishment and use of Wharf close to Dunball and as an integrated facility with the proposed freight consolidation facility at search area Junction 23-A is suggested to minimise road based movements through Bridgwater. The use of a temporary jetty at the site for aggregate import is supported.
EF
18) Overall Transport Strategy
Further clarity is required on legacy and/or restoration proposals for temporary freight consolidation facilities. Park and ride strategy
It will be important to understand the strategy and assumptions that have guided the distribution and scale of Park-and-Ride facilities. The concerns and queries of the Councils are as follows: Temporary development on greenfield sites is to be avoided if possible. Consideration should be given to the viability of Park-and-Ride facilities as a legacy benefit. The Councils would welcome discussions over bus routes in relation to the Park-and-Ride services in Bridgwater. The Councils recommend joint discussions between EDF Energy, Somerset County Council and bus operators to understand opportunities for high frequency public transport services to be integrated with the Park-and-Ride services as a legacy benefit. Walking and cycling
Measures to maximise walking and cycling from construction worker accommodation to Park-and-Ride services are encouraged by the Councils. Rail
The Travel Plan should include proposals to secure improved rail services given the definition of local travel as a journey of 90 minutes or less. The Plan should also set out proposed rail station investment and refurbishment that will facilitate onward journeys by bus, cycling and walking. Projects that should be investigated include:
Upgrading and reinstatement (between Bishops Lydeard and Taunton) of the West Somerset line to provide increased line speeds and commuter services between Taunton and Minehead. Increased frequency of stopping services for Bridgwater. Station investment and refurbishment in Bridgwater and the surrounding area linked to the Bridgwater Vision. Travel Plan
The setting of targets is encouraged so that travel behaviour can be monitored and evaluated.
Somerset Chamber of Support the approach to limit detrimental traffic movements. The company needs to be mindful not to turn Bridgwater or Commerce and Industry Cannington into an economic ghost town where people drive around/through rather than stopping to do business. Particularly interested in proposals to upgrade the rail links between Taunton and Minehead. Proposed legacy: open up rail traffic
18) Overall Transport Strategy
from anywhere in the UK and Europe; reduce existing commuter traffic on A358; reduce amount of tourism activity carried out by road; improve accessibility to West Somerset to encourage more tourists thereby increasing economic activity.
Somerset County Council Insufficient evidence has been provided to enable the Council to comment on a preferred transport strategy. Clarify the reasoning behind the proposed transport strategy. Clarify how the impact of trips outside the SATURN model peak hours will be assessed. All impacts and environmental issues should be assessed as part of the modelling process. Address the effects of seasonal variations in traffic volumes, specifically on the M5. Submit a freight management strategy at Stage 2 Consultation. Request a multi-modal trip generation assessment. Assess as part of the Environmental Appraisal, traffic-related noise, vibration and air quality. Outline how car sharing will be enforced. Fully explore opportunities for walking, cycling and public transport, in respect of the accommodation centres. Provide evidence that ‘The Jetty’ will offset 170 HGV movements per day. Outline how the traffic impact of Hinkley Point C will be mitigated, other than by the Cannington bypass. Enhancements to the rail service are not clearly addressed in the Stage 1 document. Evidence the demand for rail shuttle buses from stations to the site. The Travel Plan should deal with the movement of people only. There should be a Freight Management Strategy dealing with the movement of goods. If spoil is to be taken away by road, fully assess both the routes and sites for disposal. Provide evidence to show that the Bridgwater Bypass is not required plus a quantitative assessment of the likely impact on the BNDR by carrying Hinkley traffic. Demonstrate accessibility of the park and ride facilities by a range of transport modes, including alternatives to private cars. Provide detailed traffic impact assessments on the potential adverse impacts of the park and ride facility on J23, Dunball roundabout and J24. Ensure that statements such as ‘Bridgwater network is accustomed to taking heavy vehicles’ and ‘roads have easy access to Hinkley, particularly from Williton’ are supported by quantified and validated assessments. Concerned about the increase of HGV’s in residential areas. Accept the benefits of the freight logistics to minimise the traffic impact on the local highway network. Request that the transport assessment scoping report is prepared which clearly sets out the proposed methodologies, data
EF
18) Overall Transport Strategy
sources, modelling scenarios and limits to the assessment, in accordance with Dft/DCLG Guidance on Transport Assessment. Outline how the Oxford Brooks data has been applied to traffic routing and request a data collection report explaining what data has been collected and how it has been applied. All associated developments (and HPC) should be designed and modelled to ensure that the highway layout is suitable and what, if any, improvements are necessary.
Somerset Wildlife Trust Examine the use of public transport needs especially regarding shuttling of workers. Insufficient information presented to allow a determination of likely ecological effects at these locations. The company should select a sustainable site with minimal ecological impacts. Deliver mitigation and biodiversity gain as part of a biodiversity management strategy for development. Insufficient data available to determine what level of impact could occur to the Severn Estuary SPA, SAC and Ramsar site.
Spaxton Parish Council Concerned that additional traffic will increase congestion on the A38 and A39. Concerned about the scale of the off-site associated developments.
Taunton Chamber of Commerce Support the proposals to lessen the impact of construction worker traffic on the road network. Without such measures Taunton Deane could be adversely affected by additional traffic movements. Concerned about the additional use of the M5, as this is the only proper trunk route in and out of the south west. The M5 is often heavily congested, especially in spring and summer. Congestion can impact on business traffic in and out of Taunton.
Taunton Deane Borough Encourage good access for workers between Taunton and Bridgwater by rail, supported by a good bus service to site. Council Suggest the potential for opening the rail link between Taunton and Williton as part of the solution during construction phase. Interested in the opportunity to open the station at Wellington to provide access from the east.
The RAC Foundation for Increased accommodation in West Somerset and Minehead would, in turn, increase journey and leisure time on the A39. Motoring Local roads need significant capital improvements to aid traffic flow both during and after the construction phase. Support measures that will reduce pressure on the road network and improve transit times and quality for motorists, e.g. increased usage of railway and other transport modes. Welcome proposals to align shift patterns to non-peak traffic. There are concerns that the A39 already underperforms during off- peak travel times. Concerned that without enough road investment the traffic generated by the project might discourage tourists from visiting West Somerset. Request that the company considers the site of the redundant factory on Puriton Level as a search area for off-site non-residential
18) Overall Transport Strategy
development. The site is close to Junction 23. There is an existing but disused railway track bed and overland motorway bridge providing access from the Bristol-Taunton main line and apparent scope for restricted access and egress from/to the southbound M5, jointly utilising the rail track bed east of the motorway. This would take rail-borne nuclear movements out of central Bridgwater. There would be a need to avoid HGV traffic through Puriton and Woolavington villages. As an alternative to Puriton Level, the company should evaluate a point road/rail bridge across the River Parrett in the vicinity of Dunball Wharf. This will help to take nuclear movements out of Bridgwater.
Wembdon Parish Council Concerned about the over-reliance on A39. In the event of a major incident on the M5 between J25 and J22 motorway, traffic diverts onto the A38 through Bridgwater leading to severe congestion. The Parish Council has substantial concerns and reservations about the effectiveness of the transport strategy and in particular the impact on the safe and efficient operation of the Northern Distributor Road and the A39 west of Bridgwater. Concerned about increased traffic congestion on the BNDR (Homburg Way), Quantock Road and A39 between Bridgwater and Cannington. Traffic will take a rat-run through Wembdon, along Wembdon Hill and Wembdon Rise. Concerned about a reduction in road safety, in particular the crossings of the BNDR at Chilton Street, Wembdon Rise and at the Quantocks Road roundabout and also the crossing at Wembdon Rise for primary school children. The LDF proposes a large housing development on Cokerhurst Farm, which will increase the amount of congestion on the A39/Quantocks Road. This will be exacerbated by the relocation of Haygrove and Penrose schools to Kimmerton Lane/Queenswood Farm. The existing junctions at Wylds Road and Bristol Road are inadequate to meet large increases in traffic and the BNDR is regularly congested. The Bristol Road and Taunton Road and already inadequate. Any additional traffic will lead to gridlock.
West Hinkley Action Group Request effective mitigation measures to deal with increased traffic for those households in the local community affected by changed traffic patterns.
Williton Parish Council Concerned about the exit route from the Tower Hill site and traffic issues surrounding Egremont Corner. Concerned about the A39 and the need for significant improvements.
19) Cannington
Consultee Comments
Cannington Parish Council Concerned about potential impacts to the village, including loss of village character and identity and impacts of an increasing
EF
19) Cannington
male population. Does not consider a new village centre/facility as an appropriate compensation. Not opposed to the principle of the development. Concerned that the village does not have the appropriate facilities for construction workers. Opposed to a temporary freight logistics facility in the village and suggest that there are better site locations on brownfield land in Bridgwater. Opposed to the proposed park and ride facilities as there are better sites located closer to the motorway. Suggest implementing traffic-calming measures within the village, to make the journey slower and more inconvenient for those who try to cut through the village. Dismiss the idea of leaving CAN-C accommodation to affordable housing or student residential use, as the benefits will not outweigh the loss of village life.
Cannington Women’s Institute Opposed to the freight logistics at Cannington. Opposed to a campus for 350 male workers in the centre of Cannington village. Concerned about potential impacts to the village, including loss of village identity. Concerned about the impacts of traffic on the village, even with proposed road improvements. Suggest that the off-site associated developments may increase the risk of flooding in Cannington. Extra policing might be required as a result of the workers in the village. Object to a park and ride facility for 900 cars.
English Heritage Recommend that no development occurs in Cannington and would like the associated development strategy reassessed with the benefit of historic assets clearly considered. Discounted the search areas for CAN-A and CAN-B on the grounds that they would impact on the village setting. Suggest that in addition to temporary use of the quarry, CAN-D may be suitable. Suggest that temporary use of the quarry for spoil may be suitable. The cumulative impact of the different forms of off-site development in Cannington will have a significant and potentially detrimental impact on the character of this settlement and in particular upon the character and appearance of the conservation area and its numerous historic individual and groups of buildings.
19) Cannington
Reassess the strategy for the off-site development in Cannington with the benefit of the historic assets clearly considered. Provide a clear and robust evaluation of the contribution that the water meadows to the south of the village play in contributing toward the character and historic value of this settlement.
Environment Agency Advise that all four search areas fall wholly or predominantly within flood zone 1, meaning that they are at little or no risk of flooding. Suggest that as the Cannington Brook (Flood Zone 3b) runs through CAN-A, the site layout requires further investigation to establish the viability of development in light of the floodplain constraints that this poses. Expect water quality monitoring points to be implemented along the Brook. CAN-A offers potential for flood protection scheme for Cannington. Recommend that all sites are subject to a FRA. Recommend that drainage and pollution measures are investigated at the proposed developments. Accept the development of CAN-C and CAN-D in principle. However CAN-A offers the potential to implement a flood protection scheme for Cannington, leaving a positive flood risk reduction legacy for the village. Suggest that further investigative works are required at CAN-A, CAN-B and CAN-C with regards to groundwater abstractions. Query what prevention measures would be put in place to avoid land contamination. Advise that any spoil taken off-site for disposal will need an appropriate permit in place before any disposal can take place. Concerned that Cannington Creamery is very close to the development zone. Cannington Creamery has two very important licensed groundwater abstractions in this area, these abstractions must be protected from any contamination that may be caused by historic contamination. Special measures will be required to protect groundwater quality at this location. These measures should be disclosed as early on into the process as possible. There is a historic landfill site known as 'Field No 8191, Manor Farm' to the south of this area- under PPS23 this will need to be investigated further. Pollution prevention control should be adhered to throughout the construction and operation of the station. Suitable monitoring points along the Cannington Brook park and ride and drainage and pollution prevention measures should be looked into. Appropriately sized interceptors will be required. Any associated welfare facilities (toilet blocks) should have adequate treatment facilities developed or a mains connection. Any associated discharge consents or agreements with the local water company to take the sewage must be in place before use. A contained drainage area may be required for the freight logistics facilities depending on the eventual details produced i.e. what materials are going to be present, how many vehicle movements. Ensure pollution prevention methods are installed in the design,
EF
19) Cannington
to reduce the chance of contaminated surface water run off reaching the watercourses. The area to the north of the CAN-B site overlaps with Putnell Moor Site of Nature & Conservation Interest (SNCI), which is noted for marshy grassland and rhyme system rich with nationally scarce vascular plant species. Any advances to protect and enhance this area would be supported.
Highways Agency Expect all proposals to be supported by a robust traffic assessment and to be incorporated into the travel plan as appropriate.
Landowner Bridgwater College Concerned about the location of the search areas in relation to the nearby farm. There are potential impacts on access, noise, vehicle movements and flooding if the development proposals are not properly managed. Recommend building recreational/sporting facilities alongside accommodation to form part of the overall recreation/sporting proposal for the village. By coordinating these facilities in a managed way, they will support the workforce, community school and college needs. Concerned about the traffic and safety implications at Cannington village. Request the implementation of traffic-calming measures, as any increase in traffic along the Rodway would be of concern to the college. Ensure that the workforce is managed effectively to ensure that the bypass is used rather than 'short-cuts' through the village. Suggest the purchase and refurbishment of Cannington House as an alternative accommodation proposal. The house is currently owned by Brymore School and is used as dormitory accommodation. The college would like it used as part of a larger development of Cannington Court as an HE Leadership and Management Training Centre with a particular focus on bespoke training for the nuclear industry and its supply chain. This development currently forms part of the wider SCC led University Partnership Project and would provide a residential centre for the delivery of leadership and management training at Supervisory/Higher Education and Postgraduate Level. Support proposals to develop recreational/sporting facilities alongside worker accommodation. Would consider an option to develop a 120 ensuite residential resource on the college’s land with longer term benefits realised in additional/replacement residential accommodation for the college. A new sports hall and all weather pitch could be made available for workforce and students. Prepared to look into the possibility of using accommodation at Priory Lodge although replacement accommodation would be required including at Cannington Court where a Leadership and Management Training Centre with a bespoke training for the nuclear industry could be provided.
Parish of Stockland Bristol The proposals are ill thought out and would have a devastating effect on Cannington and the surrounding villages. Raised concerns over location of campus in relation to the college.
19) Cannington
Quantock Hills AONB Provide reference to the potential impacts on visual amenity and view from the Quantock Hills AONB. Update the baseline information to reflect the actual distance from the AONB including night views.
RAC Foundation of Motoring Ensure that access constructed to the Cannington South search area (CAN-A) does not adversely affect the flow of traffic through the bypass.
