Development Hinkley Point C Consent Order Application

Other Documents Doc Ref 8.14 October 2011

Sustainability Statement Any plans, drawings and materials submitted by EDF Energy as part of the Application to the Infrastructure Planning Commission are protected by copyright. You may only use this material (including taking copies of it) in order to (1) inspect those plans, drawings and materials at a more convenient time or place; or (2) to facilitate the exercise of a right to participate in the pre-examination or examination stages of the Application which is available under the Planning Act 2008 and related regulations. Further copies must not be taken without the prior permission of EDF Energy. edfenergy.com EDF Energy Ltd 40 Grosvenor Place London SW1X 7EN. Registered in England & Wales. Company registration number 2366852. © Copyright EDF Energy All rights reserved 2011. The official emblems of the London 2012 Games are © 2007 The London Organising Committee of the Olympic Games and Paralympic Games Ltd. All rights reserved.

CONTENTS 1. PROJECT OVERVIEW ...... 3 1.1 Introduction...... 3 1.2 Background and Context ...... 5 1.3 The Development Proposals ...... 18 2. SUSTAINABILITY STRATEGY ...... 31 2.2 Context...... 31 2.3 EDF Energy’s Corporate Sustainability Ambitions and Governance ...... 32 2.4 Project Vision and Development Objectives...... 33 2.5 Overview of the Sustainability Strategy ...... 35 2.6 Undertaking the Project Sustainability Appraisal ...... 38 2.7 Consultation Process on Matters of Sustainability...... 43 2.8 EDF Energy’s Strategic Response ...... 45 2.9 Explanation of Sustainability Commitments...... 57 3. SUSTAINABILITY STATEMENT ...... 66 3.2 Air Quality...... 66 3.3 Biodiversity and Ecosystems ...... 71 3.4 Climate Change...... 78 3.5 Communities: Population, Employment and Viability...... 88 3.6 Communities: Supporting Infrastructure ...... 94 3.7 Human Health and Well-Being ...... 98 3.8 Historic Environment ...... 103 3.9 Landscape...... 107 3.10 Soils, Geology and Land Use ...... 112 3.11 Water Quality and Resources...... 116 3.12 Flood Risk...... 121 3.13 Materials and Waste...... 125 3.14 Conclusions of the Sustainability Statement...... 130 4. SUSTAINABILITY APPRAISAL...... 133 4.2 Sustainability Appraisal Methodology...... 134 4.3 Sustainability Summary ...... 137 4.4 Air Quality...... 139 4.5 Biodiversity and Ecosystems ...... 143 4.6 Climate Change...... 155 4.7 Communities: Population, Employment and Viability...... 162 4.8 Communities: Supporting Infrastructure ...... 172 4.9 Human Health and Well-being...... 180 4.10 Historic Environment (Cultural Heritage in the AoS)...... 186 4.11 Landscape...... 192 4.12 Soils, Geology and Land Use ...... 199 4.13 Water Quality and Resources...... 208 4.14 Flood Risk...... 220

Sustainability Statement | October 2011 1

4.15 Materials and Waste...... 225 References...... 231 Glossary...... 234 ANNEX 1 – CO2 CALCULATIONS ...... I

TABLES Table 2.1: EDF Energy Project Level Objectives ...... 34 Table 2.2: Sustainability Themes and Objectives...... 38 Table 2.3: Sustainability Appraisal Scoring Criteria and Comparison with the Government’s Criteria...... 40 Table 2.4: Technical Documents...... 41 Table 2.5: Scoring Criteria for the Sustainability Opportunities Register...... 48 Table 2.6: Sustainability Measures Agreed through the Sustainability Opportunities Register ..51 Table 3.1: Summary of Air Quality Issues and Initiatives for Off-Site Associated Development & HPC Accommodation Campus...... 69 Table 3.2: Summary of Ecological Impacts and Identified Mitigation for Off-Site Associated Development & HPC Accommodation Campus ...... 76 Table 3.3: Summary of Issues and Measures to Reduce Greenhouse Gas Emissions for Off- Site Associated Development & HPC Accommodation Campus...... 86 Table 3.4: Summary of Impacts and Proposals Relating to Community Infrastructure for Off- Site Associated Development & HPC Accommodation Campus...... 97 Table 3.5: Key Issues Relating to Human Health and Well-being for Off-Site Associated Development & HPC Accommodation Campus ...... 102 Table 3.6: Implications for Cultural Heritage Objectives arising from the Off-Site Associated Development & HPC Accommodation Campus ...... 106 Table 3.7: Summary of Issues and Measures to Protect and Enhance Landscape for Off-Site Associated Development & HPC Accommodation Campus...... 110 Table 3.8: Implications for Objectives for Soil, Geology and Land Use from Off-Site Associated Development & HPC Accommodation Campus ...... 115 Table 3.9: Implications from Off-Site Associated Development & HPC Accommodation Campus on the Objectives for Water ...... 120 Table 3.10: Implications from Off-Site Associated Development & HPC Accommodation Campus on Objectives for Flood Risk ...... 124 Table 3.11: Considerations for Waste and Sustainable Materials objectives for Off-Site Associated Development & HPC Accommodation Campus...... 129 Table 4.1: Sustainability Appraisal Scoring Criteria and Comparison ...... 135

FIGURES Figure 1.1: General Site Location...... 18 Figure 1.2: HPC Development Site Boundary...... 19 Figure 1.3: Site Layout Plan...... 21 Figure 1.4: Locations of Off-Site Associated Developments ...... 23

2 Sustainability Statement | October 2011

Figure 2.1: Sustainability Strategy Roadmap ...... 37 Figure 2.2: Illustration of a Sustainability Opportunity being Appraised in the Register ...... 47 Figure 2.3: Waste Hierarchy...... 61

[Document Title] | October 2011 3

[This page is intentionally left blank]

4 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED

EXECUTIVE SUMMARY NNB Generation Company Limited (Company Number 06937084), part of EDF Energy, is the Company that will lead the new nuclear programme in the United Kingdom. For the purpose of this application for Development Consent, NNB Generation Company Limited is referred to as EDF Energy.

This Sustainability Statement has been prepared by EDF Energy to support the Development Consent Order (DCO) application for a new nuclear power station at Hinkley Point, called Hinkley Point C (HPC).

This Sustainability Statement follows a Sustainability Evaluation which was provided at Stage 2 consultation on the Preferred Proposals (2010). This reported the findings of a preliminary sustainability appraisal for the project, undertaken against the Government’s sustainability objectives for new nuclear power stations.

Achieving sustainable development concerns the balanced consideration of environmental, social and economic objectives – the three pillars of sustainability, measured and reported on as the triple bottom line. EDF Energy wishes to deliver this triple bottom line approach for the development of the HPC Project, whereby objectives under all three categories can be successfully accomplished.

The sustainability appraisal demonstrates that the proposals largely meet, and in a number of instances, exceed the Government’s objectives. Key findings of the appraisal include:

• The Government’s objective to minimise greenhouse gas emissions will be significantly exceeded by the project. The proposals for the long-term, safe, reliable generation of low carbon energy is considered to achieve this, and will be further promoted by EDF Energy’s proposals to manage emissions during the construction of the project. • The objective to create employment opportunities is significantly exceeded by the proposals for the HPC Project. The long-term sustainability of these jobs will be assisted by EDF Energy’s construction workforce development strategy, local business engagement strategy and education inspired strategy as well as by continued support for economic development in Somerset through the Low Carbon Delivery Team. • Objectives relating to human health and well-being will be exceeded, particularly during the operation of HPC. The employment opportunities created by the HPC Project, and enhanced further by EDF Energy’s community based initiatives, reflected in a range of strategies including a Health Action Plan, will play a large part in helping to meet these objectives. Building on the Sustainability Evaluation provided at Stage 2, this document provides further information on the sustainability initiatives proposed for the scheme which assist in meeting these objectives. Since Stage 2, EDF Energy has been considering a number of additional sustainability opportunities for the project. This Sustainability Statement explains these, and provides a description of the process EDF Energy has undertaken to consider and integrate these opportunities into the project.

Sustainability Statement | October 2011 1

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Accordingly, the Sustainability Statement consists of four parts:

1. Part 1: Project Overview This provides a general overview of the HPC Project, and sets out the purpose and objectives of this Sustainability Statement. It offers a description of the development proposals which constitute the Nationally Significant Infrastructure Project and the planning policies and drivers which are relevant to the project’s sustainability.

2. Part 2: Sustainability Strategy This part describes the approach EDF Energy has taken to consider and integrate sustainability into the project. It explains how EDF Energy has undertaken the project sustainability appraisal, and the process it has adopted for considering additional sustainability opportunities relevant to the project. This part also illustrates how sustainability will continue to be planned and implemented during later stages of the project through construction, operation and eventual decommissioning stages of temporary off-site associated development sites and HPC, and how the sustainability measures put forward for the application for Development Consent may be monitored and reported.

3. Part 3: Sustainability Statement This provides a description of how the sustainability opportunities which have been evaluated, developed and embedded into the project through EDF Energy’s sustainability strategy will successfully contribute to the sustainable development of the HPC Project. This is articulated in the context of a series of sustainability themes and objectives of relevance to the project.

4. Part 4: Sustainability Appraisal (Appendix) This technical appendix provides a more detailed appraisal of the HPC Project proposals against a sustainability framework. The sustainability framework was developed by EDF Energy to ensure that the proposals take account of the sustainability objectives against which they will be assessed by the IPC. It takes into account relevant national, regional and local planning policies and guidance, and it therefore demonstrates how sustainability policies and the sustainability objectives which inform those policies have been achieved.

In sum, the Sustainability Statement demonstrates how EDF Energy, through the development of the HPC Project, is demonstrating a triple bottom line approach by meeting social, economic and environmental objectives relevant to the project.

2 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

1. PROJECT OVERVIEW

1.1 Introduction

1.1.1 Part 1 , the ‘Project Overview’, explains the main purpose and objectives of the Sustainability Statement.

1.1.2 Part 1, Section 2 provides background and context. It establishes the importance of new nuclear power for sustainable development and the sustainability policy basis within which the project is being brought forward. A full policy analysis is provided in Part 4 .

1.1.3 Part 1, Section 3 provides a description of the development proposals.

a) Background 1.1.4 The Government’s White Paper on Nuclear Power (Ref. 1) and the UK Low Carbon Transition Plan (Ref. 2) clearly identifies a role for new nuclear generation as part of a low carbon energy mix, tackling the challenges of energy security and climate change. The Government’s Strategic Siting Assessment (SSA) identifies a series of sites which are ‘in principle’ suitable for new nuclear power stations, including Hinkley Point. This has been reaffirmed in the National Policy Statement for Nuclear Power Generation (EN-6) (hereafter ‘Nuclear NPS’) (Ref. 3) which has been approved by Parliament and was designated under the Planning Act 2008 by the Secretary of State on 29 July 2011 (Ref. 4). This Sustainability Statement is submitted in support of the application for Development Consent, comprising the development of a new nuclear power station, Hinkley Point C (HPC), at one of the sites identified in the Nuclear NPS.

1.1.5 Achieving sustainable development involves striking a balance between social, economic and environmental objectives of sustainability. EDF Energy wishes to deliver a triple bottom line approach for the development of the HPC Project, whereby objectives under all three categories can be successfully accomplished by the Project.

b) Purpose and Objectives 1.1.6 The primary purpose of this Sustainability Statement is to describe how sustainability has been incorporated in the design of the Project, and how principles of sustainable development would continue to be achieved during the construction, operation and eventual decommissioning of HPC. EDF Energy’s approach for demonstrating this is to appraise the project and report the findings of this appraisal against a series of sustainability themes and objectives which were identified by the Government during the Appraisal of Sustainability (AoS) of the revised draft Nuclear NPS (hereafter ‘AoS of the Nuclear NPS’) (Ref. 5).

1.1.7 This Sustainability Statement demonstrates how EDF Energy’s proposals for the HPC Project perform against a series of sustainability objectives identified by the Government as being relevant to the development of new nuclear power stations. The document fully considers the planning, regulatory and corporate drivers for sustainability that influence the development of the HPC Project.

Sustainability Statement | October 2011 3

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

1.1.8 The Government’s sustainability objectives span the social, economic and environmental objectives of sustainable development. They were developed during the preparation of the Nuclear NPS, when an AoS, incorporating Strategic Environmental Assessment (SA/SEA), was undertaken to identify potential strategically significant effects arising from implementation of the Nuclear NPS. In particular, they were adopted by the Government during the SSA process to identify, at a high level, the implications of developing a new nuclear power station at Hinkley Point. The AoS Revised Draft Site Report for Hinkley Point (October 2010) (hereafter AoS Site Report for Hinkley Point) (Ref. 6) identified potential strategically significant effects from the project, and recommended the possibility of mitigation and monitoring to minimise the impacts identified.

1.1.9 The AoS of the Nuclear NPS and the AoS Site Report for Hinkley Point were undertaken at a strategic level, with baseline data taken from published sources of information. In order to demonstrate conformity with sustainability objectives, the Government requires that applicants for new nuclear power stations provide more detailed information which can be used to determine the sustainability of the proposals at the project level. This principally includes the production of an Environmental Impact Assessment (EIA) to identify environmental impacts and demonstrate how they can be mitigated. This Sustainability Statement is informed by the findings of the EIA and other technical studies such as the Health Impact Assessment . It is also informed by the specific sustainability initiatives which EDF Energy has put forward for the project. This information has been considered and appraised to demonstrate how the Government’s sustainability objectives continue to be met, and where possible exceeded, at the project level.

c) Scope 1.1.10 The scope of this Sustainability Statement includes consideration of how EDF Energy has planned and is implementing sustainability, and in the context of the appraisal, how the project meets the sustainability objectives over short, medium and long-term. For the purpose of the appraisal, short-term relates to the period of construction, medium-term to the operational life of the facility, and longer term looks to the decommissioning phase and beyond. At this stage of the project the Sustainability Statement focuses most closely on the construction and operational phases, and highlights the steps taken to promote sustainability in the HPC Project design. In many respects there is less information relating to the decommissioning phase. This will be subject to a separate EIA prior to commencement of decommissioning, to take account of potential environmental impacts from decommissioning activities, and it may also be accompanied by a discretionary Sustainability Statement which sets out how such sustainability opportunities for that phase have been maximised. Where additional information is not yet available there will be less certainty about the sustainability of a particular outcome over the longer term. This is not to say that the proposals are unsustainable, but it does recognise that additional environmental studies must be considered at a later stage to assess this. Furthermore, a number of controls are in place to ensure that the decommissioning of HPC will be undertaken effectively. This includes the requirement for a Funded Decommissioning Programme agreed with the Secretary of State to ensure that funds for decommissioning and waste management are set aside over the operational lifetime of HPC.

