Read the Response from Friends of the Earth Sizewell C

E: [email protected] www.scoastalfoe.com Members’ responses to Sizewell C Stage 3 consultation 1. SIZEWELL C PROPOSALS OVERALL Friends of the Earth are opposed to civil nuclear power because of its association with nuclear weapons and because there is still no satisfactory answer to the problem of the waste, some of which will not degrade for 240,000 years – far longer than modern humans have walked this planet. It is not possible to ‘dispose’ of nuclear waste. There are many other reasons for objecting to Sizewell C, some of which are described below. Policy context Chapter 3 of volume 1 Stage 3 Consultation refers to the planning policy context and the need for nuclear power. However, the government’s energy policy as stated in EN-6, published in 2011, is now out of date and this is currently being revised. Since then renewable forms of energy have overtaken nuclear in terms of cost and speed of construction, showing that nuclear is now old-fashioned. The government’s statement that the need for nuclear power is ‘urgent’ is clearly false, as the lights have not gone out. The reality is that there is no need for nuclear. Finance Nuclear power is hugely expensive and it is our belief that the public should not have to pay for it through subsidies, guarantees and insurances. Decommissioning and storage of waste need to be factored in. It is still unclear how EDF and CGN will raise the funds to pay for Sizewell C. We cannot believe that it is possible to build a copy of Hinkley Point C at Sizewell at 20% less the cost, bearing in mind that the site for the reactors is a marsh as opposed to a rocky foundation. Having to create a curtain wall and go down to a depth of at least 35m is surely extremely expensive. 2. THE MAIN DEVELOPMENT SITE: OVERALL The site at Sizewell was identified as only ‘potentially’ suitable. There are many reasons why it is entirely unsuitable, most particularly because the Suffolk coast is subject to significant erosion. With climate change, rising seas and more extreme weather, this can only get worse. New hard defences to protect against incursion from the sea will accelerate erosion and flooding either side of 1 the power stations, increasing the risk to these communities and threatening Minsmere RSPB Bird Reserve. The site is also in flood zones 2 and 3 and government policy is not to put infrastructure in such areas. Designated sites and tourism It is entirely within the Suffolk Coast and Heaths Area of Outstanding Natural Beauty (AONB) and Heritage Coast, a most unsuitable place for a massive industrial complex. The permanent access road would cut the AONB entirely in two and be an ongoing danger to the resident and visiting wildlife. It is directly adjacent to RSPB Minsmere reserve, with its EU designated habitats and Ramsar. The two reactors and access causeway would be built directly on Sizewell Marshes Site of Special Scientific Interest (SSSI), important for its wet fen meadow and ditches, supporting uncommon flora, a large community of invertebrates and assemblage of breeding birds of national significance. Of the plants, Frogbit and Soft Hornwort are classified as Nationally Scarce, as are a considerable percentage of the many invertebrates; some have special protection under the NERC Act 2006, s.41, being classified as Species of Principal Importance. Fen meadow cannot be recreated nor compensated for. Such destruction is unacceptable. It is not good enough to say that you will restore an existing piece of fen meadow. Which? Where? The loss of habitats and the animals that depend on these would have significant knock-on effects on our tourist industry, as would the loss of beauty of landscape and tranquillity. The huge size of the spoil heaps would be a terrible eyesore during construction. They would be within our AONB. These, together with the borrow pits, are likely to create a large amount of dust and noise, which would be intolerable to local residents and seriously disturb the wildlife of Ash Wood, where there are protected bats. The four very tall pylons, newly introduced into the proposals, would also be detrimental to the special landscape qualities of the AONB. Marine environment and beach According to the Environment Agency the cooling water infrastructure would result in the death of many tonnes of fish, despite the installation of a capture and return system. This would affect the sea birds and harbour porpoises that depend on such fish for food. This marine environment is part of the Outer Thames Special Protection Area (SPA), designated for the rare Red-throated Diver and Little Tern. There is still much work to be done concerning the impacts on marine life. You say that further details will appear in the Environmental Statement. Why are they not included in this consultation? 2 We see that dredging would be necessary to provide a clear passage for barges to reach the beach landing facility. How would the regular dredging and the arrival of the barges avoid the Sizewell and Dunwich banks, which you say protect the Sizewell coast? Under 2.14.1 you state that the beach landing facility ‘would have no significant effect on waves, sediment transport or the adjacent beach’. We know from experience of the BLF for SZB that this is patently untrue. The BLF had such a deleterious effect on coastal processes that the councils were obliged to demand that it be taken away. Where anything projects into the sea, there is erosion on the southern side, as any of the groynes clearly demonstrate. As the BLF would be constructed at the north of the site, this means that there would be erosion directly in front of the new power station. In order to construct the BLF and the new hard defences the whole beach in front of the power stations would have to be dug up. This is a County Wildlife Site (CWS) composed of vegetated shingle, which supports rare plants including sea pea and yellow-horned poppy. This shingle is also a Biodiversity Priority Habitat, which should be conserved and enhanced. Suffolk shingle beaches are important globally. You say that you will mitigate for the loss by saving seed and replanting on the defences. Such delicate plants will not survive on rock armouring at a height well above sea level. They thrive through an extensive underground network of roots seeking out water – not possible on such an engineered structure. Moreover, you propose to take away a further 5m of beach by positioning SZC forward of SZB. This will create coastal squeeze, with less space for natural roll- back, further increasing pressure on designated sites and communities either side. This is not acceptable. Potable water You do not say where the vast amounts of potable water would come from, necessary not just for the thousands of workers, but also to mix the concrete for the construction. This region suffers from drought and water is already short. No application should be submitted unless this has been sorted out. There would be direct competition with our farmers and the tourist industry. Moreover, the Environment Agency now declares that, in 25 years, due to climate change, there will not be enough water for people to drink. Drainage The hydrological balance in this marshy area is extremely fine and some rare and uncommon plants would not survive if this were in any way altered. We are concerned about the whole drainage issue and the impact of the very large causeway leading to the reactor platform. The Leiston Drain takes the excess water from the Leiston sewage works and out to sea. Rather than an 3 open river, as it is now, which naturally floods into the marsh either side as necessary, you would be squeezing this into a concrete culvert and on another side would be the concrete containing wall. What would happen, therefore, during a storm and high seas, when waves would be driven towards the causeway, preventing the natural outflow of the river? This could cause serious back-up flooding, which could be a disaster for wildlife, such as ground nesting birds and those that nest in the ditches, e.g. swans. There is also the question of sudden precipitation, worsening due to climate change. You do not indicate how you would cope with such matters. While you say that you would build a containing wall down to 35m for the main platform, then drain the marshes within that, we do not see how you could create this without some sort of general drainage. There is bound to be an effect on the surrounding marshland. We recall the building of Sizewell B, which caused land heave. We wish to see the precise calculations of how the surrounding marshland and fen meadow would be protected – and if this is impossible, then a statement of how much would be damaged in addition to the platform area. What would you do about the very acidic water withdrawn from the peaty marshes? How could it be safely disposed of? You do not say. This is a crucial matter. Size of site We are not convinced that it is possible to build the two reactors and additional buildings within the stated 32ha. Hinkley Point C is at least 45ha. We have noticed how the amount of land taken has gradually increased over the years. Now you want to destroy Coronation Wood and take even more of Goose Hill, with very substantial loss of trees. This is totally unacceptable. What next? 3. PEOPLE AND ECONOMY Jobs and training While it is true that local people need good jobs it is our view that it would be infinitely preferable to offer these from the renewables sector rather than nuclear.

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