Sedgemoor District Council and The number of campus bed spaces proposed for Cannington (320 bed spaces) is considered out of balance with that proposed for West Somerset Council Bridgwater (500 bed spaces). Sedgemoor District Council suggests that there may be scope for accommodating a limited number of construction workers in Cannington by one or both of the following means: Accommodation of construction workers in refurbished college residencies as proposed for search area CAN-C. Accommodation of construction workers and their families in dwellings provided on a rural exception site which would be made available as affordable housing and/or sheltered housing for the elderly. Freight consolidation strategy The requirement for a road freight consolidation facility at Cannington is not understood and Sedgemoor District Council has specific concerns about the proposals on greenfield land. Park and ride strategy The scale of the proposed park and ride facility at Cannington is questioned on the basis that temporary development on greenfield sites is to be avoided if possible. Observations on Cannington South (CAN-A Search Area)
The Stage 1 Consultation document does not identify that Cannington Brook is a designated County Wildlife Site where legally protected species have been recorded. It is unclear how the proposals for Search Area CAN-A contribute to the objectives of the Councils emerging Core Strategy as they do not reflect the scale and character of the envisaged role of Cannington. It is the initial view of Sedgemoor District Council that Search Area CAN-A is not suitable for the development proposed: Residential campus – Bridgwater should be the focus for residential development proposals with the CAN-C Search Area being the preferred location for a limited amount of construction worker housing in Cannington. CAN-A may be suitable for a modest amount of housing if a pressing need for construction worker housing at Cannington is demonstrated. A potential hotel use would be contrary to policy which seeks to locate such uses in towns. A large scale of Park-and-Ride facilities proposed at Cannington is questioned and will require further justification.
EF
19) Cannington
Proposals for freight consolidation facilities at Cannington are not supported by Sedgemoor District Council at this time. In the circumstances that EDF Energy decided to progress proposals for CAN-A the following matters should be addressed: EDF Energy to demonstrate why permanent buildings could not be located within the existing settlement boundary. Full restoration or legacy proposals would need to be presented where temporary Park-and-Ride and freight consolidation sites are to be located on agricultural land. Proposals are required to demonstrate how the setting of Cannington Conservation Area would be protected or enhanced and how the amenity and biodiversity value of Cannington Brook and the green wedge would be safeguarded. Further consultation with Cannington Parish Council and Sedgemoor District Council is required to understand opportunities for legacy use of campus recreation facilities for instance as a community centre, there may also be potential for legacy use of worker accommodation as affordable housing.
Further observations on technical issues
Transportation Advantages of providing a residential campus, Park-and-Ride facility and freight consolidation facility in the CAN-A Search Area include: A reduction in the number of vehicle movements through or around the village. A good relationship to the existing local road network and Western Cannington Bypass route option. Large parts of the search area are located outside the floodplain. It is uncertain why the consolidation facility is proposed at Cannington when there is one at Bridgwater which could handle road freight. Socio-Economic Issues Further information is required on the demographic make-up of households to be located in Cannington so that health, education and other community infrastructure requirements can be assessed. Terrestrial Flora and Fauna Further information is required on how the Cannington Brook will be protected/enhanced through the project. Landscape and visual
19) Cannington
Sedgemoor District Council considers there will be a significant impact on the village of Cannington much of which is designated as a Conservation Area. Land Contamination and Waste Further contaminated land assessments/surveys will need to be undertaken by EDF Energy and reviewed and approved by Sedgemoor District Council when they are completed. Air Quality Further air quality assessments are to be undertaken by EDF Energy the methods and results will need to be approved by Sedgemoor District Council. Observations on Cannington North West (CAN-B Search Area) Policy presumption is for strict control of development outside the defined settlement boundary of Cannington although it is acknowledged that there could be a special case for associated development linked to Hinkley. It is the initial view of Sedgemoor District Council that Search Area CAN-B is not suitable for the development proposed for the following reasons: The large scale of Park-and-Ride facilities proposed at Cannington is questioned and will require further justification. Proposals for freight consolidation facilities at Cannington are not supported by Sedgemoor District Council at this time. Cannington Quarry is a designated County Geological Site and a site where significant archaeological remains have been recovered in the past. Should proposals be progressed for CAN-B development schemes would need to address the following matters: EDF Energy to demonstrate why permanent buildings could not be located within the existing settlement boundary. Full restoration or legacy proposals would need to be presented where temporary Park-and-Ride and freight consolidation sites are to be located on agricultural land. Proposals are required to demonstrate how the setting of the Scheduled Monuments would be protected or enhanced. Further observations on technical issues Transportation The advantages of providing a Park-and-Ride facility, freight consolidation facility and soil disposal site at the CAN-B Search Area are: The uses would be located away from residential properties. Good potential to provide a combined road and water borne freight consolidation facility.
EF
19) Cannington
The quarry is located relatively close to Hinkley. CAN-B is well located in relation to northern junctions of the Cannington Bypass route options. Geology, soils and land use As a designated County Geological Site the use of Cannington Quarry as a spoil tip would not be permitted unless a full assessment of alternatives is presented along with a plan to provide compensation for the loss the quarry site. Landscape and Visual Residential properties adjacent to the site would need to be buffered and well screened by landscape planting from the proposed development. Land Contamination and Waste Further contaminated land assessments/surveys should be undertaken by EDF Energy and reviewed and approved by Sedgemoor District Council. Air Quality Air quality assessments will need to be undertaken and the methods and results will need to be approved by Sedgemoor District Council. Observations on Cannington Central (CAN-C and CAN-D Search Areas) Proposals to refurbish existing accommodation in Search Area CAN-C are supported by Sedgemoor District Council subject to the detailed designs being finalised and approved taking account of the Conservation Area setting. Search Area CAN-C is the Council’s preferred option for a campus development of limited scale in Cannington. Further observations on technical issues Archaeology and Cultural Heritage Search Areas CAN-C and CAN-D are both located in a designated area of high archaeological potential. Further assessment of the nature, character and importance of the site will be sought prior to the determination of any planning application. Amenity and Recreation Search Area CAN-D is used as a golf course education and training facility by Cannington College. Proposals for reprovision/compensation will be required to accompany proposals for residential development on the site. Socio-Economic Issues The Stage 1 Consultation document does not distinguish between the facts that Search Area CAN-C is located within the existing
19) Cannington settlement boundary as defined in the Local Plan while Search Area CAN-D is not. With respect to Search Area CAN-C the siting of residential accommodation within the defined settlement boundary of Cannington and proposals for legacy use by the College would appear appropriate. Preliminary environmental assessment work undertaken for Search Areas CAN-A and CAN-B have not been extended to the central Cannington site. The completion of a Socio-Economic Study that identifies requirements for social and community infrastructure in Cannington associated with construction worker households is considered an importance area for further investigation. Land Contamination and Waste Further contaminated land assessments/surveys are to be undertaken by EDF Energy and reviewed and approved by Sedgemoor District Council. Air Quality Air quality assessments are to be undertaken by EDF Energy and the methods and results will need to be approved by Sedgemoor District Council.
Somerset County Council Concerned about the scale of the off-site associated developments at Cannington and the impact on the character of the small rural community. Request more details on the access arrangements for all sites and recommended that sustainable transport measures are provided. Concerned about the detrimental impact of the off-site associated developments on the character of the small rural community. Provide evidence as to why this scale of development is required. Provide clarity on how the off-site associated developments will resolve traffic impacts, other than those which are localised to Cannington. Identify the traffic benefits of the freight logistics. Clarify the proposals for Cannington park and ride in terms of traffic benefits and impact on the wider road network. Ensure that surveys are carried out at each of the proposed development sites to characterise their wildlife values. Cannington Brook is known to support Otters and other European Protected Species (EPS). Development on CAN-B has the potential to affect Putnell Moor CWS and species that have been recorded in the area, such as the Barn Owl. CAN-D is likely to support foraging bats and veteran trees.
Stogursey Parish Council Sought assurance that buses for workers coming from Williton will keep to the A39/C182 route and not take other smaller/unsuitable roads.
EF
20) Cannington Bypass
Consultee Comments
Bridgwater Town Council Bridgwater bypass would be preferable (from Dunball with a bridge over the River Parrett).
Burnham-on-Sea and Bridgwater bypass would be preferable (from Dunball with a bridge over the River Parrett). Highbridge Town Council
Cannington Parish Council Recognises that a bypass will benefit the village and help the flow of traffic. A route north of Bridgwater would be more beneficial to Cannington, commuters and construction traffic. The Council recommends a route from Dunball area across to a point on Hinkley Point Road between Cannington and Combwich area. Concerned that both routes are too close to residential properties in the village. Concerned that the westerly route will bring increased noise and air pollution into the village centre and will cut across the Brymore School drive causing danger. Suggest that the eastern bypass could pose as a flood hazard to the village. By building this road, it could act as a flood barrier by keeping the water in the village at times of flood. Concerned that the western bypass is too close to Cannington village. It will cut across Grade One agricultural land. Bridgwater bypass would be preferable (from Dunball with a bridge over the River Parrett).
Cannington Women’s Institute Concerned about the potential impact of the western bypass on Brymore School. Bridgwater bypass would be preferable (from Dunball with a bridge over the River Parrett). Put the park and ride, freight handling facility and accommodation facility at Dunball and then use the Bridgwater bypass.
English Heritage Request that the bypass is only considered if the transport strategy indicates an overwhelming need for one.
Environment Agency With the eastern proposal location in flood zone 3A and 3B, it is likely to pose the greatest engineering challenge for construction, subject to it passing the sequential and exception tests. Request a full FRA is undertaken which highlights the vulnerable nature of this site and how multiple watercourse crossings and surface water disposal issues will be dealt with. Investigate the potential legacy benefits of the eastern bypass proposal in the form of an enhanced tidal protection. As the eastern bypass proposal will be 2km longer than the western bypass, it will have a greater impact on local biodiversity.
20) Cannington Bypass
Undertake a FRA for the western bypass, providing details on surface water disposal and any local ditch/watercourse crossing design details. Suggest that the western inner bypass will have less impact on biodiversity as it would cut through the least amount of ditches and hedgerows. It would also be a good distance away from any protected habitat sites. Request that further ground investigation works are required around the western bypass option, especially to the northern end. Cannington Creamery has key licensed groundwater abstractions in this area which must be protected from any contamination. The eastern bypass option passes within 300 metres of a licensed groundwater abstraction at Rodway Farm. This abstraction is licensed for domestic usage and measures should be taken to ensure that this abstraction will not be affected by construction works or by the finished development.
Fiddington Parish Council Bridgwater bypass would be preferable (from Dunball with a bridge over the River Parrett).
Highways Agency In principle, the Agency is not opposed to the proposed bypass development proposals. Expect the proposals to be supported by a robust TA and to be incorporated into the TP as appropriate.
Landowner Bridgwater College Concerned that the eastern bypass proposal would split college farm land. Already suffering from lack of land for grazing and forage growing land which would be further limited by introduction of the bypass. A bridge or underpass would be needed to allow cattle and farm vehicles to reach land that would otherwise be cut off from the farm. The eastern bypass would restrict expansion of a current 9 hole golf course to a more standard 18 hole course. The eastern proposal would severely limit expansion options for the Equestrian Centre as their pony paddocks run out to the proposed bypass. The western bypass is the College’s preferred option; however there is concern over accessing its farm given the close proximity of the new roundabout farm entrance.
Landowner Individual The eastern bypass cuts through a corner of land on which there is an established badgers set. The road on the eastern bypass would require to be raised in order to avoid flood issues. Concerned that the eastern bypass would increase speed at which vehicles travel, due to the straighter road.
Natural England The eastern bypass requires a HRA.
Nether Stowey Parish Council Bridgwater bypass would be preferable (from Dunball with a bridge over the River Parrett).
Parish of Stockland Bristol Consider the proximity of the eastern route option to the Severn Estuary SPA. Concerned that the eastern bypass option will not alleviate against any of the problems that will arise from the construction traffic
EF
20) Cannington Bypass
along the A39 and Hinkley Road. Advise that the western bypass route will only turn Cannington into a ‘rat run’. The eastern route will not alleviate any of the problems that will arise with the new construction traffic along the A39 and Hinkley Road. Bridgwater bypass would be preferable (from Dunball with a bridge over the River Parrett). The Parish does not subscribe to the ill founded and ill thought out route suggested by the Cannington Action Group for the road across the Steart common adjacent to the 400kv line to the north of Stockland Bristol.
Quantock Hills AONB Outline the potential impacts on visual amenity and views from the Quantock Hills AONB. The baseline information must be updated to reflect the actual distance from the AONB.
RAC Foundation for Motoring Concerned that if the western option is chosen this would be to the detriment of non-nuclear traffic between West Somerset and Bridgwater/M5. Bridgwater bypass would be preferable (from Dunball with a bridge over the River Parrett).
Sedgemoor District Council and Observations on Proposals West Somerset Council The preliminary view of Sedgemoor District Council is that the western route would be most appropriate due to landscape, ecology and land use grounds. A new bypass at Cannington would comprise major development in its own right so proposals must be supported with rigorous justification. More detailed consultation is required with Cannington Parish Council, Cannington College, Sedgemoor District Council, Somerset County Council and the Environment Agency to discuss bypass options and highway usage and maintenance post construction. Discussions are also required around potential legacy benefits including: Flood risk management for Cannington High quality public transport proposals along the A39 Joint car parking and travel planning for EDF Energy and Cannington College. Further Observations on Technical Issues Geology, Soils and Land Use Both route options pass through land designated as Best Agricultural Land. In this respect the smaller land take of the Western Bypass option is acknowledged as an advantage.
20) Cannington Bypass Hydrogeology, Hydrology, Drainage and Flood Risk The completion of a Flood Risk Assessment is considered to be a priority study and understanding of what is possible to secure enhancements to existing flood defences on the Parrett and to the village as a whole is also required if the Western option were to be considered the preferred route. Transportation Potential environmental impacts of traffic in the centre of Cannington should also be assessed as part of a full options appraisal. Further information on the number, timing and type of anticipated traffic movements through Cannington should be presented so that the significance of an environmental impact in the centre of the village can be properly assessed. Discussions between EDF Energy and the College about residential requirements, car parking and travel planning may provide an additional area for collaboration. Terrestrial, Flora and Fauna The assessment of impacts on hedgerows is considered to be insufficiently detailed at the present time. Noise and Vibration and Air Quality Limited information particularly baseline data is available to allow a technical preference to be provided between the Eastern and Western Bypass route options in noise and air quality terms. The roads that should be assessed in further studies to be undertaken by EDF Energy will need to be agreed with Sedgemoor District Council. Landscape and Visual Additional photographic material and photomontages from key viewpoints will be important to understand the landscape and visual impacts of the bypass route option. The eastern route would significantly impact on the landscape character of the area. The western route option is shorter in length and impacts on less sensitive landscape areas, however it is important to note that the Western route would adversely impact the setting of Brymore School (a Grade 2 listed building).
Somerset County Council Request that the company funds the long-term maintenance of the bypass route. Clarify whether the same methodology was used to rationalise both the Cannington and Bridgwater bypass Request appropriate investigation for the chosen bypass route, to determine the extent of any land contamination. Require traffic modelling evidence that supports the need for a bypass route.