4 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

1.1.11 The sustainability of nuclear power generation has already been considered by the Government in its White Paper on Nuclear Power and in the formulation of the Nuclear NPS. It is therefore not for this document to appraise it further. Likewise, the balance between the radiological impacts on human health of the UK European Pressurised Reactor (EPR) practice proposed for the HPC Project and its wider social, economic and other benefits has been considered by the Government through the process of Regulatory Justification under the Justification of Practices Involving Ionising Radiation Regulations 2004 (Ref. 7). This has led to the Justification Decision (Generation of Electricity by the EPR Nuclear Reactor) Regulations 2010 (Ref. 8), confirming that the practice is justified for the purpose of the Basic Safety Standards Directive 96/29/Euratom.

d) Project Overview 1.1.12 The development proposals for the HPC Project constitute a ‘Nationally Significant Infrastructure Project’ (NSIP) under the Planning Act 2008. The NSIP comprises the construction of the new nuclear power station, together with associated development. Associated development is defined as all development, on and off-site, associated with the HPC Project that is required to support the construction and operation of the power station.

• On-site associated development includes, for example, the infrastructure required to support the operation of the power station, such as offices, storage buildings, workshops and on-site campus accommodation. • Off-site associated development is development that is located away from the HPC Project development site. This includes the majority of the campus accommodation, transport infrastructure and other infrastructure necessary to facilitate construction of the main development. 1.1.13 A summary description of the NSIP proposals is provided in Section 1.3; however the reader is referred to the Planning Statement for a full description of the NSIP.

1.2 Background and Context

a) The Need for New Nuclear 1.2.1 Nuclear power is the most affordable, large-scale, low carbon generating technology currently available that can provide secure supplies of electricity for the UK. The UK has successfully utilised the technology for more than 50 years for electricity generation and which, at its peak in 1998, accounted for 26% of UK generation. However, as the nuclear power stations approach the end of their operating lives and are decommissioned, this share has declined to around 16% (Ref. 9).

1.2.2 The Government’s Nuclear NPS emphasises the UK’s need to develop new nuclear power stations significantly earlier than 2025 so as to displace CO 2 emissions and achieve the Government’s objective of an electricity supply that is almost entirely ‘decarbonised’ by 2050.

1.2.3 The Nuclear NPS considers the need for and siting of new nuclear power stations at a strategic level, identifying those sites that are in principle suitable for new nuclear power stations. These sites, including Hinkley Point, were identified through the Government’s SSA to be credible for deployment by 2025.

Sustainability Statement | October 2011 5

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

1.2.4 The UK Government has created a legally binding framework for reducing CO 2 emissions through to 2050 via ‘the Climate Change Act 2008’ (Ref. 10), with a specific duty on the Secretary of State to ensure that greenhouse gas emissions are reduced by at least 80% by that date. Delivery of this target will require early decarbonisation of electricity supplies, which will necessitate massive investment in three areas:

• Nuclear power. • Renewable energy. • Carbon Capture and Storage on fossil fuel generation.

1.2.5 The Committee on Climate Change’s ‘Renewable Energy Review’ (Ref. 11) reiterates this position, and reinforces the need for new nuclear power relative to other renewable energy technologies. As the most affordable low carbon option currently available, nuclear power has a major role to play in the UK’s future energy mix.

1.2.6 Furthermore, the Overarching National Policy Statement for Energy (EN-1) (hereafter ‘Overarching NPS’) (Ref. 12) clearly states that ageing of the UK’s stock of power stations together with tightening environmental legislation, particularly the Large Combustion Plant Directive (Ref. 13), will require at least 22GW of existing electricity generating capacity to be replaced in the coming years, particularly to 2020. Failure to achieve this will present a risk to security of supply.

1.2.7 EDF Energy believes a diverse mix is critical to addressing climate change, ensuring security of supply and providing affordable electricity. This includes all types of generation, as well as investment in the grid and in greater energy efficiency. It is evident that action must be taken now to invest in new nuclear power stations, otherwise carbon emissions from electricity generation are likely to rise.

1.2.8 It is on this fundamental basis that EDF Energy believes there is a pressing need for new nuclear development. The proposed nuclear power station at HPC would provide more than 6% of the UK’s electricity requirements from a very low carbon source. This would represent a significant contribution to the Government’s energy policy aims in its own right. EDF Energy also promotes development at Hinkley Point in recognition that the HPC Project fulfils a number of the SSA criteria, carried through into the Nuclear NPS:

• The HPC Project is adjacent to an existing nuclear facility. There has been a nuclear power station at Hinkley Point since 1965 and the community is familiar with the technology and the employment opportunities it offers. • Hinkley Point is connected to the National Grid transmission system, although upgrades and reinforcement will be required. • The provision of direct cooling using water from Bridgwater Bay is established and is the preferred option for new nuclear development. • Ground conditions are considered suitable for development. • Environmental impacts are considered to be less in comparison to alternative sites considered.

6 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

1.2.9 Further information on the need for the HPC Project, the SSA, and the consideration of alternatives is provided in the Planning Statement .

b) Nuclear Power and Sustainable Development i. Background 1.2.10 The purpose of this section is to set out the overall policy context under which the development will be taken forward and which will influence the sustainability of the project. A more detailed review of sustainability policy in terms of relevant national, regional and local planning policies is provided within the Sustainability Appraisal (Part 4 ). Further information can also found within the Environmental Statement, including specific detail of other regulation and legislation that governs the operation of HPC and nuclear power in general.

1.2.11 Many definitions of sustainable development exist, although the common objective for all involves striking a balance between social, economic and environmental objectives to meet the needs and aspirations of people today, without compromising the ability to meet those of future generations. This is captured within EDF Energy’s company-wide sustainability policy (Ref. 14), which states:

“Being a leader in sustainability means responding courageously and constructively to the world’s most critical social, environmental and economic challenges. It means providing for today without compromising life tomorrow, and ensuring we operate our business in a genuinely sustainable way now and into the future”.

1.2.12 In March 2005, the Government launched its strategy for sustainable development entitled ‘Securing the Future’ (Ref. 15). The strategy sets out a clear commitment of the UK Government’s to deliver sustainable development. It states the principles of sustainable development:

“Will be pursued in an integrated way through a sustainable, innovative and productive economy that delivers high levels of employment; and a just society that promotes social inclusion, sustainable communities and personal wellbeing. This will be done in ways that protect and enhance the physical and natural environment, and use resources and energy as efficiently as possible.”

1.2.13 Principles of sustainable development are central to the UK planning system. The proposals for the HPC Project are being taken forward in accordance with the Planning Act (2008) which introduced a new planning regime for NSIPs in England and Wales. However, beyond the legislative requirements, a wide range of policy drivers exist which establish the sustainability context for these proposals.

ii. A White Paper on Nuclear Power, January 2008 1.2.14 ‘Meeting the Energy Challenge: A White Paper on Nuclear Power’ (January 2008) established that new nuclear power stations should have a role to play in this country's future energy mix, alongside other low-carbon sources, and provides policy guidance on siting new nuclear power stations.

Sustainability Statement | October 2011 7

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

iii. White Paper on Managing Radioactive Waste Safely, June 2008 1.2.15 The White Paper on Managing Radioactive Waste Safely (Ref. 16) sets out the high level policy framework for managing higher activity radiological waste in the long-term through geological disposal coupled with safe and secure interim storage. Before new nuclear power stations are granted consent, the Government needs to be satisfied that effective arrangements will exist to manage this waste.

iv. The Climate Change Act, 2008 1.2.16 Climate Change is widely regarded as the most pressing challenge for sustainable development. The UK is the first country to have introduced a long-term legally binding framework to tackle the dangers of Climate Change. The Climate Change Act received Royal Assent on 26 November 2008, and provides a legal framework for ensuring that Government meets its commitments to tackle Climate Change. The Committee on Climate Change (CCC) was set up as an independent body as part of the Act.

1.2.17 The Act requires that emissions are reduced by at least 80% by 2050, compared to 1990 levels. The 2050 target was raised to 80% from 60% following recommendations set out by the CCC in a letter to Secretary of State in October 2008.

1.2.18 The Act also introduces legally binding carbon budgets, which will set a ceiling on the levels of greenhouse gases that can be emitted into the atmosphere. The CCC has published its Fourth Carbon Budget Report (Ref. 17), which establishes targets to decarbonise the energy supply sector.

v. Low Carbon Transition Plan (LCTP) – National Strategy for Climate Change and Energy, July 2009 1.2.19 The LCTP sets out the Government’s plan to decarbonise the UK up to 2020. The Plan, which follows the UK Climate Change Act (2008), utilises carbon budgeting and mechanisms such as the EU Emissions Trading Scheme (EU ETS) to deliver emission reductions of 18% on 2008 levels (equivalent to a 34% reduction on 1990 levels) by 2020. In order to facilitate this transition, the LCTP identifies a range of sectors within which transformation will occur. Transforming the power sector has been a key priority for UK Government, and a target has been set to derive approximately 40% of the UK’s electricity supply from low carbon sources by the end of the plan period. In order to achieve this, a diversity of technologies, including renewable, nuclear and carbon capture and storage (CCS) will be required to deliver low carbon transition of the power sector. Nuclear power is a key priority for the Government, both for its ability to decarbonise the power sector and to maintain a secure supply to the National Grid.

vi. Regulatory Justification 1.2.20 The application of EPR within the UK is a new practice, and as such the Government has undertaken a process of regulatory justification to meet European law. This requires that member states determine whether the benefits of a new practice involving ionising radiation outweigh its potential detriments to health.

1.2.21 The justification process, which included a comprehensive public consultation, was completed in November 2010, concluding that EPR practice is justified. The

8 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

justification decision has been carried into law through a Statutory Instrument (Justification Decision (Generation of Electricity by the EPR Nuclear Reactor) Regulations 2010 no 2844.

vii. Generic Design Assessment (GDA) 1.2.22 GDA of new nuclear reactor designs is being carried out by the Office for Nuclear Regulation (ONR), an Agency of the Health and Safety Executive, and the Environment Agency (EA), which for the purposes of this process have established a Joint Programme Office. Under the GDA process, ‘Requesting Parties’ request these nuclear regulators to assess the generic safety, security and environmental implications of new nuclear reactor designs, starting in advance of any application for a nuclear site licence and other permissions to build and operate a particular design of reactor on a particular site. This assessment would then provide a potential applicant with a clear indication that such a design would be licensable and permittable at a suitable site in the UK.

1.2.23 When the GDA process started, four new nuclear reactor designs were subject to assessment. There are currently two new nuclear reactor designs still undergoing assessment: the UK EPR designed by AREVA; and the AP1000 designed by Westinghouse. As noted above, these have each been subject to a justification decision that the practice is justified.

1.2.24 At the end of the GDA process, if the regulators consider a design to be acceptable for operation in the UK they will issue a Design Acceptance Confirmation (issued by the ONR) and Statement of Design Acceptability (issued by the EA). Assessment work completed under the GDA process will be taken into account during the next stage of regulatory approval, when a potential operator applies to the nuclear regulators for a site licence and other associated permits to allow them to install and operate a nuclear power station of that type on a particular site. EDF Energy has now made such applications for HPC.

1.2.25 GDA was scheduled to be completed in June 2011 with the issue of interim Design Acceptance Confirmations and interim Statements of Design Acceptability together with agreed resolution plans for the remaining generic GDA issues. The final Design Acceptance Confirmations and Statements of Design Acceptability would then have been issued when these agreed resolution plans had been completed. However following the Fukushima nuclear accident this programme has been delayed. At the Secretary of State's request Dr. Mike Weightman, HM Chief Nuclear Inspector, has undertaken an examination of the circumstances of the accident to see what lessons can be learned to enhance the safety of the UK nuclear industry. His interim report, published in May 2011 (Ref. 18) sets out recommendations for the industry, but concludes that consideration of the accident has revealed no significant weaknesses in the UK nuclear licensing regime. His final report is due to be completed in October 2011.

1.2.26 In the meantime, issue of interim Design Acceptance Confirmations and interim Statements of Design Acceptability has been delayed so that the Requesting Parties can include the implications of the Fukushima accident and the findings of the final Weightman Report within the issues remaining to be resolved within the GDA. The HSE cannot issue interim design acceptance confirmations (DAC) and the EA, interim statements of design acceptability (SoDA), for EPR until the final report is

Sustainability Statement | October 2011 9

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

published and the resolution plan for these issues has been agreed. This is expected towards the end of 2011. Final Design Acceptance Confirmations and Statements of Design Acceptability will follow when the agreed resolution plans have been satisfactorily completed.

1.2.27 EDF Energy has been actively involved in GDA and, through its parent EDF, is joint Requesting Party for UK EPR reactor design, and has submitted information to the Joint Programme Office in accordance with the information requirements for GDA. Such information is publically available via the websites of the HSE and the Requesting Parties.

viii. The Planning Act, 2008 1.2.28 The Planning Act (2008) introduced a new planning regime for NSIPs in England and Wales, including energy generation projects. The objective of the new regime is to improve the process for delivering major infrastructure projects, making the process both faster and fairer.

1.2.29 Under the Act, a new independent body, the Infrastructure Planning Commission (IPC), was established to consider applications for NSIPs. Under the Localism Bill which is currently before Parliament, it is proposed that the IPC would be abolished and all decisions on NSIP applications taken by the Secretary of State (SoS). The Government has announced that a new Major Infrastructure Planning Unit would be established as part of the Planning Inspectorate to carry out the examination of these applications. The Act also provides for Government to produce National Policy Statements (NPSs) setting out the national policy for NSIPs. The NPSs set the strategic policy framework in accordance with which the IPC will consider individual applications. It is a statutory requirement that NPSs be produced with the objective of contributing to the achievement of sustainable development.

1.2.30 Section 104 of the Planning Act 2008 also requires that the IPC, when making its decision in respect of an application for development consent, must decide the application in accordance with any relevant NPS, except in certain specified circumstances.

ix. Overarching National Policy Statement for Energy (EN-1), July 2011 1.2.31 The Overarching NPS sets out the overarching national policy for energy infrastructure. In combination with the Nuclear NPS, it provides the primary basis for decisions by the IPC on applications for nuclear power generation developments that fall within the scope of the NPSs. The suite of energy NPSs, including the nuclear and overarching NPS, have been approved by Parliament and were formally designated by the Secretary of State on 19 th July 2011.

1.2.32 Paragraph 4.1.5 of the Overarching NPS states that, although the energy NPSs provide the main policy context for the IPC, it should also refer to other matters that it thinks are both important and relevant to its decisions. This may, for example, include Development Plan Documents or other documents in the Local Development Framework. In the event of a conflict between these or any other documents and the NPS, the NPS prevails for purposes of IPC decision making given the national significance of the infrastructure.