EF
20) Cannington Bypass
Request traffic-related environment assessments to support the western option. Full details of the Cannington Bypass proposal should be provided in order for Somerset County Council to provide meaningful comment including detailed design. No general survey has been conducted to identify whether ditches crossing the Eastern option are important botanically.
20) Cannington Bypass
Somerset Wildlife Trust Recommend installing traffic calming measures throughout the village to deter through-traffic, making the bypass a more ‘attractive’ alternative. Consider the western route to offer the least by way of ecological constraints. Similarly less disruption to ecological corridors is predicted for this route as it would keep traffic further away from protected sites.
Spaxton Parish Council Bridgwater bypass would be preferable (from Dunball with a bridge over the River Parrett).
Stogursey Parish Council Prefer the westerly option because of the bus links from the A39 west linking up with C182.
Wembdon Parish Council The Parish Council expresses no preference for the route of the Cannington bypass. This should be a matter for detailed discussion between the appropriate authorities and Cannington Parish Council. Bridgwater bypass would be preferable (from Dunball with a bridge over the River Parrett).
21) Combwich Wharf
Consultee Comments
Burnham-on-Sea and Recommend the construction of a permanent jetty at Combwich Wharf, to assist with proposals for a passenger ferry link. Highbridge Town Council
English Heritage Outline the lighting needed for early morning and late night deliveries. Suggest initial investigations are undertaken to establish what archaeological remains there may be. There is a strong likelihood of archaeological deposits within the area of the estuary identified for the jetty upgrade at Combwich Wharf. Recommend that initial investigations are undertaken to establish what archaeological remains there may be.
Environment Agency The entire site is within tidal and fluvial flood zone 3. The whole site also sits in atidal residual risk area. Clarify what the Wharf refurbishment will entail and how it will impact on the cross section of the river and tidal prism. Recommend installing interceptors to stop any contaminated surface water reaching the watercourse from the freight logistics yard. Ensure pollution prevention guidelines are followed when designing the working methods on this refurbishment, to reduce any pollution to the surrounding water environment. Methods to reduce suspended solid entering the water and other debris from the development should be implemented. Any machinery and fuel storage should not be stored near the water. Any use of concrete or similar products that can severely impact on the water environment should be managed so that the risk of pollution is reduced.
EF
21) Combwich Wharf
Request further information on how the freight logistics will be constructed and how it will impact on the flood defences along the Parrett. Outline the expected changes in patterns of erosion and accretion, as a result of the refurbishment. Clarify whether there are any implications for the flood embankments along the River Parrett. Outline the proposed actions that will be taken if damage exceeds defined limits. These developments require an appropriate FRA showing no adverse flood risk implications for ‘The Wharf’ and existing development in the locality as a result of those works. Recommend the timing of the development works to avoid disturbance to over wintering and nesting birds. An assessment to identify the bird species would be useful. Sought consultation from Somerset Wildlife Trust regarding the access point which will run alongside Combwich Brick Pit. Welcome the extended habitat survey. Subject to checking that there is no fluvial flood risk from the rhyme network that criss-crosses the site, there will be no flood risk objection in principle to the use of the land as a material/plant lay-down. Concerned about the following land constraints: access will be required to Tuckett’s Clyce. Existing arrangements will need to be safeguarded for Environment Agency/Internal Drainage Board maintenance purposes; no development will be allowed within 8.0m of the landward toe of the Parrett flood defence embankment – LD Bylaws. The Agency needs to retain appropriate access to the rear of the flood defence and also protect the earth bank defence from potential damage by machinery movements and materials stockpiling on the site; retention of the natural rhyme network may be required, with appropriate buffer strips to safeguard land drainage, Internal Drainage Board access for maintenance and environmental interests (flora and fauna). Subject to further discussion with the Agency, the Internal Drainage Board and English Nature; and an area of the site will be required for construction of a suitable surface water drainage system to accommodate tide lock storage and/or water quality treatment from the site.
Highways Agency Support the proposal for the delivery of freight by water, via the refurbishment of the Wharf. The Agency would expect Abnormal Indivisible Loads (AIL) to be delivered by water as opposed to the local and strategic road networks, as there are significant constraints in transporting such goods along the M5 corridor. Concerned that the access roads to the site may be affected by flooding (site located within flood zone 3a). This could see a potential diversion of traffic to the M5 for a short time until flooding subsides. Request the completion of a FRA. The Agency requires mitigation of the risk created by proposing alternative solutions to the
21) Combwich Wharf
diversion of transportation in flooding events.
Landowner - Crown Estate Suggest that the company consult with Bridgwater Bay Wildfowlers Club and its interests are considered. Recommend that careful consideration is given in relation to the proposed seawall and any contribution it may have to coastal squeeze. Also consider the impact that the hard defences might have on the shoreline affecting landowners of contiguous property.
Landowner Bridgwater College Concerned about the impact on the operation of the farm if the freight development is located opposite it. Concerned about the loss of the land which the college leases from Clifford Estates.
Landowner Individual As the proposals cover approximately 50% of Mr Baker’s 120 acres of land, drainage of the existing land is therefore of paramount importance. It would be ‘enormous, if not impossible’ to return the land to farming quality once the development of Hinkley Point C is complete.
Natural England The proposed developments at Combwich Wharf will require a HRA.
Otterhampton Parish Council Concerned about the area identified for storage. It is an area used by walkers, both from the parish and Parrett Trail. Seek assurance to the protection of this land, both physically and visually.
Request improvements are made to the layout of the existing junctions to Combwich and Otterhampton, to cope with already excessive speeds on the C182, Hinkley Road. Consult with the Parish Council on working hours during the refurbishment and ongoing usage.
Parish of Stockland Bristol Understand the reasoning for a small freight logistics facility near Combwich Wharf but not one nearly twice the size of Combwich.
RAC Fully recognise the benefits of refurbishing Combwich Wharf and the consequent valuable transfer of large volumes of mineral and freight traffic from road.
RSPB Welcome relocation of the proposed marine berthing facility to Cannington where existing facilties already exist. Any potential impact on the Parrett Estuary will need to be fully assessed.
Sedgemoor District Council and The principle of the use of Combwich Wharf is supported given its potential to minimise the amount of freight transported by West Somerset Council road. Combwich Reach forms part of the Severn Estuary Special Area for Conservation (SAC) and Special Protection Area (SPA) and is designated as a SSSI, the existing wharf is excluded from this designation however the potential affects of construction and operation will need to be considered through an appropriate assessment. The site is considered to be preferable over the North West Cannington (CAN-B option).
EF
21) Combwich Wharf
It is the initial view of the Council that the benefits of water borne freight transportation outweigh the loss of agricultural land outside the settlement boundary of Combwich. In developing the proposals for Combwich further EDF Energy is advised to address the following matters: Further consultation should be carried out to understand opportunities for restoration or legacy uses of the proposed development. Full restoration or legacy proposals should be presented where the temporary freight consolidation facility will be located on agricultural land. Combwich Pond located adjacent to the search area is designated as a County Wildlife Site. Further consultation should be undertaken with the Port of Bridgwater in relation to the design and operation requirements of the wharf. If consolidation storage facilities are to be located within the search area they should be located in an area where visual impacts on the openness and character of the countryside can be minimised. Further Observations on Technical Issues for Combwich Wharf Marine Water and Sediment Quality The data gap in marine water and sediment quality data should be filled. Hydrodynamics and Coastal Geomorphology More information is required on the assessment to date and the proposed studies which will be undertaken in the future. A programme of hydraulic sediment transport and morphological modelling should be provided in the project programme. Marine and Coastal Flora and Fauna The baseline is considered generally adequate but there are certain significant omissions including the national designations (example SSSI) are not noted. It is uncertain as to whether there will be a separate Environmental Statement for this element of the works and whether the Combwich Wharf will be assessed as part of the main development site underpinning the Development Consent Order application. It is recommended that further engagement with Natural England and RSPB be made in terms of defining future studies of over- wintering birds at present this is unclear.
Transportation (Marine) No information is provided on how existing river users will be affected by the proposed development and no information is
21) Combwich Wharf
provided on the design vessel in this section. The proposed desk based assessment on existing uses should consider future needs of the river for navigation. Land Contamination and Waste Further contaminated land assessment/surveys are to be undertaken by EDF and reviewed and approved by Sedgemoor District Council. Air Quality Depending on predicted usage and access routes air quality assessments may or may not be required.
Somerset Chamber of Support the improvements to the Wharf but would ask the company to consider how it could be made available for commercial Commerce and Industry use after construction of Hinkley Point C is complete.
Somerset County Council Revisit vehicular access onto the C182 to ensure it is constructed to current design standards. Concerned about the impacts on the Severn Estuary SPA and/or SAC. SCC ecological specialists will advise on the scope and nature of future surveys at this site and at other search areas.
Somerset Wildlife Trust Insufficient data is available to determine the level of impact on the Severn Estuary CPA, SAC and Ramsar site. The possible terrestrial ecological impacts need to be investigated along with effective mitigation proposals.
Spaxton Parish Council Pleased to see proposals to use the Wharf at Combwich.
The Crown Estate Suggest that the company consult with Bridgwater Bay Wildfowlers Club and interests are considered.
22) Williton
Consultee Comments
English Heritage Question the need for development in Williton. Both WIL-A & WIL-B have high archaeological potential. Any development at WIL-A should avoid the Scheduled Monument. The proposed search area WIL-B is a key prehistoric routeway.
Environment Agency Request that the site at WIL-A should be discounted, as it would automatically fail the PPS25 sequential test as the vulnerability of proposed uses are not compatible with the flood zone 3b. WIL-B is predominantly located in flood zone 1. Avoid locating the site to the far north eastern boundary (potential small
EF
22) Williton
incursion into flood zone 3b of the Doniford Stream). Ensure that drainage and pollution prevention measures are looked into for the off-site associated development at Williton. Interceptors may be required to deal with the drainage for the park and ride facility. SUDs development techniques should be incorporated into the design of this area to try and reduce the effect of the development on the surrounding environment. Any associated welfare facilities with the park and ride should have adequate treatment facilities developed. Should the company wish to pursue WIL-A, the EA suggests that it may be possible to lower the sites flood risk category by delivering flood alleviation measures. This would provide a worthy flood risk reduction legacy for the town, similar to Cannington.
Landowner Individual Suggest an option of land east of Seaward Way at Minehead (30 acres) and would be prepared to consider this to provide parking and accommodation. In the event EDF Energy wishes to give further consideration to either or both of the sites at Williton, the landowner actively welcomes any opportunity for early engagement, positive discussion and negotiation in respect of potential leasehold agreements for relevant parcels of land, on the basis of heads of term which would secure legacy development such as essential infrastructure.
Landowner(s) Killick The proposed land use seems excessive. Happy to see the proposals, as long as the site is recognised in development value.
Minehead and District Chamber Believe that Minehead is a more suitable location for a new hostel. of Trade and Commerce
Neither Stowey Parish Council Although the park and ride facility might reduce the number of cars, it will also increase the number of buses. There are a number of pinch points on the A39 between Williton and Cannington where it is difficult for two large vehicles to pass. This will potentially hold up traffic.
Quantock Hills AONB Provide reference to the potential impacts on visual amenity and views from the AONB, particularly in light of the fact that a number of open access health land hills directly overlook the town.
RAC Foundation for Motoring Suggest that both search sites at Williton will generate extra traffic on the A39. The company should evaluate proposals by local business people and landowners for new developments including diverting the A39 within the village to the existing junction of the B3191 with the A39 Long Street. Possible local improvements of the A39 between Williton and Cannington include: creating passing places (sometimes by converting lay-bys); and creating one-way overtaking lanes.
22) Williton
Sampford Brett Parish Council Justify the need to accommodate 200 workers in the area. Opposed to the strategy to minimise distance travelled as Williton is 15 miles/40 minutes from Hinkley Point C. Concerned about the visual intrusion of the campus from Quantock Hills AONB. Concerned that WIL-B is located entirely within the parish of Sampford Brett. The village is designated in the Local Development Plan as not allowing any further development due to lack of infrastructure. State that the park and ride facility in Williton is inappropriate. Preferred option would be for a bus to travel and pick up any workers located in West Somerset or, failing that, to use the current redundant parking area formerly used by Griggs Lorries off the A3190 opposite Smithyard Cottage, between Tropiquaria and Five Bells. Suggest that the run-off of water associated with the park and ride facility will increase the risk of flooding in Williton. Suggest that the A39 is unsuitable for construction traffic – any accident will bring serious disruption to the area. Concerned that the land designated is not in the current development plan.
Sedgemoor District Council and The scale of the proposed Park-and-Ride facility at Williton is questioned on the basis that temporary development of greenfield West Somerset Council sites is to be avoided if possible. It is the initial view of West Somerset Council that the provision of an appropriate amount of residential accommodation and a Park-and-Ride at the Western Search Area (WIL-A) will be preferred for the following reasons: A Park-and-Ride to the west would reduce the number of vehicle movements associated with the construction work through the centre of the village. Search Area WIL-A benefits from closer proximity and accessibility to the village centre than the WIL-B location meaning that it is an appropriate location for recreation facilities of ongoing legacy benefits for the village. The establishment of a vehicular access route through the site could assist in reducing congestion at other junctions in the village and enable housing development at the site area in the future.
The opportunity for West Somerset to input to the selection of a site and the layout of access and buildings is welcomed. Somerset Council would also be willing to discuss search areas in other parts of the District notably Minehead and Watchet. In order for West Somerset Council to confirm support for one or both sites the following matters will require further consideration: Clarity is required on the level of flood risk for each search area and flood implications of further development on the village centre which falls within the floodplain of the Doniford Stream and its tributaries.
EF
22) Williton
The suitability of Search Area WIL-B with its access on to the A358 is questioned given the majority of the traffic (both from a residential campus and from workers living further from the site from Williton) is expected to use the A39 to travel to and from Hinkley Point. Further consultation with Williton Parish Council and West Somerset Council should be carried out to understand opportunities for legacy use of residential development. West Somerset Council would require that any leisure related facilities provided be designed as a long-term legacy for the town. Further information is required on the demographic make-up of households to be located in Williton so that health, education and other community infrastructure requirements can be assessed. Further consideration must be given to potential legacy uses of the Park-and-Ride site. On completion of the underlying work to establish the magnitude of development that may be required in Williton the Authorities urge EDF Energy to consider a further round of consultation in advance of the Stage 2 Consultation. The Councils fully support exploration of the potential to bring workers from Taunton to Williton by railway and then by bus to the Hinkley Point site. The Councils would welcome the opportunity to discuss the detailed element of this work to fully understand the implications of the proposals including the implications on the A39.
Somerset County Council Clarify whether the 200-bed campus will also have parking in addition to the park and ride facility. Clarify why 12% of workers are estimated to be coming from the west via Williton, given there is no strategic road access from the west. Provide evidence on how routing has been modelled and hence how the need for a park and ride facility in these locations have been determined. Concerned about traffic impacts west of Williton associated with the park and ride facility. Information should be provided on the bus route proposed from the Williton park and ride facility to the Hinkley Point C site. Overall, there is no evidence that the proposed strategy locations are optimal. Undertake a transport related assessment at Williton to identify whether proposals for these sites are feasible in traffic terms. Recommend surveys are undertaken to gauge impacts on the protected species that occur within the Williton search areas. Question the reported record of red squirrels within 10km of Williton.
Western Power Distribution Ensure the company consult with Western Power Distribution in more detail, once developments have been decided in outline. WPD has 33,000 Volt overhead power lines running over proposed sites for campuses at Williton.
Williton Parish Council Opposed to the off-site associated developments at Williton.
22) Williton
Request that greenfield sites are not considered. Suggest the use of existing sites and existing facilities. Concerned about the development sites at Williton, including the park and ride facility. Concerned that decisions will be made by an outside body unfamiliar with the local needs and environment. Suggest that the fire station is considered for parking.
23) Bridgwater
Consultee Comments
Bridgwater Education Trust Concerned about the amount of new build traffic. The only access to Haygrove School is located directly onto the A39. Proposals will impact on Somerset County Highway’s current proposal of a feeder land for buses and cars to turn into the School across the A30. This will have a cost impact on the project.
Bridgwater Town Council Request that accommodation is not provided in a single block and should seek to provide legacy use in several locations, with sufficient leisure and social facilities. Affordable housing is a vital legacy and should be built to a suitable standard. Sites should be chosen with due regard to existing residential development and must complement and enhance the built environment.
British Waterways Request further discussions with the company should the site at BRI-D be progressed albeit that they are unlikely to have any principal objection. British Waterways owns and maintains the Bridgwater and Taunton Canal which is adjacent to this site.
English Heritage As much development as possible should be located in Bridgwater.
Environment Agency Sewage infrastructure must be in place to deal with the maximum potential volume of sewerage created from the campus buildings before it is used.
Advise that all of the proposed sites in Bridgwater are located within flood zone 3 and are therefore at risk from both tidal and fluvial flooding. BRI-A encompasses the Cellophane Pits County Wildlife Site. Strongly support incorporating this area into the design as a wildlife refuge. Suggest that under PPS23 a full ground water and contaminated land assessment is required for BRI-A. Carry out a full contaminated land investigation before development begins at BRI-B. Carry out a full contaminated land investigation at BRI-C, due to the site being situated on a closed historic landfill.
EF
23) Bridgwater
Carry out a full contaminated land investigation at BRI-D, due to the sites proximity to a closed historic landfill.
Haygrove School Concerned about the amounts of new build traffic because the only access to the school (Haygrove School) is located directly onto the A39. Proposals will impact on Somerset County Highways current proposal of a feeder land for buses and cars to turn into the School across the A30.
Highways Agency On-site accommodation would reduce the need to travel. The Agency would encourage increased provision of worker accommodation on site. Support the principle of accommodating employees within Bridgwater providing that sustainable options for transport are provided between Bridgwater and site. Requires further clarification as to how the campus will be provided at BRI-A, in line with the wider employment and housing proposals which form part of the current application. Transport Assessment to include assessment of the employee accommodation proposals and appropriate mitigation measures.
Landowner Bridgwater College Support proposals to locate accommodation on the current rugby club land on Bath Road subject to: re-location of the rugby club; there being a legacy value for the college of approximately 120 ensuite accommodation; development of a conference facility to complement the theatre plans across the road; and the college retaining at least one of the high quality playing fields.
Landowner Bridgwater College Supports the dispersal of workforce in Bridgwater. Requests early access to recreational and sporting facilities rather than waiting for legacy use. Desire for the refurbishment of the rugby club house, into conference facility which could complement the auditorium plans for the theatre on the other side of the road. Facilities for 100 participants, with additional seminar space. Also possibility for catering facilities which could be managed by the College as part of a college training facility. College would like development on the rugby club pitch to complement the state of the art theatre they are currently developing on the other side of the road, this is going to offer performance space for both the College and the community and could also offer an additional recreational/cultural facility for EDF Energy workforce.
Landowner Individual In favour of accommodation for up to 500 workers at one of several campuses in Bridgwater, with potential long term legacy uses including student accommodation and a hotel. The cattle market site, the College site and Huntsworth site should not be supported as none of the sites are capable of coming forward as part of a comprehensively planned development and with the benefit of comprehensive strategies for accommodating the traffic movements, delivering transport, landscape and biodiversity enhancements, and providing related facilities and services.
23) Bridgwater
Suggest that the site at BRI-A affords the highest priority by EDF Energy in identifying opportunities for accommodation in Bridgwater. Suggest that the site at BRI-C is the preferred site for both the short and long term benefits. The existing rugby club provides not only the space for the accommodation building but has the added benefit of an existing and sizable club house for conversion as catering recreation facility for EDF Energy staff/contractors. This location is also close to bus terminus area at the college as well as an easy walk to the town centre.
Nether Stower Parish Council Concerned about the amounts of new build traffic because the only access to the school (Haygrove School) is located directly onto the A39. Proposals will impact on Somerset County Highways current proposal of a feeder land for buses and cars to turn into the School across the A30. Aware that Somerset NHS is planning to build a new Community Hospital on the east side of Bridgwater. Concerned that the development of the new Morrison’s Supermarket Distribution Centre north of Bridgwater will lead to increased traffic, particularly HGVs on the A38 north of Bridgwater, leading to further congestion.
Sedgemoor District Council and Bridgwater represents the greatest opportunity in Sedgemoor for accommodating associated development in the most West Somerset Council sustainable way. Should it be found that there is a higher proportion of migrant workers than currently expected the Council’s preference is for the majority of additional worker accommodation to be provided in Bridgwater. The potential to use worker accommodation as a hotel legacy use would be of benefit to Bridgwater. A strategic transport investment package for Bridgwater will be sought as part of the planning obligations. The provision of Park-and-Ride services in Bridgwater align with the Bridgwater Vision Core Strategy Preferred Option. Further information on the Park-and-Ride at Bridgwater as a legacy benefit should be provided. Proposals to provide residential development in Bridgwater benefit from strong policy support. Proposals set out in the Bridgwater Vision which should be considered in relation to potential sites are as follows: BRI-A transport and movement networks within the site and linked to surrounding areas of Bridgwater are considered of great importance. Search Area BRI-B also bounds the A39 (Bath Road) an important arterial route that requires visual improvement. Search Area BRI-C is located within the station gateway project area where new development adjacent to the railway corridor will incorporate flexible office space (incubator, workshop and live/work units) alongside high density residential development.
EF
23) Bridgwater
Search Area BRI-D falls outside the Bridgwater challenge study area. Of the four search areas set out in the Consultation document it is the initial view of Sedgemoor District Council that Search Areas BRI-A, BRI-B and BRI-C are to be supported as potential locations for construction worker accommodation. An initial preference is expressed for campus development at BRI-B the Castle Market Regeneration Site for the following reasons: For campus development to proceed at BRI-A it would be necessary to demonstrate that plans can be integrated with the design of a mixed-use sustainable community at North East Bridgwater. Campus development at Search Area BRI-B would sit well with the Bridgwater Vision proposals for the Wyld Road area. The inclusion of Search Area BRI-C is supported though any building or structures should be adaptable to allow for future legacy benefits potentially in connection with the adjacent College. Sedgemoor District Council is fundamentally opposed to the inclusion of Search Area BRI-D which is considered to be poorly located with respect to existing facilities and current and proposed public transport links. Matters that will further influence accommodation proposals and the design of the scheme are as follows: All four Search Areas are located in Flood Zone 3A. The northern extent of Search Area BRI-D contains a Site of County Importance for Archaeology. Further information is required on the demographic make-up of households to be located in Bridgwater so that health, education and other community infrastructure requirements can be assessed. The Council is keen to discuss with EDF Energy how the provision of affordable housing might be secured as a legacy benefit of campus development and how the layout of development could be influenced to secure appropriate dwelling mix. There are a number of further sites in the Bridgwater area that Sedgemoor District Council consider would be suitable for the development of accommodation for construction workers. EDF Energy should fully consider these sites, the suggested sites are: Redevelopment of former Gerber factory at Wembdon Road, Bridgwater Chiltern Road Caravan Site, Chiltern Trinity Redevelopment of Haygrove School Land east of Taunton Road Bowerings Mill, The Docks Land at Monmouth Street Former Bigwood and Staples, Church Road
23) Bridgwater
Observations on technical issues Land Contamination and Waste Further contaminated land assessment/surveys should be undertaken by EDF Energy and reviewed and approved by Sedgemoor District Council. The following sites have potential risks associated with them: BRI-A North East Bridgwater BRI-B Cattle Market BRI-C Bridgwater College, Bridgwater Rugby Club, Bridgwater Football Club Air Quality Further air quality assessments are to be undertaken by EDF Energy and the methods and results will need to be approved by Sedgemoor District Council.
Somerset County Council Agree to the two identified access points at BRI-A. Improvements to Crandon Bridge junction A39 and Cross Rifles roundabout A38/A39 are yet to be agreed as there are significant differences of opinion on design issues, between the developer and SCC. Difficult to gain access to the cattle market at BRI-B. Development has been proposed on this land together with land to the north. Advise that the existing access at BRI-C is re-modelled. Ensure that other proposed off-site associated developments adjacent to a junction are appropriately assessed. Advise that problems have arisen due to the presence of Great Crested Newts and other legally protected species at BRI-A. Foraging bats may be present at BRI-B and BRI-C. BRI-D adjoins the Bridgwater-Taunton Canal CWS, which is known to support Daubenton bats, otters and water voles. Provide further research on the ecological impacts of using the proposed search areas.
Western Power Distribution WPD have 33,000 Volt (33kV) overhead power lines running over proposed sites for campuses in Bridgwater.
24) Junction 23, M5
Consultee Comments
Bridgwater Town Council Ensure that sites chosen are in accordance with planning policy requirements, e.g. flood zones should be taken into account.
EF
24) Junction 23, M5
Request that park and ride facilities are not seen as a legacy to the town. This is not a solution in provincial market towns and would be subverting local knowledge, wishes and opinion.
Burnham-on-Sea and As the nearest park and ride is the one proposed at Junction 23, clarify whether there is a possibility of further pick ups in Highbridge Town Council Burnham or Highbridge.
English Heritage Archaeological potential is similar on both sites.
Environment Agency Fully investigate drainage and pollution measures. Appropriately sized interceptors will be required to deal with the drainage for a 750 park and ride. Suitable Urban Drainage development techniques should be looked into for design of this area to try and reduce the effect of the development on the surrounding environment. Request an ecological survey is undertaken to check for protected species at J23-A. The area is adjacent to a scheduled ancient monument and therefore English Heritage should be consulted further on the matter. No objection in principle to either site being used for less vulnerable parking and/or freight uses, subject to an appropriate FRA. Advise that both sites are subject to flood risk from breach and/or overtopping of the existing Parrett tidal defences. Mitigation would be required to manage residual flood risk. Both sites J23-A and J23-B fall wholly within the flood zone 3a.
24) Junction 23, M5
Highways Agency Concerned that freight logistic facilties could worsen the impact on the strategic road network. J23-A lies in flood zone 3a. A FRA is to be undertaken which should seek to identify any potential impact on the Strategic Road Network should flooding occur, in addition to a further assessment of any direct effects on watercourses and drains. The Agency requires consultation on the conclusions of both assessments. Comments are based on the temporary nature of the use. Any long-term use would be expected to be subject to a new planning application. As the Agency provided comments to the initial options presented in July 2009, the Agency would like to reserve its position to make further comment in due course when more information is made available on the revised options at Junction 23. Provide more information from transport modelling in order to ascertain the impact of each of the options. Concerned about these proposals generating a level of trips which would detrimentally impact upon the safe and efficient operation of this junction and the flow of traffic to the M5. Due to the lack of information, the Agency is unable to make detailed comments at this stage. An internal study has highlighted that J23 could benefit from signalisation in the future. The Agency would like to be involved in potential legacy proposals for the site at J23B.
Landowner Individual Will not make a preference between the site options until conclusions are drawn and further studies completed. Throughout the construction phase both Dunball Roundabout and J23 must be seen to continue to provide adequate capacity for all predicted movements including those of committed developments such as at North Bridgwater.
Natural England J23-A is located approximately 750m from the Severn Estuary SPA and is therefore subject to a HRA. J23-B is located approximately 1,800m from the Severn Estuary SPA and is therefore subject to a HRA.
RAC Foundation for Motoring Although the Junction 23 exit avoids Bridgwater, there is a case for a traffic scheme between the A38 Bristol Road and the BNDR.
Sedgemoor District Council and The rationale for providing a Park-and-Ride site and consolidation facility at J-23 is supported. West Somerset Council It is the initial view of Sedgemoor District Council that Search Area J-23A is the preferred option for both the Park-and-Ride and freight consolidation facilities for a number of reasons. J-23A is well located in terms of access to and from the M5 motorway and is well screened by established hedgerow and bunding. In contrast access to the J-23B Search Area is relatively convoluted as traffic can only access the site directly from the north bound lanes.
Important matters to be taken into account in developing this scheme for the J-23A Search Area include:
EF
24) Junction 23, M5
The extent to which the proposals support and further the objectives for the A38 public transport corridor and Green Gateway Business Park. The ongoing viability of the Park-and-Ride site beyond the Hinkley Point C construction period and the implications this could have for legacy and restoration proposals. How flood risk will be managed at the site taking account of the Parrett barrier proposals associated embankment improvements and access requirements. The potential for enhancing the setting of the Motte and Baileys Scheduled Monument located to the northeast of Search Area J-23A. The provision of fully serviced employment sites may represent an appropriate legacy use depending on the acceptability of the employment site allocations in the Core Strategy. Suitable premises for the relocation of businesses with an existing interest in the J-23A search area. The Dunball roundabout area at J23 is considered a gateway into Bridgwater and it is important that any facilities in this area are well shielded by other built form development. Large areas occupied by parked vehicles would need to be well screened. Observations on technical issues Land Contamination and Waste Further contaminated land assessment/surveys are to be undertaken by EDF Energy and reviewed and approved by Sedgemoor District Council. Air Quality Further air quality assessments are to be undertaken by EDF Energy and the methods and results will need to be approved by Sedgemoor District Council.
Somerset County Council Consider the proposed access strategies for J23-A and J23-B to be appropriate. Advise that both site proposals have the potential to support Great Crested Newts. It is considered possible that the fields within the areas might attract birds from the Severn Estuary SPA. Concerned that the proposed areas have the potential for land contamination based on historic uses.