10 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

1.2.33 Paragraph 4.1.5 also confirms that the energy NPSs have taken account of relevant Planning Policy Statements (PPSs) and Planning Policy Guidance Notes (PPGs). In a few specific paragraphs, the NPSs incorporate by reference a particular paragraph or passage of a PPS or PPG. Apart from those points and paragraphs incorporated by reference in this way, however, it is clear that the Overarching NPS and the Nuclear NPS are intended to be self-contained and to set out a comprehensive policy context for the assessment of relevant projects, such as Hinkley Point C.

1.2.34 The Overarching NPS covers the high-level objectives, policy and regulatory framework for new energy infrastructure consistent with sustainable development. It also identifies:

• the need and urgency for new energy infrastructure and social and economic benefits of meeting that need; • the key principles to be followed in the consideration and examination of applications; • the role of the Appraisal of Sustainability and its outcome in relation to the suite of energy NPSs; • policy on good design, climate change adaptation and other matters relevant to more than one technology specific NPS; and • the assessment on handling generic impacts which are not specific to particular technology.

x. National Policy Statement for Nuclear Power Generation (EN-6), July 2011 1.2.35 The Nuclear NPS sets out the Government’s assessment of the need for new nuclear power, including the identification of Hinkley Point as a potentially suitable site for the deployment of a new nuclear power station before the end of 2025. It also provides guidance for the IPC to assess the acceptability of proposals for new nuclear power stations and gives more specific consideration to the design of the facilities. Further, it sets out policy and guidance in relation to nuclear specific impacts and siting issues surrounding a range of environmental topics. Promoters of new nuclear power stations must consider the impacts and siting issues arising from these environmental considerations, and demonstrate that these issues have been fully evaluated and dealt with through mitigation, where necessary.

xi. Appraisal of Sustainability of the Revised Draft Nuclear NPS, October 2010

1.2.36 The AoS, incorporating Strategic Environmental Assessment, of the revised draft Nuclear NPS has been undertaken by the Government at a strategic level. It considers the effects of the implementing the policy at a national level and the sites to be assessed for their suitability for the deployment of new nuclear power stations by 2025.

xii. Appraisal of Sustainability Site Report for Hinkley Point C, October 2010

1.2.37 The AoS Site Report for Hinkley Point is a technical appendix to the AoS of the Nuclear NPS. The report considers the nomination of the site at Hinkley Point as a possible location for new nuclear power station(s). The purpose of this Appraisal of Sustainability Report is to assess environmental and sustainability impacts on the Hinkley Point site and surrounding area. This report also identifies the significance of those effects, and suggests possible ways of mitigation.

Sustainability Statement | October 2011 11

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

c) Other National Policies of Potential Relevance 1.2.38 As stated above, the Overarching NPS, when combined with the Nuclear NPS, provides the primary basis for decisions by the IPC on applications for nuclear power generation developments that fall within the scope of the NPSs.

1.2.39 Notwithstanding this, the IPC may consider other matters that are both important and relevant to its decision-making. Although the energy NPSs stipulate that they have already taken the PPSs and PPGs into account, the IPC may still consider the PPSs and PPGs to be important and relevant to its decision although, if there is a conflict between other policy documents and the NPS, the NPS prevails for the purposes of IPC decision making.

1.2.40 It is also noted that, on 25 July 2011, the Department for Communities and Local Government issued the consultation draft of the National Planning Policy Framework (NPPF) (Ref. 19) which is intended to replace PPSs, PPGs and some Circulars within a single consolidated document. The consultation period concludes on 17 October 2011 and it is expected that the final NPPF will be adopted in 2012. The draft NPPF sets out a presumption in favour of sustainable development, and the need to support economic growth through the planning system. NSIPs should still be determined by the framework established within the NPSs, which are part of the overall framework of planning policy (paragraph 6). Again, the IPC may consider the draft NPPF if it is important and relevant to its decision.

1.2.41 The Planning Statement explains the weight which EDF Energy considers should be attached to PPSs, PPGs and to the NPPF. In particular, it explains that the NPSs are intended to provide a comprehensive self-contained framework of national policy for the assessment of NSIPs and that only limited weight should be attached to policies of PPSs or PPGs or to the NPPF in these circumstances.

1.2.42 Notwithstanding their limited weight, however, the policies of the PPSs and PPGs are set out below and have been taken into account in the preparation of the DCO application documents, including the Sustainability Statement. Prior to the designation of the NPSs they provided a helpful policy guide as the DCO application was being prepared and their policies continue to be relied upon by some stakeholders. It is important to remember, however, that in the event of any conflict, it is the policies of the NPSs which prevail. A summary of the main policies contained in relevant PPSs and PPGs is set out below.

ii. Planning Policy Statement 1 (PPS 1): Delivering Sustainable Development, January 2005 1.2.43 PPS1 (Ref. 20) sets out the Government’s overarching planning policies on the delivery of sustainable development through the planning system. The Government’s objectives as expressed in PPS1 include enhancing the physical environment and optimising resource and energy use. PPS1 highlights the need to consider sustainable development throughout the process of regional, local and development planning. It places the onus on planning authorities to prepare policies within development plans to deliver the Government’s over-arching objectives.

12 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

iii. Planning Policy Statement: Planning and Climate Change - Supplement to Planning Policy Statement 1, December 2007 1.2.44 The supplement to PPS 1 (Ref. 21) sets out how planning should contribute to reducing emissions and stabilising climate change (mitigation) and take into account the unavoidable consequences (adaptation).

iv. Planning Policy Statement – Planning for a Low Carbon Future in a Changing Climate (Consultation Paper), March 2010 1.2.45 This consultation paper (Ref. 22) brings together the Planning and Climate Change supplement to PPS 1 (2007) with PPS 22 on Renewable Energy (2004) into a new draft PPS on Planning for a Low Carbon Future in a Changing Climate. The new PPS is intended to replace the 2007 and 2004 PPSs and it is proposed that it will become a consolidated supplement to PPS 1. It sets out a planning framework for securing progress against the UK’s targets to cut greenhouse emissions and use more renewable and low carbon energy, and to plan for inevitable climate change.

1.2.46 The consultation paper states that addressing climate change is the Government’s principal concern for sustainable development. Plan making and development management should fully support the transition to a low-carbon future in a changing climate and actively support the delivery of renewable and low carbon energy.

v. Other potentially relevant PPSs 1.2.47 A broad range of other PPSs assist to implement sustainable development within the UK. These include:

• Planning Policy Statement 4 (PPS 4): Planning for Sustainable Economic Growth, December 2009 (Ref. 23). • Planning Policy Statement 5 (PPS 5): Planning for the Historic Environment, March 2010 (Ref. 24). • Planning Policy Statement 7 (PPS 7): Sustainable Development in Rural Areas, August 2004 (Ref. 25). • Planning Policy Statement 9 (PPS 9): Biodiversity and Geological Conservation, August 2005 (Ref. 26). • Consultation Paper on a New Planning Policy Statement: Planning for a Natural and Healthy Environment, March 2010 (Ref. 27). • Planning Policy Statement 10 (PPS 10): Planning for Sustainable Waste Management, March 2011 (Ref. 28). • Planning Policy Guidance 13 (PPG 13): Transport, January 2011 (Ref. 29). • Planning Policy Guidance 17 (PPG 17): Planning for Open Space, Sport and Recreation, July 2002 (Ref. 30). • Planning Policy Statement 22 (PPS 22): Renewable Energy, August 2004 (Ref. 31). • Planning Policy Statement 23 (PPS 23): Planning and Pollution Control, November 2004 (Ref. 32).

Sustainability Statement | October 2011 13

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

• Planning Policy Statement 25 (PPS 25): Development and Flood Risk, March 2010 (Ref. 33). • Planning Policy Statement 25 Supplement: Development and Coastal Change, March 2010 (Ref. 34). d) Regional Planning Policy i. Background 1.2.48 The Government’s revocation of regional strategies was quashed in the High Court on 10 November 2010. However, on that same date the Government reiterated in a letter to Chief Planners, its intention to revoke regional strategies through the Localism Bill. This letter was also challenged but, on 7 February 2011, the High Court held that the Government's advice to local authorities that the proposed revocation of regional strategies was to be regarded as a material consideration in their planning development control decisions should stand. The decision of the High Court was upheld by the Court of Appeal on 27 May 2011. Therefore, the regional strategies remain in place but in the case of development control decisions it is for planning decision makers to decide on the weight to attach to the strategies (see Volume 1, Chapter 4 of the Environmental Statement for a full summary of the position regarding the status of regional planning policy).

ii. Regional Spatial Strategy 1.2.49 Regional planning policy for the South West of England is currently set out in Regional Planning Guidance 10 for the South West (2001 - 2016) (RPG10) (Ref. 35), which broadly seeks to encourage more sustainable patterns of development. Policy RE6 (Energy Generation and Use) is directed at energy generation and use, supporting the target reduction in carbon emissions set by the Government in 1997 for the period to 2010.

1.2.50 The Draft Revised Regional Spatial Strategy (RSS) for the South West (2006-2026) (Ref. 36) was published by the South West Regional Assembly in 2006. In 2008 the Secretary of State published proposed changes to the draft RSS for further consultation. If adopted the RSS would replace RPG 10.

1.2.51 Policy SD 1 (The Ecological Footprint) supports, amongst other things, the building of a low carbon economy, and meeting national and regional targets relating to renewable energy. It states that the region’s Ecological Footprint will be stabilised and then reduced by:

• Achieving development that respects environmental limits. • Wise use of natural resources and reducing the consumption of key resources such as energy, water and minerals. • Building a sustainable, low carbon and low resource consuming economy which can be secured within environmental limits to bring prosperity and well-being to all parts of the region. • Encouraging sustainable construction and design as the norm in all future development and when opportunities arise, improving the region’s existing building stock in line with current best practice.

14 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

• Minimising the need to travel and securing a shift towards more sustainable modes of travel by effective planning of future development, better alignment of jobs, homes and services, improved public transport and a strong demand management regime applied in the region’s Strategically Significant Cities and Towns. • Meeting national and regional targets relating to renewable energy, resource consumption/extraction and waste production/recycling.

iii. Somerset and Exmoor National Park Joint Structure Plan Review 1991-2001 (2000) (Policies saved from 27th September 2007) 1.2.52 The Structure Plan (Ref. 37) provides the strategic base for all land use planning in the combined area covered by Somerset and the Exmoor National Park for the period up to 2011.

1.2.53 Policy STR1 (Sustainable Development) states that development in Somerset and the Exmoor National Park should:

• be of high quality, good design and reflect local distinctiveness; • develop a pattern of land use and transport which minimises the length of journeys and the need to travel and maximises the potential for the use of public transport; • cycling and walking; • minimise the use of non-renewable resources; • conserve biodiversity and environmental assets, particularly nationally and internationally designated areas; • ensure equal access to housing, employment and services; • give priority to the continued use of previously developed land and buildings; and • enable access for people with disabilities.

iv. Other Regional Policy Documents of Potential Relevance 1.2.54 Other policy documents and information at the regional level that are potentially relevant to the assessment of the sustainability of the proposals include:

• The Regional Economic Strategy for The South West 2006 – 2015 (2006) (Ref. 38). • South West Biodiversity Implementation Plan (2004) (Ref. 39). • Climate Change Action Plan (2008-2010) South West Councils (2008) (Ref. 40). • Draft North Devon and Somerset Shoreline Management Plan 2- (2009) (Ref. 41). • River Basin Management Plan: South West River Basin District (2009) (Ref. 42). • Checklist South West – South West Sustainability Checklist (2006) (Ref. 43). • The South West Regional Waste Strategy 2004-2020 (2004) (Ref. 44). • The Way Ahead: Delivering Sustainable Communities in the South West – South West Councils (2005) (Ref. 45).

Sustainability Statement | October 2011 15

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

• Sedgemoor Economic Development Strategy (2009) (Ref. 46). • Somerset Local Area Agreement (LAA) 2008 – 2011(2010) (Ref. 47). • Somerset Future Transport Plan 2011-2026 (2011) (Ref. 48). • The Sustainable Community Strategy for Somerset 2008-2026 (2009) (Ref. 49). • Strategy for the Severn Estuary (2001) (Ref. 50). • Quantock Hills AONB Management Plan 2009-2014 (2009) (Ref. 51). • South West River Basin District Management Plan (2009) (Ref. 52). • Managing Flood Risk on the Severn Estuary: Consultation (2011) (Ref. 53).

v. Local Planning Policy and Guidance 1.2.55 As described in Section 1.3 , the HPC development site is located within the administrative area of West Somerset Council (WSC), along with one of the off-site associated development sites. The other off-site associated development sites are located within the administrative area of Sedgemoor District Council (SDC).

1.2.56 As stated above, however, the Planning Act 2008 provides a different regime for NSIPs and it is the Overarching NPS, when combined with the Nuclear NPS, which provides the primary basis for decisions by the IPC on applications for nuclear power generation developments that fall within the scope of the NPSs.

1.2.57 Notwithstanding this, the IPC may consider other matters that are both important and relevant to its decision-making. This could include Development Plan documents or other documents in the LDF, although, if there is a conflict between these and the NPS, the NPS prevails for the purposes of IPC decision making.

1.2.58 Further, the Act provides that the IPC must, in making its decision on an application, have regard to any Local Impact Report (LIR) prepared by relevant local authorities. It is anticipated that the LIRs will rely in part on local policy to provide a context for their assessment. On this basis, regard has been given to the current and emerging local policy documents relevant to the HPC Project which are likely to inform the LIRs prepared by the relevant local authorities. The adopted and emerging local planning policies and guidance also provide useful indicators and objectives for sustainable development, and consequently have been considered within the Appraisal. Documents reviewed include:

• West Somerset Local Plan (April 2006) (with relevant policies ‘saved’ from 17 April 2009) (Ref. 54). • West Somerset District Local Development Framework (LDF) Core Strategy (Options Paper) (January 2010) (Ref. 55). • Sedgemoor District Council Local Plan 1991 – 2011 (2004) (Policies ‘saved’ from 27 September 2007) (Ref. 56). • Sedgemoor Local Development Framework (LDF) Core Strategy (Proposed Submission) (September 2010) (Ref. 57).

• Hinkley Point C Project Supplementary Planning Document (Consultation Draft) (February 2011) (Ref. 58).

16 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

1.2.59 Additionally, the following guidance documents which include relevant objectives and targets have also been considered:

• Bridgwater Challenge: Bridgwater Vision (2009) (referred to as Bridgwater Vision) (Ref. 59). • North East Bridgwater Design Principles Document (2009) (Ref. 60). • Sustainable Community Strategy for Sedgemoor 2009-2026 (2009) (Ref. 61).

1.2.60 A full review of these documents to identify the policy objectives can be found within the Sustainability Appraisal in Part 4 .