25) Junction 24, M5
Consultee Comments
Bridgwater Town Council Ensure that sites chosen are in accordance with planning policy requirements, e.g. flood zones should be taken into account. Request that park and ride facilities are not seen as a legacy to the town. This is not a solution in provincial market towns and would be subverting local knowledge, wishes and opinion.
English Heritage The EH has general concerns but no site preference.
Environment Agency Fully investigate drainage and pollution measures. Appropriately sized interceptors will be required to deal with the drainage for a 350-car park and ride facility. Recommend that pollution prevention methods are installed in the design of the freight logistics to reduce the chance of contaminated surface water run off reaching the watercourses. Concerned that a small section of Stockmoor Rhyne County Wildlife Site is located within the western corner of the potential development area of J24-A. Stockmoor Rhyne is an interconnecting reen network with legally protected species, nationally rare and nationally notable invertebrates and also ponds with legally protected species and stretches of adjacent hedgerows. Water voles have been recorded in the vicinity of the drain adjacent to the site. No flood risk objection in principal to the proposed sites at J24-A, J24-B & J24-C, subject to appropriate FRA’s. The site at J24-A falls within flood zone 1. Surface water disposal will be a challenge within this area. Question whether this site could be effectively drained into the adjoining Stockmoor village housing scheme. If not, connection difficulties could be experienced for surface water due to lack of discharge points. The sites at J24-B and J24-C fall within flood zone 1. The only difficulties envisaged relate to how any new surface water drainage system will be connected to an adequate discharge point, as there is nothing obvious nearby with spare capacity. A full infiltration and/or greenfield runoff limitation scheme is envisaged if the sites cannot be connected to an adequate discharge point.
Highways Agency The Agency welcomes the staggered construction approach for J23 and J24. Concerned about locations of J24B and J24C as they could generate a greater impact on the junction. Upon receipt of the FRA at Stage 2, the Agency would like to make further flood risk comments. The Agency will provide further comments upon receipt of the FRA at Stage 2.
EF
25) Junction 24, M5
Landowner Individual Currently promoting land for mixed use within the emerging LDF. Willing to cooperate with EDF Energy in satisfying their needs for a park and ride and freight logistic facilities. Suggest that they could also accommodate a number of other declared site needs including a residential campus, a high quality hotel, serviced offices and leisure and retail facilities to serve the campus and adjacent neighbourhood. Own all of J24-B. They are currently working up a planning application for the land, although when they applied approximately 4.5 years ago, this was not supported by the Local Planning Authority. Willing to meet with EDF Energy to explore opportunities. Own J24-C. They are currently working up a planning application for the land, although when they applied approximately 4.5 years ago, this was not supported by the Local Planning Authority. Willing to meet with EDF Energy to explore opportunities.
Natural England Reference should be made to the potential visual impacts from the Quantock Hills AONB, particularly cumulative impacts given the recent and visually prominent developments at Junction 24. Update the baseline information to reflect the actual distance from the AONB.
Quantock Hills AONB Service Baseline information on landscape and visual assessment to be updated. Reference to be made to the potential visual impacts from the Quantock Hills, particularly cumulative impacts.
RAC Foundation for Motoring Concerned that the A38 between Junction 24 of the M5 and central Bridgwater is already prone to congestion. Traffic backs up from central Bridgwater to the Showground Roundabout at peak times. Suggest that the results of baseline traffic flow studies are compared with observation and experience of road conditions.
Sedgemoor District Council and All three search areas identified by EDF Energy fall outside the defined settlement boundary for Bridgwater set out in the Local West Somerset Council Plan, however the scope for development in search areas J24-A and J24-C is established in the Core Strategy Preferred Option and Bridgwater Vision. Opportunities should be taken to enhance wildlife habitats and increase public uses of Bridgwater and Taunton Canal that passes to the east of search area J-24C. The rationale for providing a Park-and-Ride site and consolidation facility at J24 would appear appropriate on the basis that vehicle movements throughout the rest of the highways network in the centre of Bridgwater and to the western parts of Sedgemoor would be reduced. It is the initial view of Sedgemoor District Council that Search Area 23-A at North Bridgwater is the preferred location for the Bridgwater Freight Consolidation Facility but that search area J24-A is an appropriate location for a self Bridgwater Park-and-Ride site. The reasons for putting forward Search Area J24-A as the preferred Park-and-Ride location are set out below. It presents the greatest opportunity for a legacy public transport use on the basis that it is located on the A38 public transport
25) Junction 24, M5
corridor and directly adjacent to employment uses and the major residential development of Stockmoor. Land at J24-A is currently being promoted for employment development. This will have an impact on the site’s availability in the short to medium term although could potentially provide longer term legacy benefits in terms of a service site. A Park-and-Ride site located to the east of the M5 at Junction 24-B or Junction 24-C would be likely to increase the number of vehicular movements across Junction 24. The J24-B and J24-C search areas are visually prominent from the motorway and the freight consolidation and Park-and-Ride proposals are not considered appropriate in this context. Of the three search areas presented for consultation policy support for development at J24-B is weakest as it does not fall within the settlement boundaries found in the Local Plan or Core Strategy Preferred Option. The only legacy use that could be considered here would be its future restoration. Search Area J24-C is identified in the Core Strategy Preferred Option Report for Employment Development. It is important to note however that the site is facing significant apportion through the consultation process. The Stage 1 Consultation document refers to an alternative Park-and-Ride site further to the north on the A38 (adjacent to Dawes Farm) which is allocated in the adopted Local Plan. The site has been discounted by EDF Energy on the grounds of potential adverse impacts on residential amenity on the basis of off peak operation. It is requested that a full and comprehensive assessment is undertaken before discounting the site completely. Important factors in determining the acceptability of a scheme at search area J-24A in all the allocated sites in the location plan are: The extent to which proposals support and further the objectives for the A38 public transport corridor and enhanced distribution centre proposals set out in the Core Strategy Preferred Options Bridgwater Vision and Future Transport Strategy. The ongoing viability of the Park-and-Ride site beyond the Hinkley Point C construction period and the implications this could have for legacy and restoration proposals. Full restoration or legacy proposals should be presented where temporary Park-and-Ride and freight consolidation sites are to be located on agricultural land. The provision of fully serviced employment sites may represent an appropriate legacy use depending on the acceptability of employment site allocations in the Core Strategy.
Obersvations on technical issues Land Contamination and Waste
EF
25) Junction 24, M5
Further contaminated land assessments/surveys are to be undertaken by EDF Energy and reviewed and approved by Sedgemoor District Council. Air quality Further air quality assessments are to be undertaken by EDF Energy and the methods and results will need to be approved by Sedgemoor District Council.
Somerset County Council Support the development at J24-A as it is likely to trigger outstanding signalisation works required on the A38 roundabout. Advise that the site at J24-B was previously proposed for use with the same access location considered appropriate by SCC. Advise that the site at J24-C was previously proposed for class B1 and B8 use and has achievable access. Clarify whether early morning disruption on nearby residences has been considered for all park and ride facility proposals. Great Crested Newts are present in ponds close to J24-A. Protected species surveys and invertebrate surveys may be required. The site at J24-C has a roost record for Whiskered Bat from a veteran tree. Concerned that the former Huntworth Depot has potential for land contamination because of fuel storage or other automotive activity. Junction 24 provides the only site in Somerset for the rare Roesel’s bush-cricket. The whole area is likely to support foraging bats. May require the company to undertake protected species surveys and targeted invertebrate surveys.
Appendix A.7
TABLE OF COMMENTS ON BROADER COMMUNITY ISSUES
EF Appendix A.7: Table of Comments on Broader Community Issues
26) Broader Community Issues
Consultee Comments
Avon and Somerset The rise in local population caused by the incoming workforce during construction and operation could increase the demand on Constabulary local policing services. Protest activity by environmentalists and anti-nuclear protest groups could create high demand for policing services outside of core business hours.
Minehead and District Development could bolster the tourism accommodation providers’ income in quieter times but does not wish development to result Chamber of Trade and in a significant number of tourism bed spaces. Commerce
Sedgemoor District Council It should be ensured that the Sustainability Statement addresses all elements of the development proposals including preliminary and West Somerset Council works, off-site associated development, Hinkley Point C and southern construction areas. The associated development proposals are expected to meet the most stringent energy efficiency environmental standards. The range of issues discussed within the proposed Sustainability Statement should be tied to specific key performance indicators which will allow a mechanism for measuring them. Precipitate CO2 emissions will increase substantially once the construction of Hinkley Point C commences. Mitigation measures will be required. It is recommended that EDF Energy demonstrate the sustainability objectives for Hinkley Point C proposals in the context of national initiatives for the development of a national supply chain, economic renewal, educational initiatives, environmental stewardship, carbon reduction and security of supply.
Somerset County Council Lacking analysis describing existing socio-economic conditions and how socio-economic impacts correlate with planning policy. Concerned about socio-economic methodology as best means to assess the impacts of a project of this scale.
South West Regional Will assess ability to deliver regional economic priorities when additional information available. Development Agency
26) Broader Community Issues
West Somerset Council Concerned that no evaluation made on potential impact on tourism. Necessary to present to the Council an informed strategy to manage and mitigate impacts before confirming accommodation strategy.
Little information on how EDF Energy’s proposals integrate with wider regeneration and economic objectives.
27) Jobs and Training
Consultee Comments
Bridgwater College Welcome proposals to recruit local people for employment. Training opportunities can be accessed via the college including via the Energy Skills Centre (already under construction) which EDF Energy are likely to want to contribute financially to and to use for training options.
Bridgwater Education Trust The Trust would value the opportunity to engage with EDF Energy on work placements at Hinkley for their young people and would value EDF Energy's participation in Enterprise week.
The Trust wishes to develop close links with EDF Energy to develop relevant training to enable their young people to secure jobs at Hinkley Point. Positive impact on job creation for the community and our young people. Keen to develop a relationship with EDF Energy as a partner in assisting the Trust to achieve its aims of developing training opportunities and to build on EDF Energy’s objective to leave a positive legacy for the area. Possibilities for training opportunities and apprenticeships. Encourage work placements at Hinkley for Young People, talks linked to the curriculum and mentoring – would value EDF Energy’s participation in Enterprise Week and involvement with Somerset Enterprise Learning Partnership. Development of a “real project” linked to training on site with staff – possibly with an annual award for outstanding pupil. Training to develop knowledge of low carbon alternative energy sources.
Bridgwater Town Council A local labour agreement is essential to ensure 50% local provision is honoured. It is equally important to ensure training opportunities are maximised through the employment and skills charter.
Burnham-on-Sea and There appears to be no real employment benefit for Burnham and Highbridge, particularly since most of the transport options are Highbridge Town Council located some distance away. More information is required about the training and recruitment policies.
EF
27) Jobs and Training
Devon County Council The community benefits package should include links to skills development/apprenticeship programmes in the local area.
Minehead and District Welcomes the opportunity for better all year wages but concerned that any increase will be negated by cost of living increases or Chamber of Trade and staff will be forced to commute from other parts of West Somerset. Commerce Local traders and business may miss out on potential jobs due to lack of knowledge and experience.
Nether Stowey Parish Council Positive impact on job creation for the community and our young people. Training opportunities and apprenticeships.
Sedgemoor District Council It is critical that the labour force requirements are better understood in terms of the number of workers, the skills required and where the labour force is likely to be sourced within the UK.
Sedgemoor District Council There is limited reference baseline material. This is an omission as the context for the strategy must be driven by an awareness of and West Somerset Council local training and development challenges and opportunities. The reference made to the Flamanville experience in relation to targeting the under-privileged requires further elaboration and does not provide sufficient information at this time. It is recommended that a detailed profile be included of non-job seekers allowance out of work benefit claimants in analysis especially those considered economically inactive who would be interested in returning to work. The Councils fully support the procurement strategy to involve a local workforce; however there is concern that the local workforce estimate may not be realistic. Local labour content in more recent studies is substantially below the 50% assumption level quoted in the Stage 1 Consultation document. It is recommended that further sensitivity testing be undertaken in relation to a lower local labour assumption and its effects on the distribution of the workforce arising from a lower percentage. The size of the European construction skills pool in nuclear reactor construction will in part be influenced by the number of concurrent projects within the overall build programme. Consideration should be given to the relative phasing of construction programmes across the UK and European fleet. The study could benefit from a bottom up analysis of the labour demand relative to the labour supply using SOC categorisation. The baseline needs a fuller account of the likely work force implications arising from associated development and preliminary development (eg the creation of hostel accommodation and Park-and-Ride). No reference is made to how this training strategy will deal with the issue of displacement. There is currently no differentiation of those in receipt of out of work benefits in terms of the barriers presented to get back to work
27) Jobs and Training
in securing specific job outcomes in the project or through associated development. It is recommended that EDF Energy scope a route map for different groups of people on out of work benefits describing how the project could create opportunities for different groups targeted by the LADS. There should be explicit recognition of LAA targets in the training and procurement strategy. There is a need for EDF Energy to demonstrate how Bridgwater College will work alongside community development organisations and organisations such as Homes in Sedgemoor to effectively reach certain difficult to reach target groups especially at neighbourhood level and amongst sub-groups of the economically inactive. Further information is required on the level of engagement achieved between training providers and foreign companies in supply chain regarding agreements to train specific numbers of local people for specific job opportunities on the project. The authorities will require a well developed employment and skills charter for local people at District level.
Smallpeice Trust The Trust wish to be involved in the project, particularly in encouraging the study of STEM subjects in local schools and colleges.
Somerset Chamber of Engage with local colleges and other partners to assess how any skills gaps can be addressed. Develop a one-stop web portal Commerce and Industry through ‘Into Somerset’ to inform any business interested in the project. Regular procurement seminars to inform on progress and process – so access to pool of local suppliers.
Somerset County Council The Training and Procurement Strategy should identify how the project will create opportunities for different groups and recognise local priorities. An understanding of the economic impacts particularly on local labour content of the project needs to draw on data on the economic impacts of similar projects. By training workers in specialist skills, is there a chance of future loss of benefit to Somerset as trained workers then leave the area to work on other nuclear projects?
South West Regional Discussions are required between EDF Energy and the Energy Skills Centre at Bridgwater College. The view is to ensure that Development Agency opportunities for energy skills development in areas such as construction, science and engineering are secured for the local community.
Taunton Chamber of Taunton Chamber believe that the Taunton Deane area population is well placed to provide some of the necessary skills required for Commerce the build project plus a future population who could train for the specialist skills required both on the project build and during the running of the new station. Somerset College already has a regional reputation for providing suitable technical courses and is an ideal base for providing additional training courses for EDF Energy.
EF
27) Jobs and Training
As far as possible, skills should be drawn from the area and region where, currently, we are over dependent on public sector and often low-skilled, part time employment.