Sustainability Statement | October 2011 17

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

1.3 The Development Proposals

a) The HPC Development Site and On-site Associated Development i. Background 1.3.1 Hinkley Point is located on the West Somerset coast, 25km to the east of Minehead and 12km to the north-west of Bridgwater. The general location of the Hinkley Point C development site is shown in Figure 1.1. The Site is bounded to the north by Bridgwater Bay and to the west by land in agricultural production. The village of Shurton lies to the south. The permanent development site would cover approximately 67.5 hectares (ha). Immediately to the east, the land is occupied by Hinkley Point A (HPA) and Hinkley Point B (HPB), which form the existing Hinkley Point Power Station Complex. HPA operated between 1965 and 2000 and is currently undergoing decommissioning by Magnox South Limited as nuclear site licensee under agreement with the Nuclear Decommissioning Authority (NDA). Hinkley Point B, owned by EDF Energy, has operated since 1976 and is scheduled to continue generating until at least 2016. The HPC development site boundary is shown in Figure 1.2.

Figure 1.1: General Site Location

18 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Figure 1.2: HPC Development Site Boundary

ii. Preliminary Works 1.3.2 The development proposals include the various associated developments which are needed to facilitate the construction of HPC. A full description of these is presented within Volume 1 , Chapter 2 of the Environmental Statement ; a descriptive summary is provided below.

Site Preparation Works 1.3.3 To accommodate the land based elements of the HPC Project, the site would require levelling and the creation of several platforms. This would include the creation of a main platform at 14m above ordnance datum (AOD), and an ancillary platform set at 20m AOD. The proposed development involves site clearance (including fencing, vegetation removal, demolition of existing structures, and creation of alternative footpaths); earthworks (including soil stripping and storage, site levelling, spoil screening/storage for re-use on-site); provision of earth retaining structures; commencement of deep excavations; provision and relocation of drainage infrastructure (including culverts, outfalls, balancing ponds); the provision and operation of plant and machinery (including concrete batching); site establishment works (including layover facilities, car parks, haulage roads, site access points and roundabouts, and laying replacement and/or diversion apparatus); and other associated works. This component of the project will commence in advance of the

Sustainability Statement | October 2011 19

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

main works, and has been subject to a separate planning application submitted to West Somerset Council (Ref. 3/32/10/037).

Temporary Jetty 1.3.4 A temporary jetty extending approximately 500m into Bridgwater Bay is proposed in the western part of the Development Sites. The temporary jetty will enable the delivery of at least 80% of the cement, sand, aggregates and cement replacement products required for the construction of HPC by sea. It may also be possible for the jetty to receive other materials such as pre-fabricated units. By transferring this freight from the roads to the water, there will be a significant reduction in HGV traffic during the construction of HPC. The temporary jetty will be removed when it is no longer required, following commissioning of the second reactor unit.

iii. Main Power Station Buildings 1.3.5 The proposed HPC nuclear power station design would comprise two UK EPR reactor units and associated buildings. The UK EPR reactor unit is a development of existing technology designed with a 60 year lifespan. The design makes more efficient use of fuel than current reactors, thus reducing the quantities of spent fuel requiring storage and disposal. In each unit, steam produced in steam generators by heat transferred from the reactor, powers a single large turbine. This is directly connected to an electrical generator capable of producing and exporting around 1,630MW of electricity. Seawater is used to condense the steam back to water before it is returned to the steam generators. Electricity from the generator is stepped-up to high voltage (400kV) via transformers before being exported on EDF Energy overhead lines to the national grid 400kV substation which connects the generation output to the National Grid transmission system

1.3.6 HPC would comprise a range of buildings, above ground, seabed and sub-surface structures and related facilities including:

• Two Nuclear Islands each comprising a UK EPR reactor and associated buildings. • Two Conventional Islands, each including a Turbine Hall, located adjacent to the Nuclear Islands. • A Cooling Water Pumphouse for each UK EPR reactor unit with related infrastructure. • Sea bed cooling water intakes and outfall structures together with tunnels connecting these to the cooling water pumphouses and turbine halls. • Fuel and waste management facilities, transmission infrastructure including the National Grid 400kV substation, staff facilities, administration, storage facilities and other plant. • A Public Information Centre (PIC) to provide education and public information facilities. • A Sea Wall incorporating a public footpath. • Access and parking facilities for workers, visitors and deliveries for the main power station and the National Grid 400kV substation.

1.3.7 The general site layout is shown in Figure 1.3.

20 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Figure 1.3: Site Layout Plan

Sea Wall 1.3.8 A new sea wall would be constructed which would extend east and west of the new power station (and would link to the sea defences of the existing Hinkley Point Power Station Complex). The sea wall’s primary purpose is to protect the coastline from erosion. The sea wall would be a simple concrete structure, approximately 760m in length and 13.50m AOD in height. It would be constructed to allow for an increase in height should this be required in the future if flood risk increases as a result of climate change. The design life of the sea wall will be 100 years to allow for 60 years of power station operation and 40 years of subsequent decommissioning.

Cooling Water Infrastructure 1.3.9 The new power station would require two offshore intakes and one outfall structure for water to condense steam exiting from the turbine. The system would include a

Sustainability Statement | October 2011 21

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

fish recovery and return system. The locations of the water intakes and outfall would be positioned to prevent recirculation of warm water.

b) Off-Site Associated Development i. Background 1.3.10 As part of the NSIP, EDF Energy proposes various other developments located away from the HPC Development Site. This off-site associated development is required to support the delivery of the HPC Project and to mitigate and manage potential impacts associated with its construction. The proposed off-site associated developments comprise:

• Accommodation campuses for up to 1,000 construction workers across two sites. These are in addition to the accommodation campus for 510 workers proposed within the HPC development site. • Park and ride facilities for up to 2,400 car parking spaces, 49 mini-bus parking spaces, 125 motorcycle spaces, 125 bicycle spaces and 51 bus parking bays, with ancillary facilities, across four sites. • Freight management facilities for up to 140 heavy goods vehicles (HGV) with ancillary facilities, across two sites. • An induction centre for staff in connection with the HPC construction phase. • A consolidation facility for postal/courier deliveries. • A bypass around the west of Cannington. • Refurbishment and extension of the existing Combwich Wharf and an associated freight laydown facility for the storage of Abnormal Indivisible Loads (AILs) and other construction goods being delivered via Combwich Wharf before they are transferred to the HPC development site. A new Goods Wharf access road is proposed to link Combwich Wharf with the existing Combwich Wharf access road which would be altered.

1.3.11 Figure 1.4 shows the location of the off-site associated developments in relation to HPC. A further summary of this development is provided below. For fuller descriptions of these off-site associated developments please refer to the Environmental Statement for details.

22 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Figure 1.4: Locations of Off-Site Associated Developments

1.3.12 The associated developments have been subject to extensive consultation and are proposed to meet the needs of the construction project, whilst at the same time reducing the impacts on the local communities and the environment as far as reasonably possible. The associated developments are proposed in order to achieve the following objectives:

• To manage the flow of personnel and freight (including goods delivered to Combwich Wharf) to the HPC Project. • To provide freight management facilities to regulate the flow of HGVs through Bridgwater and Cannington, particularly at peak times. • To provide accommodation for the non-home based workforce (in addition to accommodation that has been identified as available within the local community and surrounding area). • To minimise travel to work distances. • To provide a bypass around Cannington to lessen the impact of vehicle movements through the centre of the village.

Hinkley Point C On-site Accommodation Campus 1.3.13 The proposed HPC on-site accommodation campus consists of:

• an accommodation campus including living space for 510 occupants within 15 accommodation buildings; two 5-a-side football pitches and associated toilet facilities; 319 car parking spaces and motorcycle and bicycle parking spaces; an amenity building providing amongst other things administration, canteen, laundry, gymnasium and recreational facilities; bus drop-off point; and internal access roads;

Sustainability Statement | October 2011 23

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

• access off the C182 (Wick Moor Drove); • landscaping within the site, including tree planting around the site perimeter; and • other ancillary development including signage, fencing, lighting, CCTV and utilities.

1.3.14 This proposed development would be used by EDF Energy during the construction phase of the HPC power station to accommodate non-home-based workers for approximately six and a half years.

1.3.15 It is anticipated that construction would commence in Quarter 2 2013 for approximately 15 months. It is estimated that the accommodation campus would be operated by EDF Energy between Quarter 3 2014 and Quarter 1 2021, after which its post-operational phase would commence.

1.3.16 It has been assumed that infrastructure would be removed and the land would be restored as part of the wider HPC post-operational strategy.

1.3.17 For a full description of the proposed development, including the construction, operation and post-operational phases, refer to Volume 2 of the Environmental Statement .

Bridgwater A Accommodation Campus 1.3.18 The proposed Bridgwater A accommodation campus consists of:

• an accommodation campus, including living space for 850 occupants within 25 accommodation buildings; three football pitches (one full size and two 5-a-side pitches) and associated changing facilities; 543 car parking spaces and bus, motorcycle and bicycle parking spaces; an amenity building providing amongst other things administration, canteen, laundry, gymnasium and recreational facilities, and internal access roads; • access off the A39 (Bath Road), changes to the road markings along the A39 (Bath Road) and the stopping up of Fredrick Road; • a new drainage rhyne; • landscaping within the site, including tree planting around the perimeter of the site; and • other ancillary development, including signage, fencing, lighting, CCTV and utilities.

1.3.19 This proposed development would be used by EDF Energy during the construction phase of the HPC power station to accommodate non-home-based workers for approximately six and a half years.

1.3.20 It is anticipated that construction would commence in Quarter 1 2013. The proposed development is likely to be constructed in a phased basis. First occupation is expected to be in Quarter 3 2014 and use of the proposed development is anticipated to cease in Quarter 1 2021, after which its post-operational phase would commence. It has been assumed that some infrastructure would be removed and some retained, some of which would not be confirmed until closer to the time that

24 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

EDF Energy would cease use of the site. See the Post-Operational Strategy, appended to the Planning Statement , for further details.

1.3.21 For a full description of the proposed development, including the construction, operation and post-operational phases, refer to Volume 3 of the Environmental Statement.

Bridgwater C Accommodation Campus 1.3.22 The Bridgwater C accommodation campus consists of:

• an accommodation campus, including living space for 150 occupants within four accommodation buildings; an all weather 5-a-side football pitch; 66 car parking spaces, and motorcycle and bicycle spaces; a temporary canteen building for a period of approximately six months until the facilities at Bridgwater A accommodation campus become operational, and internal access roads; • alterations to the existing gyratory on the A39 (Bath Road), including provision of two bus shelters and changes to the road markings; • access road off College Way; • landscaping within the site, including tree planting along College Way; and • other ancillary development, including signage, fencing, lighting, CCTV and utilities.

1.3.23 This proposed development would be used by EDF Energy during the construction phase of the HPC power station to accommodate non-home-based workers for approximately seven years.

1.3.24 It is anticipated that construction of the proposed development would commence in Quarter 1 2013 for approximately 12 months. It is estimated that the accommodation campus would be operated by EDF Energy between Quarter 1 2014 and Quarter 1 2021, after which the facility would no longer be required by EDF Energy. The accommodation campus would be retained and used in connection with Bridgwater College as student accommodation or other alternative educational uses.

1.3.25 For a full description of the proposed development, including the construction, operation and post-operational phases, refer to Volume 4 of the Environmental Statement .

Cannington Bypass 1.3.26 The proposed Cannington bypass would link the existing A39 southern bypass to the C182 (Rodway). The proposed development would consist of:

• a 1.5km single carriageway road, with a design speed of 40 miles per hour (mph) (70 kilometres per hour (kmph)), 7.3m wide with a minimum 2.5m wide verge on the west side and a 3.5m wide cycle/footway on the eastern side; • a new roundabout to join the C182 (Rodway) and alterations to the alignment of the existing side road and accesses including the C182 (Rodway0, Chad’s Hill, Withiel Drive and Sandy Lane; and field accesses;

Sustainability Statement | October 2011 25

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

• environmental mitigation, including earth bunds, screen planting and an ecological underpass; • drainage including culverts and balancing ponds; and • associated signage, crossings, services and lighting.

1.3.27 It is anticipated that construction of the proposed development would commence in Quarter 1 2013 for approximately 21 months and would be available from Quarter 4 2014 to support the construction and operation of the Hinkley Point C (HPC) power station. Following completion of the construction phase it would be opened for public use and adopted by the Highway Authority (Somerset County Council (SCC).

1.3.28 For a full description of the proposed development, including the construction, operation and post-operational phases, refer to Volume 5 of the Environmental Statement .

Cannington Park and Ride 1.3.29 The proposed Cannington park and ride facilities consist of:

• a park and ride facility, including two separate parking areas for the parking of workforce (132 car spaces) and visitors (120 mini-bus/van spaces) including a bus waiting area and some ancillary structures including bus shelters and security/welfare facilities; • a new access onto the A39 via a new left turn entry and exit, junction; • widening of the A39 and provision of footway between site access and A39 Main Road eastern roundabout; • landscaping, screen planting and the provision of earth bunds for visual mitigation and spoil storage; • surface water drainage infrastructure (including detention pond); and • other ancillary development, including signage, fencing, lighting, CCTV and utilities.

1.3.30 The proposed development would be used by EDF Energy during the construction phase of HPC to transport and manage the flow of some of the construction workforce to and from the HPC construction site for approximately eight years. The proposed development would mainly attract local traffic from workers living close by to Cannington and smaller settlements to the south and west of Cannington. It would also attract visitor traffic from further afield. Workers living within Cannington itself could also walk or cycle to the site.

1.3.31 It is anticipated that construction of the proposed development would commence in Quarter 1 2013 for approximately 11 months. It is anticipated that the park and ride would be operated by EDF Energy between Quarter 4 2013 and Quarter 4 2021. Once the proposed development is no longer required to support the construction of the Hinkley Point C power station, the proposed development site would be restored to its existing agricultural use.

26 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

1.3.32 For a full description of the proposed development, including the construction, operation and post-operational phases, refer to Volume 6 of the Environmental Statement.

Combwich 1.3.33 The proposed development at Combwich would include the refurbishment and extension of the existing Combwich Wharf and an associated freight laydown facility for the storage of AILs and other bulky construction goods being delivered via Combwich Wharf before they are transferred to the HPC construction site. A new Goods Wharf access road is proposed to link Combwich Wharf with the existing EDF Energy owned Combwich Wharf access road. Amendments are also proposed to the existing Combwich Wharf access road including at its junction with the C182.

1.3.34 The proposed development would comprise:

• refurbishment and extension of Combwich Wharf to accommodate deliveries by water of Abnormal Indivisible Loads (AILs) and bulky construction goods associated with the construction of Hinkley Point C (HPC) Power Station; • provision of a new freight laydown facility in an area to the south-east of Combwich village for the handling and storage of AILs and construction materials before they are transported to the main HPC site; • improvements to the existing EDF Energy owned Combwich Wharf access road; and • minor alterations to the junction of the C182 at the junction of Combwich Wharf access road.

1.3.35 It is anticipated that construction of Combwich Wharf would commence in Quarter 1 2013 for approximately 12 months. It would be operated by EDF Energy from Quarter 1 2014 to Quarter 3 2020.

1.3.36 Construction of the Combwich freight laydown facility is anticipated to commence in Quarter 1 2014 for approximately 12 months. It would be operated by EDF Energy from Quarter 1 2015 to Quarter 3 2021.

1.3.37 Once construction of HPC has been completed, it is proposed that Combwich Wharf would be retained in its refurbished state for the duration of the operational life of HPC to support its operation. The freight laydown facility would be entirely removed and the land restored to its original use (agricultural land). The improvements proposed to the Combwich Wharf access road and at its junction with the C182 would also remain once the construction of HPC has been completed.

1.3.38 For a full description of the proposed development, including the construction, operation and post-operational phases, refer to Volume 7 of the Environmental Statement .

M5, Junction 23 Park and Ride, Freight Management and Courier Consolidation Facilities and Induction Centre 1.3.39 The proposed development at Junction 23 of the M5 consists of:

Sustainability Statement | October 2011 27

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

• a park and ride facility, including hardstanding for vehicle parking for 1,300 cars, minibuses and vans, and associated motorcycle, bicycle and bus parking spaces; bus terminus; and ancillary structures, including bus shelters and amenity/welfare and security buildings; • a freight management facility, including hardstanding for vehicle parking for 85 heavy goods vehicles (HGVs) and other vehicles; a freight checking area; associated car parking and ancillary structures, including an administration/amenity and security building; • a consolidation facility for postal/courier deliveries comprising a consolidation facility building with associated parking area; • a worker induction centre comprising induction space and welfare facilities; and 120 car parking spaces and motorcycle and bicycle spaces; • new site access and site access improvements comprising realignment of the highway arrangements off the Dunball roundabout; • internal roads and a roundabout; • works to River Parrett flood defences; • landscaping, screen planting, ecological mitigation area and the provision of earth bunds for visual mitigation and spoil storage; • surface water drainage infrastructure (including detention pond); and • other ancillary development, including fencing, lighting, CCTV, signage and utilities.

1.3.40 The proposed development would be used by EDF Energy for approximately six and a half years. It is anticipated that construction of the proposed development would commence in Quarter 3 2013 for approximately 12 months. It is estimated that the proposed development would be fully operational by EDF Energy between Quarter 3 2014 and Quarter 4 2020.

1.3.41 Once construction of the Hinkley Point C (HPC) power station is complete EDF Energy would no longer require the proposed development. At this stage, the site could be restored to its current agricultural use. Additional landscaping, drainage and ecological mitigation habitats associated with EDF Energy’s use of the site would however be left in place. Alternatively, the site could be retained in part to allow for future use by third parties, such as continued use for similar commercial purposes (for example, park and ride and/or freight management uses by parties other than EDF Energy); or the site could be redeveloped for employment generating uses (for example, business uses (Use Class B1), general industrial uses (Use Class B2) and/or storage/distribution uses (Use Class B8).

1.3.42 For a full description of the proposed development, including the construction, operation and post-operational phases, refer to Volume 8 of the Environmental Statement .

M5, Junction 24 Park and Ride and Freight Management Facilities and Temporary Postal/Courier Consolidation Facility and Induction Centre

1.3.43 The proposed development at Junction 24 would provide park and ride and freight management facilities for workers of the HPC construction phase, and temporary

28 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

postal/courier consolidation facilities and an induction centre until those facilities at Junction 23 become available.

1.3.44 Given the existing infrastructure within the site, the site would be available to use earlier in the construction phase of the Hinkley Point C (HPC) Project and before others associated development sites become available. Therefore, until the Junction 23 associated development site becomes fully operational, the Junction 24 site would accommodate additional facilities for the HPC construction workforce and HPC delivery vehicles. The proposed development therefore consists of:

• a park and ride facility, including parking within existing warehouse building and externally for 1,300 cars, minibuses and vans, reducing to 698 spaces once the facilities at Junction 23 become available, and associated motorcycle, bicycle and bus parking spaces; bus terminus; and ancillary structures, including bus shelters and amenity/welfare and security areas/buildings; • a freight management facility, including an area for vehicle parking for 140 heavy goods vehicles (HGVs), reducing to 55 spaces once the facilities at Junction 23 become available; a freight checking area; and ancillary structures, including administration/amenity and security areas/buildings; • a temporary consolidation facility for postal/courier deliveries comprising a consolidation facility building with associated parking area, until the facilities at Junction 23 become available; • a temporary worker induction centre located within existing tray wash and vehicle maintenance building comprising induction space and welfare facilities; and 75 car parking spaces and motorcycle and bicycle spaces, until the facilities at Junction 23 become available; • internal roads; • landscaping; and • other ancillary development, including fencing, lighting, CCTV, signage and utilities.

1.3.45 The proposed development would be used by EDF Energy for approximately nine years. It is anticipated that construction of the proposed development would commence in Quarter 1 2013. It is estimated that the proposed development would be fully operational by Quarter 3 2013 with the facilities being introduced in phases from Quarter 1 2013 onwards. EDF Energy would operate the site until Quarter 3 2022.

1.3.46 For a full description of the proposed development, including the construction, operation and post-operational phases, refer to Volume 9 of the Environmental Statement .

Williton Park and Ride site 1.3.47 The proposed Williton park and ride facilities consist of:

1.3.48 The proposed development would comprise:

• a park and ride facility, including a 160 space car park for workers’ vehicles, a bus waiting area and some ancillary structures including bus shelters and

Sustainability Statement | October 2011 29

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

security/welfare facilities, accessed from the existing lorry park access from the B3190; • landscaping and supplementary screen planting for visual mitigation; and • other ancillary development, including signage, fencing, lighting, CCTV and utilities.

1.3.49 The proposed facility would provide car parking for the workforce of the HPC construction site, and motorcycle, bicycle and bus parking spaces. The site forms part of a wider existing lorry park, which would continue to operate (on a reduced area) whilst EDF Energy occupies part of the site.

1.3.50 It is anticipated that construction of the proposed development would commence in Quarter 1 2013 for approximately nine months. It is anticipated that the park and ride would be operated by EDF Energy between Quarter 4 2013 and Quarter 4 2020. Once the proposed development is no longer required to support the construction of the Hinkley Point C power station, any temporary built works carried out in relation to the operation of the site as a park and ride facility would be removed and the site would be restored to its existing use as a lorry park, depot and storage area.

1.3.51 For a full description of the proposed development, including the construction, operation and post-operational phases, refer to Volume 10 of the Environmental Statement .

Associated Highway Improvements 1.3.52 In addition to the off-site associated development outlined above. The NSIP includes 11 related highways improvements, as follows:

• A38 Bristol Road/The Drove Junction. • A39 Broadway/A38 Taunton Road Junction. • A38 Bristol Road/Wylds Road Junction. • Wylds Road/The Drove Junction. • A39 New Road/B3339 Sandford Hill Roundabout. • M5 Junction 23 Roundabout. • Washford Cross Roundabout. • Claylands Corner Junction. • C182 Farringdon Hill Lane, Horse Crossing. • Cannington Traffic Calming Measures. • Huntworth Roundabout.

30 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

2. SUSTAINABILITY STRATEGY

2.1.1 This part of the Sustainability Statement describes the approach EDF Energy has taken to evaluate sustainability opportunities for the project. It explains how it has instigated the most appropriate portfolio of measures for implementation in the project’s design, construction and operation to meet its planning and regulatory requirements, corporate aspirations and stakeholder expectations, and in doing so to deliver sustainability against the triple bottom line.

2.1.2 This part considers the following:

• The main terms of reference of the sustainability strategy. • EDF Energy’s corporate governance structure for sustainability and how this informs the strategy for the HPC Project. • The sustainability objectives of relevance to the project. • The sustainability appraisal process. • The consultation exercise and how it has informed the sustainability of the proposals. • The process EDF Energy has taken to consider ‘sustainability opportunities’ for the project. • An explanation of the sustainability commitments. • The principal mechanisms that would be used embedded these commitments in the project.

2.2 Context

2.2.1 The sustainability of nuclear new build is founded on its attributes of low carbon emissions, secure electricity supply, and stable, affordable prices once nuclear stations are constructed. These are very material benefits in sustainability terms, towards which the HPC Project would contribute significantly. However, at a national scale the sustainability benefits of nuclear new build will not be realised unless such projects are economically viable and can be delivered without unnecessary delay. In that regard, the sustainability strategy for the project is informed not only by the ability to achieve better social, economic and environmental outcomes at the regional and local scale, but also by constraints such as viability, feasibility and implications for the timescale on which the project starts to deliver electricity. These factors may lead to significant dis-benefits at the national scale if they bring the economic value of the project into doubt or cause significant delay to the project programme.

2.2.2 The sustainability strategy has been developed with consideration to the following terms of reference:

• To develop measures which are cost effective and deliver genuine sustainability benefit. • To develop measures which take account of the relevant planning, regulatory and corporate drivers which influence the Project.

Sustainability Statement | October 2011 31

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

• To develop measures which present no significant impacts on the Project’s programme and its deliverability. • To ensure that where possible, measures have associated Key Performance Indicators (KPIs) which are transparent, and are able to be monitored and reviewed by EDF Energy. • To use sustainable design codes and standards that are credible, effective, and can be externally verified. • To ensure a management system is implemented that will enable additional measures to be developed at a later stage, as and when possible. • To ensure that progress against these measures can be reported externally, in accordance with EDF Energy’s quality assurance procedures.

2.3 EDF Energy’s Corporate Sustainability Ambitions and Governance

2.3.1 EDF Energy’s sustainability ambitions have motivated the level to which sustainability has been addressed in this project. EDF Energy has a strong corporate commitment to sustainability, set out in a published sustainability policy entitled ‘Our Sustainability Commitments’ (Ref. 62). The policy covers a range of areas including reducing carbon and waste, delivering low carbon nuclear responsibly, building a world-class culture, helping customers and serving communities. The development of the HPC Project will give EDF Energy significant leverage opportunities to deliver a number of these sustainability commitments, helping to ensure that EDF Energy is ‘on track’ to deliver these commitments. Key commitments relevant to the HPC project include:

• Delivering a 60% reduction in carbon intensity 1 from the generation of electricity from its power stations by 2020. Building new EPR power stations, with very low lifecycle carbon emissions will make a major contribution towards achieving this target. • Working with Government, Non-Governmental and other organisations towards implementing a long-term UK radioactive waste solution. • Supporting development in the UK of the skills necessary to sustain nuclear businesses by working with schools, universities and other bodies.

2.3.2 EDF Energy is in the process of updating its published sustainability policy, and will issue a revised corporate sustainability strategy in summer 2012 which will build on existing commitments.

2.3.3 At the company level, EDF Energy’s sustainability policy is implemented through a structured corporate governance system, split into three tiers. The primary tier of this is EDF Energy’s Sustainable Development Committee, which is chaired by the CEO to assist in the review of its corporate governance. The purpose of the Sustainable Development Committee is to provide company-wide leadership in the delivery of EDF Energy’s sustainability ambitions.

1 All electricity generation technologies emit greenhouse gases at some point in their life cycle and hence have a carbon footprint. Fossil-fuelled generation has a high carbon footprint, with most emissions produced during plant operation. The delivery of low carbon energy technologies such as new nuclear will assist in reducing the average carbon footprint (intensity) of electricity, by displacing more carbon intensive forms.

32 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

2.3.4 The second tier is the EDF Energy Corporate Responsibility and Environmental Panel (CREP), which consists of senior representatives of sustainability teams across the businesses units. This includes Nuclear New Build, of which the HPC Project is a part. The CREP is central to the development of policy and operational objectives, and as such has been consulted on the sustainability proposals being applied to the HPC Project. In turn, a number of the objectives and activities being considered for the HPC Project are informing objectives at company level.

2.3.5 The third tier of governance is through the Sustainability Leadership Group, which co-ordinates the delivery aspects of EDF Energy’s sustainability performance and ensures cross-functional communication on sustainability initiatives. This group has been working closely with the HPC project team to ensure that these outcomes are realised. 2.4 Project Vision and Development Objectives

2.4.1 For the HPC Project, EDF Energy has agreed a project vision with the joint Councils of Sedgemoor District, West Somerset and Somerset County, which demonstrates the intention to deliver the project in a sustainable manner, and which addresses social, economic and environmental issues accordingly. This Vision is as follows:

“EDF Energy intends to deliver a nuclear power station at Hinkley Point C that will make a major contribution to the nation’s low carbon energy needs. The development, operation and ultimate decommissioning of the power station will be undertaken in a manner consistent with the highest standards of safety, reliability and sustainability.

EDF Energy will strive to ensure that the inherent benefits of its investment in Hinkley Point C are captured in a way which maximises its practical contributions to the local and regional economy.

EDF Energy will ensure that any significant adverse effects of the construction, operation or decommissioning of the power station are appropriately mitigated in a way which is environmentally responsible and sensitive both to the needs of the community and to the strategies of the relevant authorities.”

2.4.2 In accordance with this Vision, EDF Energy developed a series of objectives relevant to the delivery of the new build nuclear power station ( Table 2.1). These include high level objectives which relate to the development of the project as a whole, as well as topic specific objectives relating to accommodation, travel planning, recruitment and procurement, community and waste management. The way in which EDF Energy will achieve these objectives is explained in a number of strategies that support the application for Development Consent. This Sustainability Statement illustrates how these objectives have been applied to deliver a more sustainable outcome.