Taunton Deane Borough Somerset College is a key deliverer of skills and training in the region. Taunton Deane would like to ensure that Somerset College is Council involved in the Hinkley project. Taunton Deane recognises the huge opportunity for the local community to attain skills that will benefit the new nuclear plant and for the local colleges in becoming centres for the provision of training. Ensure that the relevant colleges are involved in discussions at the earliest possible time. The council request that EDF Energy use the Construction Skills Academy in Taunton for skills training during the construction period. Taunton wishes to promote itself as a destination for both workers and businesses associated with the EDF Energy development.
Williton Parish Council Encourage recruitment from the local community and schools.
28) Procurement
Consultee Comments
Bridgwater Town Council Support commitment to use local contracts and suppliers and use of local companies where possible. Interested to see how implemented in next stage.
Environment Agency There are no environmental considerations in the procurement strategy e.g. the Agency would expect EDF Energy to be seeking to find suppliers that are environmentally accredited.
Highways Agency The Agency supports the encouragement of sourcing supplies and services from the local area as this will minimise the generation of trips onto the SRN. Welcome procurement objectives, in particular the implementation of the Travel Plan which seeks to minimise the need for travel particularly by road and at peak periods.
Minehead and District Provide local traders and businesses with knowledge and experience so they don’t miss out on job opportunities. Chamber of Trade and Commerce
Sedgemoor District Council Provide more detail on economic regeneration and the delivery of local facilities/services. As locally based companies are more likely to hire local people, it would be beneficial to include a profile of local companies in the
28) Procurement and West Somerset Council baseline. The authorities require more information on mechanisms to be employed by EDF Energy to ensure support for local supply chain development initiatives and inward investment is secured and how such initiatives may secure legacy benefits. It would be useful to gain feedback from any Area procurement events that have already been held. Further socio-economic work (a full assessment of the locality and the likely supply chain relationships of the project) should be carried out, with information from international data on the economic impact of projects recently constructed in other countries. It is recommended that there is clear recognition of LAA targets in the Training and Procurement Strategy. Baseline information on local company capabilities to supply the project is largely absent from the document and supporting information. The Stage 1 Consultation document contains no specific reference to the VAT stock composition of the study area used to analyse the baseline yet this is a bench mark an indicator used in the LAA Targeting Framework for Somerset. There is no assessment of the proportion of businesses in knowledged driven sectors with a potential to supply the project. There is also no representation of the current state of the knowledge economy in relation to companies engaged in relevant high technology and medium high technology capable of supplying a project. Baseline socio-economic data provided by EDF Energy as an external reference to the Stage 1 Consultation document should be expanded to include an analysis and VAT stock profile for the study area to align with LAA targets NI171 and NI172. Paragraph 7.2.3 includes reference to “where practicable, to stimulate and secure inward investment into Somerset to achieve economic restructuring”. There is no mention of supply change opportunities related to associated development. Further information on contracting models would be welcome. Further work will be required on the onward investment strategy and the procurement strategy within the District and the County Council. The Councils fully support the procurement strategy to involve a local workforce; however there is concern that the local workforce estimate may not be realistic. Local labour content in more recent studies is substantially below the 50% assumption level quoted in the Stage 1 Consultation document.
EF
28) Procurement
Somerset Chamber of ‘Into Somerset’ could support EDF Energy to coordinate procurement, training and inward investment opportunities. Commerce and Industry Legacy – keen that the legacy to the economy is as great as that for the infrastructure. Companies attracted to Somerset as inward investment should be encouraged to lay down long standing roots that exceed the construction phase. Hope that after construction is completed that Somerset-based businesses continue to be contracted to provide a significant amount of on-site non-technical support as is the case with existing A and B sites.
Somerset County Council As well as inward investment, business start up and indigenous growth are also important to the council. More focus is required in these areas. More information is required on the mechanisms to be employed by EDF Energy to ensure support for local supply chain development initiatives. More information is required on how local supply chain initiatives will reduce the physical impacts associated with the development (such as transport etc). In addition to construction period benefits, EDF Energy also need to address the operational procurement opportunities for the County. Potential for contractual conditions. It is not clear how the use of 50% of local labour will be delivered. This issue needs to be addressed through further socio- economic impact work, drawing on data from projects recently constructed in other countries. The socio-economic assessment methodology is not the best means to accurately assess the economic impacts of a project of this scale. An assessment of the likely supply chain relationships of the project (drawing on international data on the economic impacts of similar projects) will gain a better understanding.
Taunton Chamber of Fully supports measures by EDF Energy to enable local businesses to be involved in the build project either directly or indirectly. Commerce
Taunton Deane Borough Taunton wishes that its business community has the opportunity to understand how it might become part of the supply chain and Council benefit from this major investment.
29) Benefits to the Community
Consultee Comments
Bridgwater College Proposed development is an exciting opportunity for the community at large.
29) Benefits to the Community
EDF Energy’s willingness to enhance the communities at Cannington, Williton and Bridgwater is supported. There are several projects that the college would want to propose including recreational/sporting developments at Cannington, development at Cannington Court, theatre development on Bath Road in Bridgwater and purpose built training facility for creative skills.
Bridgwater Education Trust Would welcome further discussion about community benefits.
Bus travel and safe access for our pupils walking and cycling to the school. What will be the family catchment given where the new school (Haygrove) will be situated. Can there be funding across the schools for the new build? For example, Haygrove would like an all-weather pitch/contribution to the science block etc. Encourage the use of the linguistic specialism i.e. for families coming from France. The Trust would be interested to know more about what support EDF Energy will provide for community facilities. The Trust would wish to work together with EDF Energy to assist in identifying such provisions. The Trust will be asking EDF Energy for funding for school facilities, e.g. Haygrove School would like an all-weather pitch/contribution for a science block.
Bridgwater Forward Hope EDF Energy will back the provision and future operation and management of suitable public swimming facilities within Bridgwater Town Centre at the Northgate site.
Bridgwater Town Council The Town Council is supportive but considers it essential that local issues are resolved in favour of the local communities of which Bridgwater as the ‘host’ town is the key settlement. Benefits to the community should be seen in three phases to produce a comprehensive package: The now – commitment to the area – balancing high environmental impact with socio-economic needs Mitigation – compensation through service support – e.g. health, leisure, social, cultural, extra policing and civil protection Long term benefits – supporting infrastructure for transportation and environmental gain, the socio-economic offer, helping achieve the objectives of the Bridgwater Vision and regeneration of the fabric of the town, including the public realm.
Burnham Boat Owners Sea At the end of its life can the jetty be used as an artificial reef? Angling Association
Cannington Parish Council Whilst would welcome any help in the village through new projects such as a new village centre that has parking facilities or affordable housing, not convinced that the advantages would outweigh the disadvantages.
Devon County Council The community benefits package could include awareness raising about low carbon/renewable energy.
EF
29) Benefits to the Community
Further clarity on the legacy plan.
Environment Agency There are opportunities to enhance the level of flood protection especially in Williton and Cannington. These opportunities should be fully utilized as this would be of high community benefit. Cannington bypass (eastern route option) does offer the opportunity for legacy benefits in the form of an enhanced tidal protection to some areas due to the road acting as a defence barrier. Within each development green infrastructure should be incorporated where practicable to enhance the environment in which the local community live in and provide a valuable resource to local residence.
Haygrove School Would welcome discussions about bus travel and safe access for our pupils walking and cycling to the school and community benefits.
Highways Agency The Agency supports the package of mitigation measures identified to reduce or eliminate the potential impact on the local area. In particular, the Agency actively encourages construction time limits, construction phasing restrictions, and sustainable transport (e.g. Travel Plan, Combwich Wharf, Temporary Aggregates Jetty, Cannington Bypass and localised road improvements). The Agency would like to be involved with discussion about the potential legacy of site J23-B (continuation of a park and ride to serve Bridgwater and/or part of the site to be developed for employment use).
Kilve Parish Council Footpaths – from Sea Lane to Rowditch Lane (A39 East) and From Village Hall to Midlands Farm (A39 West). Both of these routes are regularly used by walkers which entails them going along the A39. This is currently a dangerous road and will become more so with the proposed increased traffic. A new Village Hall or major refurbishment of the existing hall – preserving the old hall but providing a modern interior. Kilve Cricket Club has been in existence for 150years and is the only youth facility in the area. Over the last few years they have built a new pavilion, which still needs electricity. They would also like to enhance the amenities for spectators by providing seating and a children’s play ground to be used by the villagers and visitors to the beach area.
Landowner Bridgwater The College believes that the proposed development is an exciting opportunity for the community at large and the College in College particular. The College welcomes the fact that EDF Energy is proposing to recruit local people for employment at HP. The college and EDF Energy have already had fruitful discussions about the training opportunities that EDF Energy might access through Bridgwater College. The development of the Energy Skills Centre forms part of this discussion. This facility is already under construction with contributions from the Nuclear Skills Academy, the SWRDA, the NDA. College borrowings are also currently underwriting the residual funding of this £7.765m project. It is anticipated that EDF Energy will also want to contribute financially to the project as well as encouraging the supply chain to both contribute to its construction and equipment as well as making full use of the facility in terms
29) Benefits to the Community
of training options.
Minehead and District Welcomes the great opportunity for West Somerset and Minehead and supports any opportunity to increase and improve Chamber of Trade and Minehead’s economy and the possibility of workers living in Minehead. Any pressure from workers and their families on local Commerce facilities should be overcome.
Nether Stowey Parish Council If development at Nether Stowey – suggested legacy benefits (owned by a Community Trust) include affordable housing, a residential care home/nursing home for local people, accommodation for small businesses. Development could involve ancillary parking and social and leisure facilities, both of which should have a legacy use. Mitigation, regardless of whether or not there is associated development in Nether Stowey, includes: support affordable homes to rent in the village; support local tourism initiatives; support community cohesion, voluntary projects in the village and provision of youth, leisure and other community facilities; and provision of health, education and other social services.
Otterhampton Parish Council An all weather surfaced play area close to the village of Combwich; improvements to the Village Hall, a shelter for the crèche; and a safe cycle route from Hinkley to Cannington.
Parish of Stockland Bristol There are no specific requests for Stockland-Bristol; The Parish is not demanding a village hall or playing fields etc. The Parish is supporting EDF Energy’s quest for build a new power station for the future of the country. The area needs to have new roads and infrastructure, this will be another lasting legacy.
Parrett Internal Drainage In accordance with Planning Policy Statement 25 the associated development sites will seek to improve the local flood risk as part Board of the development.
Passenger focus Park and ride sites may also benefit the local community by producing additional services for them. The provision of such facilities would be welcomed and it may be that the research carried out by Passenger Focus on passenger priorities may be of some use when entering the planning phase for such facilities.
EF
29) Benefits to the Community
RAC Foundation Improvements to the A39 (the major access route to/from West Somerset and the adjacent part of Exmoor) would be a general community legacy benefit.
Sedgemoor District Council The authorities request that a community benefit package is developed to offset the consequences of hosting any new nuclear and West Somerset Council project. The authorities would prefer the provision of housing accommodation for workers that is of a permanent form of construction and that can be adapted and transferred following construction of the Hinkley Project to an appropriate body to address local housing needs. Engage with the Councils and Registered Social Landlords (RSLs) to identify the specific types of housing needs in locations where campus developments are proposed. The provision of student accommodation and sheltered accommodation in appropriate quantities and location is supported. Provide a full assessment of the social and community infrastructure requirements of the proposals for the following sectors: Libraries, community centres and cultural facilities; social services; education; emergency services; health; and sports facilities, recreation and open space. The creation of a community woodland would be a possible restoration option. It is necessary that the councils and communities are able to influence decisions on associated infrastructure so that positive legacy outcomes can be achieved. Further consultation with Cannington Parish Council and Sedgemoor District Council is required to understand opportunities for legacy use of campus recreation facilities, for instance as a community centre. The Councils recommend that joint discussions with EDF Energy, Somerset County Council and bus operators are held to understand the opportunities for high frequency public transport services to be integrated with the park and ride services as a legacy benefit. The authorities would prefer EDF Energy to use park and ride sites that could ultimately provide a legacy benefit. Community benefits are presented in terms of project attributes and characteristics rather than any holistic approach to managing a long-term commitment. No definition has been offered concerning what EDF Energy constitutes as community benefits There is limited information on enterprise/SMES and this is an important emission as these could compete for some of the sub- contracting opportunities. The section is structured around an inventory of measures covered in other parts of the document. It does not present any firm basis
29) Benefits to the Community
for how EDF Energy will support communities over a longer time frame. This needs to be considered as the work develops. There are limited references to community need and the management of need in relation to a realistic level of support funding. Options have not been presented for the purposes of developing an approach to community benefits or a route map to get a preferred option for long-term engagement. Further consideration should be given to how the training and procurement strategies might be used to procure services from projects established using this funding. With the exception of employment and skills descriptions, there is a limited amount of detail on a strategic approach to economic regeneration and the delivery of local facilities/services (community benefits). It is not clear whether it is EDF Energy’s intention to look for financial sustainability or whether the intention is to make general investments in projects with a social objective (without seeking a financial return). The strategic approach should be defined. Further information is required from EDF Energy on the non-financial participation in the community. The scoping of a specific community benefit strategy is absolutely essential to maintaining the long-term viability of the project. The community benefit strategy should provide guidance as to how legitimate needs not yet definable may be addressed. The principles for supporting projects that are likely to emerge from the community need should be articulated and clarified. Options for Government structures need to be explored including how EDF Energy will carry through any culprit social responsibility to impacted areas. These options should consider a social enterprise delivery model for appropriate for discharging long-term responsibility. Consideration should be given to the balance between supporting capital and running new projects. It will be helpful if the boundaries for the disbursement of funding to projects were to be defined to geographical areas which bear the impact of the site and its construction, operation and decommissioning. Expectations concerning funding leverage from other social partners should be established. It is currently unclear as to what role other social partners may play. There is limited indication from the evidence presented as to what form the community benefits should take over and above employment and skills/workforce development. Further information is required in this respect. It is not clear as to the extent of dialogue that has taken place with partners and communities. This should be investigated further. The legacy use of worker accommodation in Bridgwater could provide a high quality hotel that the town currently lacks. A strategic transport investment package will be sought for Bridgwater as part of the planning obligations. The provision of fully-serviced employment sites may represent an appropriate legacy use for worker accommodation.
EF
29) Benefits to the Community
Workers accommodation should be accompanied by leisure related facilities that could provide a long-term legacy use for the local communities.
Smallpeice Trust Trust hopes to play a successful part in the project in encouraging STEM subjects in local schools and colleges.
Somerset Chamber of Legacy – use proposed campuses for student accommodation. Need to avoid them becoming housing ghettos – they should not Commerce and Industry become the answer to homeless or affordable housing issues without careful consideration, planning and management.
Somerset County Council It is believed that a community benefits package should also be created for the wider Somerset community, to offset the consequences of hosting a nuclear power plant. A community benefits package should be developed that takes a long term view- creating a legacy for the development and recognising local aspirations for community, social and economic investment. Involve the local authorities, other key stakeholders and the community who will have an interest in the Hinkley project, in the development of the community benefits package. The requirement for additional road improvements should be identified. It is suggested that as part of the Stage 2 Consultation, EDF Energy is clear about what is required for planning mitigation and what added value can be brought to the community of Somerset in the form of community benefit. Need for a wet weather attraction linked to the low carbon agenda to mitigate the negative impacts of the development.