Sustainability Statement | October 2011 33

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Table 2.1: EDF Energy Project Level Objectives EDF Energy Project Level Objectives High-level project objectives • To manage construction in a way that maximises operational efficiency and minimises disruption to the local community. • To avoid adverse impacts on air quality. • To provide positive socio-economic benefits to the local community, e.g. through opportunities for training, employment and participation in the supply chain. • To make a positive contribution to local place-shaping, e.g. by taking forward development in line with regional and local priorities for regeneration. • Where possible, to create infrastructure that has a long-term, sustainable legacy benefit for the local community. • To minimise any negative environmental impacts and seek opportunities for environmental enhancement. • To be a “good neighbour” and ensure the needs and views of the local community are fully taken into account. Objectives of the Accommodation Strategy • To develop a balanced strategy, making use of existing accommodation in the local area and supporting local businesses and accommodation providers whilst seeking to avoid displacement of local people or the local tourist industry. • To meet the operational needs of the Hinkley Point C Project by providing a range and choice of good quality accommodation of a type that will be attractive to workers and meet the requirements of contractors. • To adopt a strategic approach to the location of any purpose built accommodation campuses, focussing on locations with good accessibility to public transport which are sustainably located in relation to either the Hinkley site or to local services. • To ensure that all purpose built accommodation is of a high standard, with high quality facilities and amenities (e.g. bars, sports facilities, laundries), and is appropriately priced. • Where possible or appropriate, to ensure that purpose built accommodation and associated facilities (e.g. recreational facilities) are developed on a sustainable basis, with legacy opportunities considered. • To reduce adverse impacts on local communities and to ensure that workers, in all forms of accommodation are well supported and maintain high standards of conduct, especially in their interaction with the local community. • To ensure the impacts of the development on local communities are assessed, managed and mitigated and that appropriate mitigation measures are put in place. Objectives of the Transport and Freight Management Strategies • Minimise the volume of traffic associated with the development of the new power station so far as reasonably practicable at all times, but especially during peak hours. • Maximise the safe, efficient and sustainable movement of people (i.e. travel by non-car methods) and materials (i.e. delivery by non-road) required for the HPC Project so far as reasonably practicable. • Minimise the impacts both for the local community and visitors to the area using the road network so far as reasonably practicable. • Provide long-term sustainable legacy benefits for the local community from new infrastructure, where appropriate. • Maximise the control of movements associated with the construction of the HPC Project so far as reasonably practicable. • Take all reasonable steps to ensure the resilience of the transport network in the event of an incident. • Take all reasonable steps to protect the natural and built environment.

34 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

EDF Energy Project Level Objectives Objectives of the Training and Recruitment Strategy • To work with contractors, local authorities, central Government and others to develop a training and recruitment programme that will deliver sufficient numbers of appropriately skilled personnel on time to build and operate the new power station. • Together with partners, to leave a legacy of enhanced skills and high quality employment in the UK and specifically in the local area. • To promote the training and recruitment of local people and support the provision of training courses and facilities in the local area. • To encourage the provision of apprenticeships, for both civil and mechanical and electrical jobs, by both the developer and key contractors, targeted at local school leavers. • To promote training for specific disadvantaged groups in the local area. Objectives of the Procurement Strategy • To encourage and facilitate the involvement of local businesses in the supply chain for the nuclear power station. • Where practicable, to stimulate and secure inward investment into Somerset to achieve economic restructuring and meet economic objectives. • To support the use of the project to contribute to the economic development of the local region. • Through support for the local supply chain, to make a positive contribution to the economic development and regeneration of the local area in line with national, regional and local policies. Objectives of the Waste Management Implementation Strategy • To reduce the volume of waste produced. • Maximise reuse and recycling within the wider development. • Maximise reuse and recycling outside of the development and at the associated developments. • Reduce volume of waste sent to landfill. • Minimise transport requirements. • Sustainably use existing infrastructure.

2.5 Overview of the Sustainability Strategy

a) Background 2.5.1 The development of the sustainability strategy has evolved and gathered momentum as the project has progressed to the application for Development Consent. The approach taken for the Project can be best illustrated against key work stages in the Projects planning program, summarised as follows:

ii. Stage 1 – Outline Proposals • Identification of key requirements for sustainability based on project proposals. • Identification of policy drivers for sustainability and how EDF Energy will address this for the application for Development Consent.

iii. Pre Stage 2 Consultation – Preferred Proposals

• Development of the ‘Sustainability Framework’, including a series of sustainability appraisal objectives.

Sustainability Statement | October 2011 35

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

• Identification of high level sustainability opportunities through discussions with the environment team, designers and EDF Energy corporate, and agree sustainability aspirations. • Undertaking of an initial appraisal of the scheme proposals against this framework and publication of the initial findings in the ‘Sustainability Evaluation’ for consultation at Stage 2.

iv. Post Stage 2 Consultation - EDF Energy’s Strategic Response

• Formation of the Sustainability Leadership Group (SLG). • Identification of key gaps and lessons learned from consultation responses. • Consideration of further sustainability opportunities and development of detailed initiatives and KPIs to measure progress. • Undertaking feasibility studies. • Integration into the procurement process. • Development of an Integrated Management System, incorporating sustainability. • Re-appraising the updated proposals against the Sustainability Framework. • Publication of the final sustainability statement for the application for Development Consent.

v. Post DCO consent – Implementation

• Implementing sustainability in construction. • On-going monitoring and reporting. • Preparation for, and implementation of, sustainability in commissioning and operation. • Consideration of opportunities for future decommissioning.

2.5.2 The sustainability strategy can also be summarised diagrammatically as a road map shown in Figure 2.1.

36 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Figure 2.1: Sustainability Strategy Roadmap

Sustainability Statement | October 2011 37

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

2.6 Undertaking the Project Sustainability Appraisal

a) Development of a Sustainability Appraisal Framework 2.6.1 The undertaking of a sustainability appraisal is an important element of EDF Energy’s overall approach to sustainability. The sustainability strategy has been informed, in part, by the findings of the Project’s sustainability appraisal.

2.6.2 A sustainability appraisal framework (Sustainability Framework) was developed by EDF Energy to ensure that the proposals take account of the sustainability objectives against which they will be assessed by the IPC. This Sustainability Framework was first published in support of EDF Energy’s Stage 2 consultation, and has been updated for submission as part of the application for Development Consent. The final Sustainability Framework is available in Part 4 .

2.6.3 EDF Energy’s approach for demonstrating how sustainability will be achieved for the project is to appraise then report its proposals against a number of sustainability objectives which were identified by the Government during the AoS of the Nuclear NPS. To ensure consistency, EDF Energy has used the same sustainability themes and objectives as this AoS (Table S.4.1). A list of these is set out in Table 2.2.

Table 2.2: Sustainability Themes and Objectives Sustainability Sustainability Objectives Theme Air Quality • To avoid adverse impacts on air quality. Biodiversity and • To avoid adverse impacts on the integrity of wildlife sites of international and Ecosystems national importance. • To avoid adverse impacts on priority habitats and species including European protected species. • To avoid impacts on valuable ecological networks and ecosystem functionality. Climate Change • To minimise greenhouse gas emissions. Communities: • To create employment opportunities. Population, • To encourage the development of sustainable communities. Employment and • Viability To avoid adverse impacts on property and land values and avoid planning blight. Communities: • To avoid adverse impacts on the function and efficiency of strategic Supporting transport infrastructure. Infrastructure • To avoid disruption to basic services and infrastructure. Human Health • To avoid impacts on physical health. and Well-Being • To avoid impacts on mental health. • To avoid loss of access to recreational opportunities, their quality and user convenience. Cultural Heritage • To avoid adverse impacts on the internationally and nationally important features of historic environment. • To avoid impacts on the setting and quality of build heritage, archaeology and historic landscapes.

38 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Sustainability Sustainability Objectives Theme Landscape • To avoid impacts on nationally important landscapes. • To avoid impacts on landscape character, quality and tranquillity, diversity and distinctiveness. Soils, Geology • To avoid damage to geological resources. and Land Us • To avoid the use of greenfield land and encourage the reuse of brownfield sites. • To avoid the contamination of soils and adverse impacts on soil functions. Water Quality • To avoid impacts on surface water hydrology and channel geomorphology and Resources (including coastal geomorphology). • To avoid adverse impacts on water quality, including coastal and marine water quality, to assist in the achievement of Water Framework Directive Objectives. • To avoid adverse impacts on the supply of water resources. • To avoid adverse impacts on groundwater quality, distribution and flow and assist achievement of Water Framework Objectives. Flood Risk • To avoid increased flood risk (including coastal flood risk) and seek to reduce risks where possible. Materials and • To promote the sustainable use of materials. Waste* • To minimise waste and apply principles of the Waste Hierarchy. *Note that the theme Materials and Waste has been added by EDF Energy to take account of sustainability issues relevant at the regional and local levels that were not identified by the Government at the strategic level. ‘Waste’ refers to conventional waste (i.e. non radioactive) waste arising from the construction and operation of the facility.

2.6.4 EDF Energy has appraised the project against the above objectives; the full appraisal is available in Part 4 . The appraisal takes into account the issues relevant to the project, including the planning policies and associated objectives against which the project will be judged.

2.6.5 In making an application to the IPC, there is no strict need to appraise the proposed development against regional and local planning policy. This process has already been incorporated into the formulation of the Nuclear NPS, which takes into account regional and local policy as part of the SSA process. However, the Nuclear NPS is set at the strategic level and it will not have had regard to the details of the proposed development. In response to this, the Sustainability Framework identifies policies and objectives at regional and local levels of Government, in order to consider how the proposals are also able to meet these.

b) Sustainability Appraisal Scoring System 2.6.6 Throughout the project, the proposals have been subject to ongoing appraisals against the Sustainability Framework to ensure sustainability objectives relevant to the project have been taken into account.

2.6.7 The Sustainability Appraisal identifies how potential sustainability issues have been determined and what measures have been put in place to ensure that they are effectively managed. The Sustainability Appraisal also identifies the positive effects of the project, and how these will be enhanced further by EDF Energy’s commitments.

Sustainability Statement | October 2011 39

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

2.6.8 The appraisal process incorporates a simple scoring system based on judgement of the extent to which the objectives have been achieved or not achieved. To maintain consistency, EDF Energy adopted the general principles of the scoring system used by the Government AoS of the Nuclear NPS. However, as previously noted, this was conducted at a strategic level. To provide an appropriate appraisal, EDF Energy has modified this to ensure that it can be effectively applied at the detailed project level. The appraisal adopted takes account as far as possible comments received by stakeholders at Stage 2, ensuring a transparent approach has been adopted. Table 2.3 provides a comparison between the Government’s scoring criteria and that adopted for the project appraisal.

Table 2.3: Sustainability Appraisal Scoring Criteria and Comparison with the Government’s Criteria Significance Category of Effect at Outcome Category of Effect National Level Adopted for HPC (Government Appraisal Appraisal) ++ Major Development actively

Significantly The delivery of the Significant encouraged as it would Exceed the project as a whole will resolve an existing Objective make significant sustainability problem. headway in Effect considered as contributing to being of sustainability at the national/international regional/local level. significance. The objective is significantly exceeded. + Minor No sustainability
Exceeding the EDF Energy has Significant constraints and Objective supplied essential development mitigation to reduce acceptable. Effect impacts as well as considered of sustainability national/international initiatives, and thus the significance. objective is exceeded. 0 No Significance Neutral effect 0 Neutral Mitigation has been (meeting the applied to reduce objective significant adverse however no effects although there additional are no sustainability sustainability issues to resolve. On benefit) balance the delivery of the project will have a neutral effect. - Minor Potentially sustainability  Not Meeting The objective has not Significant issues; mitigation and/or the Objective been met, and on negotiation possible. balance, there are Effect considered of impacts from the national/international project which cannot significance. be mitigated. -- Major Problematic because of  Significantly The delivery of the Significant known sustainability Below meeting project as a whole will issues; mitigation or the Objective create significant and negotiation difficult unresolvable and/or expensive. sustainability problems Effect considered of at the regional/local national/international level. significance.

40 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Significance Category of Effect at Outcome Category of Effect National Level Adopted for HPC (Government Appraisal Appraisal) ? Uncertainty Where the significance ? Uncertainty Where the outcome of an effect is against the objective is particularly uncertain, unknown in general, or i.e. insufficient additional information information is available would be required in to fully appraise the the future to more effects of the accurately determine development or the the outcome, the score potential for successful is qualified with a ?. mitigation, the significance category is qualified by the addition of ‘?’

c) Technical Studies 2.6.9 To support the appraisal of the proposals against the sustainability objectives, a number of technical studies and strategies were reviewed. Table 2.4 identifies the range of technical studies which have been prepared by EDF Energy for the application for Development Consent which have been drawn upon for the appraisal.

Table 2.4: Technical Documents Study/Strategy Scope Environmental Impact This identifies the environmental baseline and assesses the Assessment/Environmental environmental impacts, having regard to proposed mitigation Statement measures, of the proposed development, including the off-site associated development. Planning Statement This presents and reviews the Hinkley Point C proposals within the context of planning policy. It considers the compliance of the project as a whole against the relevant planning policy tests against which the overall acceptability of the project should be considered. Alternative Sites Assessment The Alternative Site Assessment (ASA) assesses the alternative site options that were considered in selecting the preferred associated development sites. The purpose of the assessment contained in the ASA is to determine whether the sites proposed for associated development are appropriate, or whether alternative sites ought to be preferred. HPC Post-Operational Strategy This sets the approach that will be taken to facilitate a satisfactory future for temporary associated development sites. Overarching Flood Risk The OFRAR and Site Specific Flood Risk Assessments have Assessment Report (OFRAR) been produced in accordance with the Overarching NPS, the and Site Specific Flood Risk Nuclear NPS and PPS 25: Development and Flood Risk (2010). Assessments These identify how the sites meet the sequential test, and can overcome flood risk. Health Impact Assessment and The Health Impact Assessment (HIA) identifies and assesses the Health Action Plan potential health outcomes (both adverse and beneficial) of the proposed Hinkley Point C (HPC) Project. It is accommodated with a Health Action Plan, forming part of the HIA, which identifies opportunities for improving health.

Sustainability Statement | October 2011 41

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Study/Strategy Scope Transport Assessment This provides an overarching assessment of transport strategy for the HPC Project and the transport impacts during construction and operation. Freight Management Strategy This strategy has been prepared to promote sustainable transport options during construction of HPC. Waste Management This strategy sets out a framework for waste management for the Implementation Strategy Project in accordance with the UK Waste Hierarchy. Combined Heat and Power A CHP study has been undertaken to determine the potential use (CHP) study of CHP at HPC. This fulfils a requirement established within the Nuclear NPS, which requires applicants consider opportunities to integrate CHP into the generation process. The findings of the CHP study are summarised in this document. Design and Access Statements Design and Access Statements have been prepared for the NSIP - Project Wide and Site Specific. to identify the design rationale for the development. A Project Wide Design and Access Statement has been prepared which provides overarching information on the project, and establishes sustainability principles relevant to the project as a whole. A second, more detailed suite of documents has also been prepared for the main site and for each of the off-site associated developments (Site Specific Design and Access Statements). These include sustainability principles relevant to each of the sites, and where possible include targets and design measures proposed. BREEAM Predictive EDF Energy is applying BREEAM (Building Research Assessments Establishment Environmental Assessment Method) to a number of buildings across the project. Detailed predictive assessments which demonstrate how specific measures will be employed in the design of buildings to achieve BREEAM is provided as technical appendices to the site specific Design and Access Statements. The overall approach to BREEAM is set out within this Sustainability Statement. CEEQUAL Predictive CEEQUAL (Civil Engineering Environmental Quality Assessment Assessments Award Scheme) is being applied to the various civil engineering elements of the project’s off-site associated development. Predictive assessments, demonstrating how CEEQUAL will be achieved are provided as technical assessments in the Site Specific Design and Access Statements. The overall approach to CEEQUAL is set out within this Sustainability Statement. Life Cycle Carbon Assessment A life cycle carbon assessment of the project has been of the Carbon Footprint of the undertaken to assess the carbon footprint associated with power Planned Hinkley Point C Power generation from HPC. It assesses impacts from all life stages of Station. the project, including construction. Community Based Strategies A number of community based strategies have been developed and the Hinkley Charter by EDF Energy through on-going consultation with the local authorities and other key stakeholders in the region. The Hinkley Charter summarises all of the commitments and provides an agreement between EDF Energy and the Joint Councils. The specific strategies are important mechanisms for the project to deliver better social and economic outcomes. They include: • Local Business Engagement Strategy. • Construction Workforce Development Strategy. • Community Safety Management Plan. • Worker Code of Conduct Strategy, appended to the CSMP.