Somerset County Council Would like to work with EDF Energy through the Bridgwater Educational Trust to enhance use of the BSF sites for the local (Building Schools for the community. Future) Would like EDF Energy to ensure the continued safety of and safe access to the new Haygrove and Penrose site west of Durleigh and the Chiltern Trinity Technology College (both adjacent to A39).
Somerset Leisure Want to discuss how health and well-being, physical and sporting activities could be included in EDF Energy’s future plans for the area and benefit the local population.
Somerset Leisure, Haygrove Would welcome further discussion about community benefits. School
Somerset Wildlife Trust EDF Energy has not demonstrated that associated accommodation will be sustainable. The accommodation needs to offer an end purpose to the local communities. EDF Energy has an opportunity to contribute to landscape conservation activities within the local environment for the benefit of
29) Benefits to the Community
communities. By working with conservation organisations and stakeholders, EDF Energy can create an accessible, inspirational landscape rich in wildlife. SWT believes that EDF Energy has an opportunity to demonstrate its commitment to the quality of life of local communities by creating a lasting landscape legacy: an inspirational place rich in wildlife for all to enjoy. The associated off-site developments have an excellent opportunity to create substantial wildlife gains. Perhaps a community woodland or a county wildlife park could be offered up, not only as a means of conserving precious local wildlife, but creating somewhere for present and future local communities to experience and enjoy their rich natural heritage.
South West Regional It will be good to understand further how the development proposals will complement the ‘The Bridgwater Challenge’ work and Development Agency therefore the economic regeneration of Bridgwater.
Stogursey Parish Council Wish to see substantial investment in the local school to maintain and enhance it for future generations.
Taunton Deane Borough There are a number of sites within Taunton with planning permission which could deliver workers’ accommodation quickly and to a Council high standard. There is already an existing need for affordable housing or nursing/student accommodation which could be considered for future uses once no longer required by EDF Energy.
Wembdon Parish Council At this stage the vision is to provide facilities for junior football, village cricket and a village hall plus a multi use play area. Such a facility could be offered as a recreational area for construction and establishment staff and would be an opportunity to facilitate good relations between the existing and incoming communities.
West Hinkley Action Group Recognition of loss of amenity in the enjoyment of house and garden by giving financial support for individual mitigation measures such as tree-planting, double glazing etc. A guarantee with reference to both short and long-term property values in the form of compensation and/or a guarantee of support of sale for properties suffering from planning blight. An on-base resident Community Liaison Officer in Stogursey Parish for the duration of build and operation to establish and maintain mutual understanding, reciprocal consideration and good relationships between developer and local residents. The land released to the south (by moving the buffer northwards) should become an amenity area for local residents, which during construction would go some way towards compensating them for the loss of numerous Public Rights of Way.
West Somerset Council Amongst the community benefits to be considered should be improvement to local facilities such as the fabricated buildings at Stogursey School. The Council is concerned about the lack of detailed information on the intentions of EDF Energy to commit to delivering benefits for
EF
29) Benefits to the Community
the local communities.
Williton Parish Council Look at the needs of the younger community and how Williton is developed for the future in terms of work and new businesses.
Appendix A.8
TABLE OF ISSUES NOT DIRECTLY RELATED TO THE PROPOSALS
EF Appendix A.8: Table of Issues Not Directly Related to the Proposals
30) Nuclear Energy and the Principle of Development
Consultee Comments
Bristol City Council Minded to object proposals for additional nuclear power station at Hinkley Point. Inefficient and poor use of resources in face of alternative and safer sources of energy. Constraint placed on the effective delivery of alternative renewable energy to the energy network in the Hinkley Point area.
Cannington Parish Council In principle do not oppose the proposed new build at Hinkley Point, cannot see benefits to the village in the form of local trade and employment. Wish to remain a village and feel there are better sites in local towns, especially Bridgwater.
Cannington Women’s Institute No objection to the power station – just the associated work.
Environment Agency Proposals need to take these into account the relevant NPSs.
Greenpeace Nuclear power is inadequate because it is too little too late, unnecessary because we can reduce emissions and use better technologies and dangerous due to intractable problems of radioactive waste and nuclear weapons proliferation.
Highways Agency Can the “Associated Development” form part of the main application to the IPC or will separate applications be needed under TCPA 1990?
Minehead and District Chamber of Support the proposed development in principle and support any opportunity to increase and improve the Minehead Trade and Commerce economy. Development could bolster the tourism accommodation providers income in quieter times but does not wish development to result in a significant number of tourism bed spaces.
Nether Stowey Parish Council Consider and welcome the proposed development of Hinkley Point C as a significant and positive investment in the area, however, there are pressures and challenges that need to be addressed
Parish of Stockland Bristol In the majority, does not have any problem with the new station or 2 at Hinkley Point and in fact recognise the need for power in the 21st century and the majority do not have a problem with nuclear power.
Sedgemoor District Council and Proposed siting of the Hinkley Point C power station is supported by the authorities.
30) Nuclear Energy and the Principle of Development West Somerset Council
Smallpeice Trust Vital investment to ensure energy security.
Somerset Chamber of Commerce Fully supports the principle of a new nuclear power station based at Hinkley Point C. and Industry
Somerset County Council Support development at Hinkley and nuclear power on the basis that the operation is demonstrated to be safe and associated benefits outweigh environmental impacts. SCC support nuclear power and the expansion of new nuclear development at Hinkley Point provided the benefits of development outweigh environmental impacts.
Somerset Wildlife Trust Expect new energy projects to generate substantial carbon emission savings and deliver a net gain for local biodiversity.
South West Regional Development Keen to understand how the development proposals will complement the economic regeneration of Bridgwater. Agency Interested in the contributions to ensure a sustainable and secure energy supply is provided at a regional level. Broadly supportive of development proposals.
South West Strategic Health Support a sustainable approach to energy production including reducing demand, increase in energy efficiency and develop Authority local renewable energy systems. Acknowledge role of nuclear power in providing part of the UK’s energy requirements.
Stop Hinkley Object to the building of a new nuclear power station because of the health risks to local people and risks from a serious accident or terrorism. Question the need for additional energy by nuclear power.
Taunton Chamber of Commerce Believe Taunton Deane, Somerset and the region will benefit from such a substantial infrastructure development that requires the highest skills and technical abilities.
Wembdon Parish Council (late Wembdon has a long-standing and positive connection with the Hinkley Point power stations and the Parish Council response) considers and welcomes the proposed development of Hinkley Point C as a significant investment in the area. However, believe a project of this size brings with it pressures and challenges which will need to be addressed at the planning stage or will have a detrimental impact on Wembdon.
EF
31) Submission Documentation
Consultee Comments
North Devon Council Need to undertake a Sustainability Appraisal, undertake and EIA and prepare an Environmental Report.
Sedgemoor District Council and Strongly advise that in addition to including an Environmental Statement and Consultation Report in support of the DCO West Somerset Council application, EDF Energy also submits the following documents: A full Transport Assessment and Travel Plan, including a transport assessment of the associated development and options that have been taken forward and rejected. A Flood Risk Assessment A Health Impact Assessment A Construction and Logistics Strategy An Environmental Management Plan Economic Assessment using the Sedgemoor District Council Checklist A Procurement and Training Strategy summarised in an Employment and Skills Charter A draft of a Development Consents Obligation
32) Stage 1 Consultation
Consultee Comments
Quantock Hills AONB Service Quantock Hills Service not mentioned as being consulted in 3.1.4.8 Quantock Hills AONB Service is not mentioned in Table 1.1. Consultation to Date
33) Further Consultation
Consultee Comments
CABE Not commented on associated development, welcome the opportunity to do so.
Countryside Council for Wales Welcome approach by EDF Energy in the creation of liaison groups to advise on both authorisation process and the issues that need to be addressed in the EIA.
Ministry of Defence Encourage further engagement with EDF Energy prior to submission and to develop mitigation strategies.
NHS Somerset Suggested consultation between the ambulance service and EDF on proposals. Request direct consultation because of the implications for health service planning for the future.
Sedgemoor District Council and No ‘new’ options should be incorporated at Stage 2. West Somerset Council
South West Regional Development Continue to meet team for more informed discussion Agency
Taunton Deane Borough Council Wish to be involved in ongoing consultation.
Error! Reference source not found. Error! Reference source not found.
Appendix A.9
REFERENCE TRACKING SYSTEM
301 _Ref264545301 \r \h \* MERGEFORMAT |Error! Reference source not found.} Error! Reference source not found.d.
Appendix A.9: Reference Tracking System
This tracking system is designed to enable those respondents, who submitted comments in their questionnaires, to track EDF Energy’s responses to the key issues raised, as set out in Chapter 5 of this report. By each individual reference number is a list of section numbers, which can be cross referenced with the list below. Those respondents who only ticked the boxes in the questionnaires have not been referred to other sections, therefore their reference box remains blank.
1 Preliminary Works
2 Construction Activities and Restoration
3 Southern Landscape Buffer
4 On-site Accommodation
5 Operational Considerations and Design
6 Landscape and Visual
7 Spent Fuel, Waste and Decommissioning
8 Marine Development
9 On-Site Parking and Access
10 Overhead Line Infrastructure
11 Amenity and Recreation
12 Historic Environment
13 Environmental Information and Assessment
30214 Other Environmental Issues
15 Other Hinkley Point C Development Site Comments
16 Overall Strategy
17 Overall Accommodation Strategy
18 Overall Transport Strategy
19 Cannington
20 Cannington Bypass
21 Combwich Wharf
22 Williton
302
Error! Reference source not found. Error! Reference source not found.
23 Bridgwater
24 Junction 23, M5
25 Junction 24, M5
26 Broader Community Issues
27 Jobs and Training
28 Procurement
29 Benefits to the Community
30 Nuclear Energy and the Principle of Development
31 Submission Documentation
32 Stage 1 Consultation
33 Further Consultation
Reference Sections Number
172
181 11 and 18
183 19 and 20
184 11,19,20,21,23,27 and 29
186
187 11,17,18,20,21,22 and 23
189 14,18,19,21 and 22
191 1,2,3,4,6,8,11,18,20,21,22,24,27,29 and 32
198 29
200 4,14,17,18,20,22 and 29
201
202 11,17,20,27 and 29
203 4,11,18 and 22
303 _Ref264545301 \r \h \* MERGEFORMAT |Error! Reference source not found.} Error! Reference source not found.d.
Reference Sections Number
204 1,2,3,4,11,16,19,20,21,22,25,27,29 and 32
205 14,17,18,20,25 and 30
206 6,18,19,22,27 and 29
207 16,17,18,19 and 20
208 1,2,18,20 and 21
210 1,11,18,19,20,21,22,23,27, and 29
211 18,19,27 and 30
212 1,16,17,18,19,20 and 27
214 11,15,18,19,20,27 and 29
215 18,19,20,21,22,24,25,27 and 29
216 11,14,18,20and 27
217 1,2,11,14,17,18,19,20,21,27 and 29
218 3,11,16,17,19,20 and 26
219 3 and 4
220 2,4,11,16,18, ,27 and 29
221
304222 2,11,6,18,19,20,21,24,27 and 33
223
224 4,18,21,23 and 29
225 11,14,17,1819,20,29 and 30
226 8,11,18,20 and 27
227 18,20,21 and 29
228 2,3,4,6,14,17,19,20,21,29 and 30
229
304
Error! Reference source not found. Error! Reference source not found.
Reference Sections Number
230 1,2,3,4,6,11,17,18,20,21,22 and 29
231 4,17,18,19, 20,21,23,29 and 30
232 26 and 29
235 3,11,20 and 22
238
239
240 1,2,4,11,16,20,21,22,23,27 and 30
241 3,18,20,22,23,27 and 29
242 4,6,11,17,18,20,21,27,30 and 32
243 1,2,3,11,14,17,18,19,20,21,27 and 29
244 7,18,22 and 23
245 17,18,21 and 29
246 16,17,18,19,20,21 and 29
247 4,11,18,20,21 and 30
248 14,18,19,20,26 and 32
249 2,4,7,11,20,21,22 and 23
250
251 19 and 20
252 3,11,17,18,19,21,29 and 33
256 18,29 and 32
257 4,17,18,19,24 and 29
258 11,21,22 and 30
259 4,11,19,20,21,22,27 and 29
260 2,3 and 21
261 4,17,20,21 and 25
305 _Ref264545301 \r \h \* MERGEFORMAT |Error! Reference source not found.} Error! Reference source not found.d.
Reference Sections Number
262
263 1,3,8,11,17,18,21,23,27,29 and 30
264 16,17,20 and 21
265 2,3,11,18,21,27 and 29
266 4,6,11,19,21,27 and 29
267 3,11,17,18,19,21,24,25,27,29 and 30
268 3,4,18,19,20,21,22,23 and 29
269 17,19,20 and 30
270 11 and 20
271 19
272 20
273 1,11,20,21,25,29 and 30
274
275 20
276 2,17,20 and 29
277 11 and 19
306278 22
279 14,18,22 and 29
280 4,7,9,18,19 and 29
281 2,3,11,17,20,21,24,25,27 and 29
282 20
283 11,12 and 30
284 18,21,22 and 29
285 4,18,22,27 and 29
306
Error! Reference source not found. Error! Reference source not found.
Reference Sections Number
286 4,17,18,20,21,22 and 23
287 18
288 17,18 and 30
289 15,17,18,19,20,21 and 29
290 2,20,30 and 32
291 21,27 and 29
292 1,4,6,10,11,17,19,20,22,27,29,30 and 32
293 18,22 and 23
294 4,18,19 and 20
295 19 and 32
296 2,11,18,21,23,24 and 27
297 20
298 16 and 18
299 19,20,21,23 and 24
300 1,4,16,18 and 22
301 18,22 and 33
302 2,11,17,18,20,21,23,25,27 and 29
303 3,4,8,11,16,17,18,19,20,21,23,27,29 and 30
304 6 and 9
305 2,3,4,11,16,18,27 and 29
306 16
307 2 and 11
308
309 3,9,10,16,18,19,21,22,23,27,29 and 33
310 11,20,21,25 and 27
307 _Ref264545301 \r \h \* MERGEFORMAT |Error! Reference source not found.} Error! Reference source not found.d.