42 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Study/Strategy Scope • Accommodation Strategy. • Education Inspired Strategy. • Economic Development Strategy. • Overview of the Outline Contingency Response Arrangements, appended to the CSMP.

2.7 Consultation Process on Matters of Sustainability

2.7.1 EDF Energy recognises that effective consultation is an extremely important element necessary to deliver a more sustainable outcome for the HPC Project. EDF Energy has undertaken extensive consultation throughout the planning process with the local community, statutory consultees and other interested parties. The formal consultation process has been divided into four stages:

b) Stage 1 Consultation; November 2009 – January 2010 2.7.2 This first formal tranche of consultation was based on EDF Energy’s initial proposals, and included information on the general proposals and options for the Project including associated development. The findings of this consultation process have fed into the associated development site selection process to ensure that, as far as possible, relevant concerns were addressed. A Statement of Community Consultation (SOCC) was prepared and published prior to the consultation stage, which summarised the scope of consultation and how it was to be carried out. This, and all following SOCCs at future stages, was drawn up through consultation with the three local authorities within whose boundaries development is proposed: West Somerset Council, Sedgemoor District Council and Somerset County Council.

2.7.3 With regard to specific sustainability information in its Stage 1 consultation, EDF Energy published its intention to develop the project in a sustainable way, and illustrated the type of information that would be further developed for the final application for Development Consent. A range of responses relating to sustainability were received from the Stage 1 process, examples of which include:

“Associated development proposals would be expected to meet the most stringent energy efficiency and environmental standards, which should be tested through externally certified assessment methods such as CEEQUAL, BREEAM and the Code for Sustainable Homes”.

“It is recommended that sustainability initiatives be tied into specific key performance indicators which allow a mechanism for measuring the active pursuit of sustainability initiatives”.

“It is recommended that objectives be evaluated to ensure alignment with the Regional Spatial Strategy Sustainability Appraisal Framework including the Sustainability Appraisal (SA) objectives and indicators therein. Furthermore, this should reference SA objectives for the Sedgemoor District Council and West Somerset Council’s Local Development Frameworks (LDF)”.

Sustainability Statement | October 2011 43

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

“It is recommended that EDF Energy demonstrate the sustainability objectives for the 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”.

2.7.4 Further details of the comments received at Stage 1 are presented in the Consultation Report , including EDF Energy’s response to the issues raised.

c) Stage 2 and Stage 2 Update Consultations; July 2010 – October 2010 and February 2011 – March 2011 2.7.5 These consultation stages were based on EDF Energy’s ‘Preferred Proposals’ for the HPC Project. The Stage 2 consultation included publication of the Sustainability Evaluation document, which set out findings of an initial sustainability appraisal and highlighted measures which EDF Energy would look to include in the design, construction and operation of the development to secure a more sustainable outcome.

2.7.6 The consultation exercise was carried out in accordance with the proposals set out in EDF Energy’s revised SOCCs and strategy documents published prior to the start of the two consultations.

2.7.7 A range of responses relating to sustainability were received through the Stage 2 and 2 Update process. These are set out in the Consultation Report . Examples include:

“The Councils consider that the Sustainability Evaluation was overly generous and not supported by a sufficiently rigorous evidence base. Greater detail is required on why and how the sustainability outcomes identified by EDF Energy will be achieved”.

“A recurring theme of the consultation responses is that the achievement of project level objectives presented within the Sustainability Evaluation should be able to be measured. It has been suggested that a monitoring, reporting and intervention mechanism is put forward to support the achievement of these objectives. This could include additional KPIs and targets”.

“It is considered that there is inadequate links demonstrated between the Sustainability Evaluation process and how this has informed the masterplan designs and other strategy documents. I.e. a visible sustainability strategy is missing, which demonstrates links between objectives and outcomes”.

2.7.8 Further details of the comments received at Stages 2 and 2 Update are presented in the Consultation Report , including EDF Energy’s response to the issues raised.

d) M5 Junction 24 and Highway Improvements Consultation; July 2011 – August 2011 2.7.9 EDF Energy carried out consultation on ‘Proposed Changes to the Preferred Proposals Including M5 Junction 24 and Highway Improvements in the Bridgwater Area’ taking a staggered approach from 1 July to 28 July for Statutory consultees and

44 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

the general public, and from 15 July to 12 August 2011 for the local community. This consultation exercise resulted in a limited number of comments relating to the sustainability of the Project; however, these comments were taken into account.

2.7.10 Based on the consultation responses received, EDF Energy has set about undertaking a significant consultation response process to ensure that the feedback received has been appropriately addressed. For the sustainability aspects, an internal process was created allowing responses to be addressed appropriately by the project team. Common queries and suggestions were highlighted for discussion. The sustainability related consultation responses fell into two main categories. The first contained those that related to the approach to the Sustainability Evaluation undertaken for Stage 2, including its methodology and the baseline that it draws from. The final sustainability appraisal presented within this document takes account of the feedback received, where appropriate and possible. The second category contained responses relating to the general sustainability strategy, including the sustainability initiatives and aspirations that were identified by EDF Energy at Stage 2. Specifically responding to these comments, EDF Energy has focused since Stage 2 consultation on the development of further detail and the consideration of additional sustainability opportunities to deliver EDF Energy’s Vision for the project. This process involved the creation of a Sustainability Leadership Group (SLG), which has provided a key role in sustainability governance at the project level.

2.8 EDF Energy’s Strategic Response

a) Sustainability Leadership Group (SLG) 2.8.1 Prior to Stage 2 consultation, the sustainability work was primarily focused on identifying and evaluating the sustainability related initiatives being considered for the HPC Project by the project team, and characterising these in relationship to the appraisal objectives. To develop further detail and ensure that additional sustainable design and construction initiatives were considered and integrated into the project effectively, the SLG was established shortly after Stage 2. The SLG consists of representatives from the HPC Project development team, and includes senior members from the construction, procurement, environment and communications teams, as well as the project’s external sustainability advisors.

2.8.2 The SLG has played a key role in the ongoing development of EDF Energy’s sustainability strategy for the HPC Project. This will be in place throughout the construction and operation of the power station. Accordingly, an important element of the SLG is that its membership is dynamic, and the group will be joined by relevant potential contributors as the project develops, including main contractors, key suppliers and ultimately the plant operators.

2.8.3 Since the SLG was established, it has been working in a number of key areas to ensure that sustainability is embedded in the scheme as far as practically possible in advance of the application for Development Consent. The following activities have been key to this:

• Review of consultation responses, best practices and innovations in sustainability to define stakeholder expectation. • Raising sustainability awareness across the project.

Sustainability Statement | October 2011 45

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

• Appraising further sustainability opportunities and developing those opportunities already considered: − sustainable design standards in buildings and infrastructure; − achieving carbon reduction in design through the development of renewable energy and low carbon strategies; − developing further detail on a waste strategy and considering further ways to reduce the impact of temporary accommodation; and − considering the application of the carbon impact of the project, and opportunities to reduce the impact of construction; • Developing an Integrated Management System. • Embedding sustainability requirements into the procurement process and defining contractors and suppliers obligations. • Defining key requirements for reporting.

ii. Defining Stakeholder Expectation 2.8.4 The extensive consultation exercise provided a useful context for how stakeholders wished to see sustainability incorporated into the project. This has helped EDF Energy gauge the views of stakeholders, including local communities around Hinkley Point. However, stakeholder expectation is also indirectly influenced by how other major construction projects have developed and implemented sustainability – i.e. how these projects have set precedents and best practices. For this, a review of major infrastructure projects was undertaken and comparisons were made between the types of commitments made, KPIs and how these were developed and monitored. The opportunities presented from other projects were evaluated by the SLG.

iii. Project Wide Awareness Raising on Matters of Sustainability 2.8.5 As part of the SLG’s remit for the project, steps have been taken within EDF Energy to ensure that the profile of sustainability and its importance to the project is promoted. All EDF Energy employees undergo environmental and sustainability training. Additional initiatives will continue to be put place to provide presentations and training for relevant members of the projects teams.

2.8.6 Key meetings of the SLG have been attended by EDF Energy’s Chief Environmental Officer and its Head of Sustainability, enabling EDF Energy’s corporate sustainability objectives to be continually taken into account in the development of the project. Further to this, the project’s sustainability initiatives have been discussed with EDF Energy’s CREP, and were presented to and approved by the project Executive.

iv. Appraising Further Sustainability Opportunities and Developing those Opportunities Already Considered 2.8.7 A key area of focus for the SLG has been to identify and test additional potential opportunities to enhance the sustainability of the project and to develop further detail on the sustainability measures identified at Stage 2.

2.8.8 In order to identify and appraise additional sustainability opportunities, a ‘Sustainability Opportunities Register’ was developed, which detailed a broad range

46 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

of sustainability initiatives available to the project. These were identified through consultation and best practice reviews. Within the Register they were assigned to the sustainability appraisal themes and objectives described above. While the Sustainability Opportunities Register has been prepared and maintained by the project’s external sustainability advisors, its content has been subject to consultation with the project’s environmental topic leads and the SLG, including key representatives from the design, procurement, construction and planning teams.

2.8.9 The intention of the register was to identify a number of additional potential sustainability opportunities, and through a systematic and considered approach, identify the most relevant opportunities which could be embedded in the project. In order to do this, the register provided a simplified system to appraise the relative value of a sustainability opportunity to EDF Energy, based on a rating system that took account of:

• Relevant external legislation and planning policy. • EDF Energy’s own corporate policy. • Stakeholder interest as represented by consistent themes in the consultation responses. • Potential precedents set by other major construction projects in the UK. • The risk to the project that would be incurred should it fail to be delivered. This took into account both the perceived size of the hazard and how likely it was that this hazard would materialise.

2.8.10 An illustrative example of this approach is provided in Figure 2.2 below. Additional information on the scoring criteria used for this purpose is provided in Table 2.5.

Figure 2.2: Illustration of a Sustainability Opportunity being Appraised in the Register

ABCDE Automatically Legislation/ Hazard/ Frequency/ Risk Sustainability Sustainability Stakeholder Significant? Y/N Summary Impact Specific Measures Corporate Severity of Occurrence Assessment Theme Objective Interest (Score 3 in A or (A+B+E) Policy/Planning Impact (Probability) (CxD) B) Climate Change To minimise Require contractors to greenhouse gas report carbon emmissions (ghg) emissions to EDF Energy. 2 2 N 23 6 10 2.8.11 Within this framework, a sustainability opportunity may have a significant impact in one of two ways:

• It scores 3 in either columns A or B, i.e. either it is required directly by legislation, policy or planning commitments, or it was represented as a consistent major theme within the consultation responses and is therefore demonstrated to be of significant interest to stakeholders; or alternatively. • Although of less acute significance for legislative, corporate or stakeholder requirements, failure to implement it would represent a significant risk to the project – for example, in wasting resources or causing avoidable environmental impacts. This leads to a score of up to 9 in column E.

2.8.12 The Summary Impact (total score) is then determined by adding together scores in columns A, B and E. The criterion for significance is a Summary Impact of 10 or above. In the above example, the opportunity is found to have been significant on this basis.

Sustainability Statement | October 2011 47

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Table 2.5: Scoring Criteria for the Sustainability Opportunities Register Criteria Definition Scoring Legislation/Corporate This evaluation criterion is based 0 - EDF Energy corporate policy or Policy/Planning upon whether the sustainability planning policies do not apply. opportunity is either subject to regulatory control via planning 1 - EDF Energy corporate policy or requirements set by national or local planning policies apply but only in planning policies, or is an EDF a general way. Energy corporate commitment or 2 - EDF Energy corporate policy or planning requirement. E.g. noise planning policies may apply from construction sites will be subject directly under certain to regulatory control, low carbon circumstances. Absence of control electricity generation is an EDF measures or a meaningful Energy corporate sustainability response is likely to have a minor commitment. Planning requirements regulatory or reputational impact. by national or local planning policies. 3 - EDF Energy corporate policy or planning policies directly apply to the project. Absence of control measures or a meaningful response could result in prosecution, failure to achieve consent or serious reputational harm. Stakeholder Interest The project incorporates range of 0 - No stakeholder interest. statutory and non-statutory 1 - Of minor interest to stakeholders including: national stakeholders as an indirect government and government concern. agencies, local government, site neighbours, NGOs, land owners and 2 - Of interest to stakeholders but EDF Energy staff. The evaluation not a primary concern. Absence of criterion is based upon the extent to control measures or meaningful which this factor has informed the response is unlikely to result in a responses received in the planning objection or challenge to consultation exercises. the planning process or reputational harm. Possible individual complaint during construction or operation. 3 - Of significant interest to stakeholders. Absence of control measures or a meaningful response addressing stakeholder concerns could result in a planning objection or challenge to the planning process or reputational harm. Likely to result in multiple or sustained complaints during construction or operation. Hazard/Severity of The potential severity of harm and 0 - No hazard exists. Impact consequences from a single instance 1 - Minimal hazard - little impact or event ONLY should be considered. localised to site despite the failure In this context "harm" includes or absence of the sustainability reputational harm and wastage of measure. natural resources. E.g. failure to require contractors to use sustainable 2 - Medium hazard - localised timber could result in the supply of harm as a result of failure or timber from unsustainable sources. absence of the sustainability In this context beyond the site measure. Possible minor impact beyond site boundary.

48 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Criteria Definition Scoring boundary includes the supply chain. 3 - Major hazard, e.g. Significant harm beyond the site boundary is likely should the sustainability measure be absent or fails. Frequency/Occurrence A qualitative estimate should be 0 - Very unlikely to occur even in (Probability) made of how often the hazard is likely the absence of control measures. to occur in the absence or failure of 1 - Possible occurrence should the sustainability measure. control measures fail or be absent. 2 - At least one occurrence is likely should control measures fail or be absent. 3 - Multiple occurrences are likely should control measures fail or be absent.