Reference Sections Number
311 18
312 18
313 6
314 2,3,4,11,17,18,19,20,21,22,23 and 29
315 22
316 22
317 18
318 3,4,6,11,17,18,19,21,24,25,27,29 and 32
319 7, 17,20 and 21
320 2,11,12,17,20,21,27 and 29
321 2,3,11,12,14,15,20 and 23
322 11,17,18,20,22,23 and 24
323 2,3,4,11,20,22,27,29,32 and 33
324 19
325 3,11,17,18,19,20,21 and 27
326 11,18,19,20,21,24 and 29
308327 11,18,21 and 25
328 8,17,19 and 29
329 2,4,5,6,8,11,17,20,22 and 24
330 17,18,19,21 and 29
331 11,18,20,21,22,23 and 27
332 14
333 17,20 and 23
334 18,21 and 29
308
Error! Reference source not found. Error! Reference source not found.
Reference Sections Number
335 11 and 23
336 3,11,20 and 21
337 2,11,18,20,22,29 and 32
338 18,19,20,21,27,29 and 30
339
340 2,11,18,19,20,21,23,24,25 and 27
341 4,11,14,19,20,21,27 and 29
342 2,4,11,12,14,17,19,20,21,22,27 and 33
343 8,11,17,18,20,21,24 and 27
344 11 and 22
345 11,17,22 and 27
346 24 and 25
347 19 and 20
348
349
350 19
351 18,19,20,22,23 and 29
352 2,3,6,17,20,21,23,27 and 29
353 1,4,11,14,17,18,20,21,27,29, 30,32 and 33
354 17,18,19 and 27
355 11,14,15,18,19,21,23,27 and 30
356
357 18 and 29
358 18 and 23
359
309 _Ref264545301 \r \h \* MERGEFORMAT |Error! Reference source not found.} Error! Reference source not found.d.
Reference Sections Number
360 4,18,20,27 and 32
361 18,19,20,21,24,25 and 29
362 18,19 and 20
363 18,19 and 20
364 30
365 2,12,14 and 20
366 3,17,18,19,20 and 29
367 1,18,23 and 29
368 11
369 11,17,18,19,20,21,23 and 29
370 17,18,19,20,21 and 27
371
372
373 21 and 27
374 3,11,17,18,19,20,21,23,27,29 and 30
375 22,27,29 and 30
310376 17,18,20,24,25 and 30
377 1,2,6,11,26,27,29 and 32
378 2,6,17,18,20,21,22,29 and 33
379 11,22,27 and 29
380 1,3,11,17,18,20,21 and 29
381 1,3,11,16,17,18,20,21,22,24,27 and 29
382 4,17,18,21,22,23,2730.32 and 33
383 1,18,19 and 29
310
Error! Reference source not found. Error! Reference source not found.
Reference Sections Number
384 19 and 20
385 19 and 20
386 1,16,18,21 and 29
387 17,18,20,27 and 29
388 1,3,11,14,18,19,21 and 29
389 2
390 19,20,21,24,25,29 and 32
391 1,2,7,11,17,20,21 and 27
392 18,20 and 21
393 1,2,3,11,14,18,20,21 and 29
394 11,16,17,21,22,27 and 32
395 1,2,3,11,14,17,18,20,21,23,27 and 29
396 2,21,22 and 27
397 2,3,11,20 and 21
398 1,11,18,29 and 32
399 14
400 7, 14 and 20
401 2,3,4,14,17,21,26,27 and 30
402 1,4,18,19,20,21,23,27 and 29
403 2,3,17,18,20,21,27,29 and 30
404 20,27,29 and 32
405 1,11,17,18,20,21,23 and 29
406 18,19,20,23,24,29 and 30
407 18
408
311 _Ref264545301 \r \h \* MERGEFORMAT |Error! Reference source not found.} Error! Reference source not found.d
Reference Sections Number
409 17 and 18
410 2,4,6,11,17,19,21,22,23,27 and 29
411 3,4,11,19,21,29 and 30
412 4 and 22
413 3,4,9,20,21,22 and 27
414 17,18,21,22 and 29
415 4,8,11,14,18,21,27 and 30
416 6,19,20,21,22,27,29,32 and 33
417 3 and 29
418 7,11,27 and 29
419
420 11,22 and 32
421 7,11,16,27 and 33
422 3,11,17,18,19,21,27,29 and 30
423
424 22,29 and 32
312425 14
426 14
427 1,2,11,12,16,18,19,21,22,24,27 and 29
428 1,2,11,19,20 and 29
429 1,2,3,4,18,19,20,21,22,27,30 and 33
430 1,8,11,16,17,18,22,23,24,27,29 and 30
431 7 and 30
432 2,3,4,8,11,19,20,24,26,27 and 29
312
Error! Reference source not found. Error! Reference source not found.
Reference Sections Number
433 2,3,8,11,17,19,20,24,25,27 and 29
434 4,11,20,21,22,24 and 27
435 3,17,27 and 29
436 11,17,18 and 29
437
438 1,2,11,16,18,20,21,22,23,27,29 and 30
439 11,17,18,19,21,23,24,25,27 and 29
440 1,18,29 and 30
441 1,6,7,11,16,17,18,20,21,27,29 and 33
442 2,3,8,11,17,18,20,21,22 and 27
443 20,22,29,30 and 33
444 6,11,17,18,20,21,24 and 25
445 22
446 2,3,11,14,17,18,19,20,23,27 and 29
447 8,14,17,23,24 and 29
448 3,4,6,11,17,18,20,22 and 32
449 18,19,29 and 30
450 2,3,13,19,20,27 and 29
451 1,2,3,13,18,21,22,23,27 and 29
452 2,3,4,6,9,11,17,18 and 33
453 1,17,18,22 and 29
454 3,4,6,11,17,18,20,27 and 29
455
456 4,17 and 21
457 1,3,4,9,11,17,20,21,24,25,27 and 29
313 _Ref264545301 \r \h \* MERGEFORMAT |Error! Reference source not found.} Error! Reference source not found.d
Reference Sections Number
458 1,2,27 and 29
459 11,16,20,21,27 and 30
460 3,11,18 and 32
461 3,11,13,17,18,20,21,22,27 and 29
462 2,4,6,11,18,20,21,23,27 and 29
463 25
464 2,3,4,6,11,18,21,23,29 and 32
465 11,19,21,22 and 23
466 1,3,4,6,11,13,17,18,20,21,24,25,27,29 and 33
467 11,23 and 29
468 19,25 and 29
469 17 and 22
470 11 and 27
471
472 9,11,17,18,21,22 and 29
473 1,14,18,19,20,29 and 30
314474 22
475 1,18,19,20,22,27 and 29
476 1,2,6,7,13,14,15,17,18,21,22,23,27,29,30,32 and 33
477 3,11,14,17,18,20,21,27 and 30
478 17,18 and 22
479 2,3,4,11,18,20 and 29
480 3,8,22 and 27
481 6,11,18,21 and 22
314
Error! Reference source not found. Error! Reference source not found.
Reference Sections Number
482 17
483 22
484 2,4,8,11,14,17,18,19,21,24 and 27
485 18 and 22
486 17,19 and 23
487 30
488 1,3,11,14,16,17,18,19,20,21 and 29
489 14
490 14,18,,20,23,24 and 30
492 11,17,20 and 27
493
494
495 7,11,20,27 and 29
496 19,21,23,27 and 29
497 2,3,4,11,17,18,20,21,22,27 and 29
498 4,11,18,20,21,22 and 29
499 2,3,6,13,17,20 and 30
500
501 3,4,11,12,18,20,21,29 and 30
502 18 and 19
503 11,18,21,23 and 29
504 1,11,17,18 and 32
505 17,19,21,23,29,30 and 33
506 1,19,20,21 and 29
315 _Ref264545301 \r \h \* MERGEFORMAT |Error! Reference source not found.} Error! Reference source not found.d
Reference Sections Number
507 11,17 and 22
508 5,11,18,20,21,27 and 30
509 2,3,4,11 and 29
510 1,2,3,4,11,17,18,19,21,22,24,29 and 30
511 22 and 30
512 4,7,11,22 and 23
513 18
514 11,18,22,27 and 29
515 18, 22 and 29
516 17,18,19,21,29 and 30
517 11
518 4 and 22
519 3,11,20 and 22
520 17,18,19,20 and 22
521 1,11,14 and 18
522 14,17,22 and 32
316523 4,11,21,27,29 and 30
524 2,4,11,14,16,19,20,21 and 22
525 1,3,4,11,16,17,18,27 and 29
526 17,18,19,20,22,23,24,27 and 33
527 1,3,4,11,16,17,18,27 and 29
528 11,17,18,20,21,22,27,29 and 33
529 4,27 and 29
530 16,22,32 and 33
316
Error! Reference source not found. Error! Reference source not found.
Reference Sections Number
531 4,17,22,27 and 29
532 18
533 22
534 2,3,4,16,18 and 30
535 2,3,4,8,18,27 and 29
536 17,22 and 29
537 4,18,19,27 and 29
538 18 and 27
539 1,2,3,4,11,18,21,23,24,27 and 29
540 11,20,21,22,27,29 and 33
541 4,14,18,19 and 29
542 2,4,11,18,19,20,21,22,23 and 24
543 8,18,20 and 29
544 1,2,11,14,16,17,20,21,23,24,27,29 and 30
545 17,18,22 and 29
546 2,3,6,11,20,21,22,27,29 and 33
547 2,7,11,14,15,17,19,22,24,25 and 29
548 17,21 and 22
549 1,2,3,11,13,17,18 and 21
550 1,2,3,4,11,14,16,17,18,20,21,29 and 30
551
552 14,17,20,21 and 22
553
554 23 and 29
555 22
317 _Ref264545301 \r \h \* MERGEFORMAT |Error! Reference source not found.} Error! Reference source not found.d.
Reference Sections Number
556 18,20 and 22
557
558 17
559 2,17,18,21 and 24
560 18
561 11,17,18,27 and 32
562 1,4,9,11,18,21,27, 29 and 32
563 11,18,20,21,27,29 and 30
564 19,20 and 27
565 2,11,18,19,20,21,27 and 29
566 11 and 17
567
568 21 and 27
569 3,11,20,21 and 29
570 7,17,21,22 and 29
571
318572 19
573
574 3,11,18,20,21,22,27 and 33
575 2,3,11,18,19,20,21,22,24,27 and 29
576 2,6,7,18,19,21 and 29
577 4,11,12,18 and 21
578 8
579 22
318
Error! Reference source not found. Error! Reference source not found.
Reference Sections Number
580 17,22,27 and 29
581 1,2,3,4,11,17,20,21,22,27 and 29
582 3,4,11,17,20 and 29
583 2,4,13,20,21,22,24,27 and 29
584 4,14 and 22
585 1,2,3,5,11,19,20,21,24,27 and 29
586 11 and 22
587 18,19 and 20
588
589 2,3,4,8,11,18,27 and 29
590 17,18 and 29
591 20
592 2,11,13,17,27 and 29
593 1,2,11,18,19,27,29 and 30
594 1,14,17,18,19,21,23 and 27
595 1,2,3,11,17,18,21 and 29
596 1,2,6,17,18,21,23,27 and 29
597 2,9,11,14,17,18,20,21,22,23,29 and 30
598 20,21,27 and 29
599 2,3,4,11,17,20,24,25 and 29
600 3,4,8,9,11,18,19,21,24,25,27 and 29
601 4 and 20
602 1,4,17,18,19,20,21,23 and 29
603 3,11,17,18 and 20
604 1,2,4,5,11,18,19,21,23 and 29
319 _Ref264545301 \r \h \* MERGEFORMAT |Error! Reference source not found.} Error! Reference source not found.d.
Reference Sections Number
605 3,4,11,16,20,21,22 and 29
606 4,18,19,29 and 30
607 19,20,22,29 and 30
608 11,17,18,21,22,27 and 29
609 17 and 21
610 16,17,19,20,21,27,30 and 33
611 2,6,8,11,18,20 and 21
612 1,9,11,19,21,27 and 29
613 9,11,14,19,20,23,27 and 29
614 4,17,18,21 and 23
615 18,23 and 29
616 2,5,6,11,17,18,19,21,23,24,25,27 and 29
617 2,3,11,16,18,19,21,23,27 and 29
618 8,9,11,14,17,18,20,23 and 33
619 18,19 and 23
620 18 and 22
320621 2,21 and 24
622
623 20
624 8
625 8
626 8
627 8
628 8
320
Error! Reference source not found. Error! Reference source not found.
Reference Sections Number
629 8
630 8
631 8
632 8
633 8
634 8
635 8
636 8
637 8
638 8
639 8
640 8
641 8
642 8
643 8
644 8
645 8
646 8
647 8
648 8
649 8
650 8
651 8
652 8
653 8
321 _Ref264545301 \r \h \* MERGEFORMAT |Error! Reference source not found.} Error! Reference source not found.d.
Reference Sections Number
654 8
655 8
656 8
657 8
658 8
659 8
660 8
661 2,4,14,18,22,29 and 30
662 2,4,18,22 and 29
663 19
664 11,17,20,22,27 and 29
665 7,18,20,21 and 22
666 21 and 29
667
668 2,6,11,17,18,21,22,27 and 29
669 11 and 27
322670 11,18,19,21,25 and 33
671 2,3,4,11,18,19,21,22,29 and 30
504-E
515-E 30
516-E 19
518-E 19
322
Error! Reference source not found. Error! Reference source not found.
Reference Sections Number
523-E 29
530-E 25
571-E 20
600-E 3,9,11 and 29
6046-E 32
23207-E 4,16,18 and 19
26164-E 2
26220-E 32
30697-E 19
30706-E 20
30711-E 20
30720-E 20
50697-E 20
50705-E 18
50717-E 18 and 30
50720-E 18 and 30
50733-E 20
50738-E 18
50878-E 4,1118,19,20,21,24,25,29 and 32
50885-E 6,8,14 and 17
50890-E 16 and 22
50899-E 5,14 and 30
50902-E 18 and 19
50906-E 18,19 and 20
50915-E 18
323 _Ref264545301 \r \h \* MERGEFORMAT |Error! Reference source not found.} Error! Reference source not found.
Reference Sections Number
50918-E 22
60794-E 22
60822-E 14,16,17,18 and 20
60839-E 19
60901-E 22
61065-E 22
62109-E 18
62110-E 30
62111-E 11
62113-E 30
62115-E 30
62119-E 29
62121-E 14
62125-E 22
62127-E 22
62128-E 14,18,27 and 30
32462129-E 18 and 22
62130-E 16,18,22 and 30
62139-E 22
62151-E 14
62172-E 14
62177-E 9 and 29
62178-E 9 and 29
62190-E 21
324
Error! Reference source not found. Error! Reference source not found.
Reference Sections Number
62192-E 18 and 29
62194-E 29
62202-E 20
62205-E 16,18 and 22
62206-E 14,16 and 30
62209-E 20 and 25
62211-E 19,20,23,25 and 32
62213-E 17,18,19 and 20
62216-E 18,22 and 27
62218-E 14
62220-E 30
62225-E 30
62227-E 4,17,18,22,23 and 29
62237-E 2,7,18,29 and 32
62239-E 14
62240-E 14
62245-E 20
325