2.8.13 An important objective of the sustainability strategy was that it should identify additional opportunities that are cost effective, in terms of their impact on the project’s feasibility, cost or programme, and hence on its economic viability, as well as delivering genuine sustainability benefits. To help to ensure this, in addition to assessing the value of the opportunity as described above, the register also took the broad cost of implementation into account, using a simple scale ranging from no or minimal cost to high cost. This enabled EDF Energy to identify the opportunities which represented the best value for money in terms of sustainability.

2.8.14 The assessments made in the Sustainability Opportunities Register were tested through a workshop with full SLG representation. ‘Owners’ were identified for each component within the portfolio of recommended options, and internal key performance indicators established to allow implementation to be monitored. As a result of implementing this process, a short-list of realistic and appropriate opportunities was produced with agreed means of monitoring and reporting throughout the life of the project.

2.8.15 A number of key areas were identified as providing opportunities to meet sustainability objectives. These fall under the followings headings:

• Sustainability Assessment Tools and Associated Ratings. • Biodiversity. • Climate Change. • Materials and Waste. • Communities – Supporting Infrastructure (Transport). • Water Resources. • Archaeology/Heritage. • Reporting and Communication. • Training.

Sustainability Statement | October 2011 49

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

2.8.16 A summary of the measures which fall under these areas, and which are being taken forward in the HPC Project is shown in Table 2.6. The project stages are referred to as follows:

• D – Design. • C – Construction. • O – Operation. • DC – Decommissioning/restoration.

50 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Table 2.6: Sustainability Measures Agreed through the Sustainability Opportunities Register Theme # Sustainability Option KPI Project Stage Explanatory Notes D C O DC 1 BREEAM – Bespoke BREEAM score.

Status: Approved Measure assessment for Amenity ’Very good’ rating is a requirement of the Local Authority through Blocks with ‘Very Good’ prevailing planning policy. This target will be filtered down to the design rating instead of ‘Good’. brief for buildings over 1000 m 2. Following further feasibility studies, additional sustainability measures were identified to achieve ‘Very Good’ which are cost effective and will contribute to the operational efficiency of the buildings when in use. 2 BREEAM – Multi residential BREEAM score.

Status: Approved Measure ‘Excellent’ rating for Higher standards of sustainability sought for EDF Energy legacy Bridgwater C. buildings. 3 BREEAM – Bespoke BREEAM score.

Status: Approved Measure ‘Excellent’ rating for the Higher standards of sustainability sought for EDF Energy permanent HPC site buildings: PIC, buildings where BREEAM is applicable. OSC and STC. 4 BREEAM – Multi residential BREEAM score.

Status: Approved Measure ‘Very Good’ rating for Following further feasibility studies, additional sustainability measures Accommodation Blocks at were identified to achieve ‘Very Good’ which are cost effective and will BRI-A and on-site. contribute to the operational efficiency of the buildings when in use. 5 Design brief to ensure Energy strategy.
Status: Approved Measure options to reduce energy The off-site associated developments and the HPC accommodation and associated emissions campus have been taken forward subject to energy assessments, which Assessment Tools and Associated Ratings Associated Tools and Assessment in the operation of have characterised the CO 2 emissions associated with them. The Combwich Wharf, Park and assessments have been used to assess identify the appropriate low Rides and Freight carbon and renewable energy strategies appropriate to buildings, and Management Facilities are has also been used to plan for reducing emissions from lighting. considered. An evaluation The strategy must address energy through a logical hierarchy, whereby of renewable energy options to reduce consumption through efficiencies are adopted first. technologies should be included as part of this.

Sustainability Statement | October 2011 51

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Project Stage 6 CEEQUAL – ‘Very Good’ CEEQUAL Score. Status: Approved Measure rating for Junction 23, CEEQUAL will be implemented for specific elements of the associated Junction 24, Williton park

development and a score of Very Good will be achieved subject to and ride, Combwich feasibility studies. Laydown Facility and Cannington park and ride. 7 CEEQUAL – ‘Excellent’ CEEQUAL Score. Status: Approved Measure rating for Cannington

CEEQUAL will be implemented for specific elements of the associated Bypass. development and a score of Excellent will be achieved subject to feasibility studies. 8 Incorporate green roofs at Green roofs Status: Approved Measure the HPC site where specified where
A feasibility study has been produced which sets out the buildings that feasible. applicable. have green roofs and the type of roofs proposed. 9 Design permanent Status: Approved Measure landscaping features on The principle of this option was agreed, however must be undertaken temporary sites to have a very carefully to ensure no risk to protected species. long-term ecological benefit

Biodiversity Biodiversity that can be maintained when the operation of the facilities ceases. 10 It is required that all Tier 1 2 Supplier Status: Approved Measure contractors set out a requirement set in This will be included in the procurement process for Tier 1 contractors. It strategy for how emissions contracts. is expected that best practice is followed to ensure emissions are will be limited from the Supplier reduced. Fuel use may be monitored and evaluated to calculate

delivery of goods and emissions emissions. services. strategies. Fuel use Climate Change Climate monitoring.

2 Tier 1 contractors are those appointed to carry out a major work package of the project, forming part of the construction breakdown.

52 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Project Stage 11 Require that Tier 1 Supplier Status: Approved Measure contractors monitor their requirement set in This will be included in the procurement process for Tier 1 contractors. It emissions and set contracts. is expected that best practice is followed to ensure emissions are progressive targets for Emissions data.
reduced. Fuel use may be monitored to calculate emissions. reduction which will be reported back to EDF Energy. 12 Ensure localised electricity Requirement of Status: Approved Measure grid provisions are built into design brief. Ensure localised electricity grid provisions are built into the HPC Project the HPC Project to provide to provide an option for the low carbon decommissioning of HPB. EDF an option for the low carbon Energy will include sufficient flexibility in design through appropriate decommissioning of HPB -

infrastructure to be achievable if desirable. However, this is dependent include flexibility in design on HPB. through appropriate infrastructure to enable this if desirable. 13 Sustainable Materials Statement of

Status: Approved Measure Policy for issue to intent issued as Materials policy should include a Black/Grey and Green list of materials. contractors. tender/contract EDF Energy will require that all contractors demonstrate how this will be requirement. adhered to. This will be in the form of a strategy and will include Contractor information on working with the supply chains, evaluating options for strategy. Modern Methods of Construction and diverting local waste streams for re- use. Materials which are not suitable for nuclear island structures will form part of the black list. This option needs to be site-sensitive to avoid prejudicing nuclear requirements. It should be noted that while best Materials Materials endeavours will be made to use green materials, the technical requirements will override this ambition. The UN Global Compact and REACH requirements be included as part of this list. 14 100% of Tier 1 suppliers 100% of Status: Approved Measure will have an EMS. suppliers.
The resource for monitoring this requirement is subject to further evaluation. However this will form part of the IMS.

Sustainability Statement | October 2011 53

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Project Stage 15 At least 90% of timber At least 90% of Status: Approved Measure sourced in accordance with material.
It is not possible to commit to 100% due to the large quantities of timber FSC requirements across required for formwork. project. 16 Where practicable and Neutral cut and fill Status: Approved Measure feasible, commit to a proportions for Particular associated development sites where this is feasible need to be neutral cut and fill balance some associated determined. This will be balanced with the main site as material will be for some associated development kept on site where possible. development sites – This sites (exact % Establish a neutral cut a fill balance which will be informed by high levels will be possible for P&R TBC). achieved on site set against low levels achieved on Cannington bypass. sites and some campuses Neutral cut and fill Materials will be used for re-levelling the site and landscaping bunds (except BRI-A&C due to
proportions for provided there are no height limits. contaminated land). main site (commit This will save the transport (lorry movement) and disposal of Commit to a neutral cut and to 80%). approximately 2 million m 3 of soil. fill balance for the main site - This target will not include contaminated land (small amount). 17 Require that contractors Supplier Status: Approved Measure take all opportunities to requirement set in This option was deemed feasible and will be implemented however explore the use of contracts. technical requirements will prevail. standardised, prefabricated
and modular buildings and construction elements where appropriate 18 Development of a re-use A reuse hierarchy Status: Approved Measure strategy for temporary for sustainable EDF Energy will explore options for sustainable after use of the buildings buildings. legacy use of and infrastructure at an appropriate point in the future. The reuse temporary


hierarchy follows the UK waste hierarchy, and identifies that direct re-use

Waste Waste developments is the most sustainable outcome, although demonstrates that not all has been project elements are expected to achieve this. produced.

54 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Project Stage 19 Investigating opportunities Anaerobic Status: Approved Measure for Anaerobic Digestion to Digestion contract EDF Energy will explore all options for anaerobic digestion and will seek process food waste arising set up.
to make use of anaerobic digestion as it becomes available in the locality. from on site canteen and accommodation where feasible.

20 Allow cyclists to park Cyclist facilities Status: Approved Measure directly at the main site if provided on main Cyclists will be given an option to cycle to main site by providing they wish, as opposed to site.

adequate cycle storage facilities during construction and operation but travelling to park and ride they will not be encouraged to do so due to possible hazards on the C182 facilities during construction road. and operation. 21 Travel by bus and cycle will Requirement set Status: Approved Measure be a condition of in contracts. This measure forms part of a wider package of work falling under the employment for contractors
‘people movement strategy’. during the construction

phase. 22 Encourage linked trips Linked trips Status: Approved Measure including the two-way encouraged.

This will be implemented through contractual negotiation with future management of waste. waste contractor. 23 Electric vehicles – Design Design future Status: Approved Measure in facilities to enable the proofed. This is included in the design brief. retrofit of electric charging

points at the HPC permanent development

Communities – Supporting Infrastructure (Transport) Infrastructure – Supporting Communities site at a later date.

Sustainability Statement | October 2011 55

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Project Stage 24 Water consumption will be Water Status: Approved Measure monitored by all contractors consumption Targets will be set in accordance with the Department of Trade and and targets will be set. measured and Industry (now the Department for Business Innovation and Skills) KPIs monitored. available from the Centre of Construction Innovation. Measures to
EDF Energy will compile water consumption data to measure trends and encourage explore ongoing options for water reduction with contractors, while contractors to flagging up and investigating any abnormal consumption levels. prevent wasting Monitoring will encourage contractors to reduce water consumption. Water Resources Resources Water water as far as Existing information processing through IMS would be used if applicable. possible. 25 Include an exhibit in the Space for Status: Approved Measure PIC showing local archaeological Somerset Museum will be the official owner of the excavation archive but archaeology and how the remains

items for display will be provided on a long-term loan to EDF for the PIC. project has protected allocated. The Museum should also be able to advise us on how the findings should

Heritage remains where possible. be displayed. Archaeology/ Archaeology/

26 Proposal to report on Successful Status: Approved Measure sustainability at 3 levels: communication at A subgroup within the SLG was set up to drive this forward and agree the • Local community. all levels. scope of reporting (to include three pillars of sustainability). • Contractor Sustainability will be reported within existing annual reports. In addition, quarterly reports will be produced for the local community on the back community.


page of the existing newsletter. • Annual sustainability All reporting will be aligned with EDF Energy’s Quality Assurance Reporting and and Reporting reporting in line process. Communications Communications with EDF corporate commitments. 27 Contractors receive training 100% of site Status: Approved Measure for sustainability aspects. workers on main This will be delivered as part of the site induction. site receiving

training on

Training Training sustainability issues.

56 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

2.9 Explanation of Sustainability Commitments

2.9.1 This section provides further information on how and why the sustainability opportunities have been developed for the project, and the method for applying these.

2.9.2 The SLG has evaluated opportunities across a number of specific key areas:

• application of sustainable design standards in buildings and infrastructure; • achieving carbon reduction in design through the development of renewable energy and low carbon strategies; • developing further detail on a waste strategy and considering further ways to reduce the impact of temporary accommodation buildings and infrastructure; and • considering the application of the carbon impact of the project, and opportunities to reduce the impact of construction.

b) Sustainable Design Standards in Buildings and Infrastructure 2.9.3 One of EDF Energy’s main terms of reference for the sustainability strategy is to use sustainable design codes and standards that are credible, effective and capable of being externally verified.

2.9.4 EDF Energy considers that the most appropriate way of achieving this is to apply sustainable design criteria through widely recognised assessment schemes, which allow for an audit and third party verification to demonstrate compliance. EDF Energy has considered a number of methods to achieve this. The main vehicle of choice for this purpose is BREEAM (the Building Research Establishments Environmental Assessment Method), which can be applied to a number of buildings associated with the project; and CEEQUAL (Civil Engineering Environmental Quality Award Scheme), which is the equivalent scheme for civil engineering elements of the project.

ii. BREEAM 2.9.5 BREEAM is the most widely recognised sustainable design standard for non- domestic buildings in the UK. It is also an independently verified sustainability standard, which rates a building’s sustainability on the scale of ‘Unclassified’ to ‘Outstanding’, depending on the extent to which sustainable design and construction measures are employed.

2.9.6 EDF Energy would apply this standard to all associated development buildings over 1000 m 2. This includes all accommodation campuses, amenity buildings on those sites and the induction facility at Junction 23. BREEAM standards will be applied at different levels, depending on the future use of these buildings. Permanent buildings (Bridgwater C) would be designed to BREEAM Excellent. Buildings of a temporary nature, only required to facilitate the construction of HPC, would be designed to lower standards reflecting that investment in such buildings may be uneconomical and potentially unsustainable.

2.9.7 The Stage 2 consultation proposed that the BREEAM standard of ‘Good’ should be applied for temporary buildings. This was criticised as un-ambitious during consultation. The design teams have explored options to achieve ‘Very Good’ for

Sustainability Statement | October 2011 57

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

these temporary buildings via BREEAM predictive assessment work, and conclude that this target can be met, which will align with draft policy D3 of the SDC Core Strategy and the expectations of stakeholders The predictive BREEAM assessments are appended to the Design and Access Statements.

2.9.8 For permanent buildings at the HPC site, BREEAM is also being applied. However the majority of buildings are of industrial type with limited or infrequent occupancy, and are also governed by very specific design standards in order to satisfy the conditions of the nuclear site licence to be issued under the Nuclear Installations Act 1965 (as amended). In many circumstances, these buildings do not need to meet with Part L of the Building Regulations, and have such specific design requirements that BREEAM is not applicable or appropriate to apply.

2.9.9 Consequently, BREEAM is being applied for three HPC site buildings, the operational service centre (OSC), the public information centre (PIC) and the simulator building/training centre (STC). EDF Energy intends to achieve BREEAM Excellent for these buildings, and has identified through predictive assessment work that such targets are possible (see BREEAM Predictive Assessment appended to the HPC Development Site Design and Access Statement) . The achievement of BREEAM Excellent is subject to final assessment.

2.9.10 All BREEAM assessments have been developed through liaison with the Building Research Establishment (BRE), to define which BREEAM criteria to apply and the way in which they are applied. The approach agreed with the BRE is to apply BREEAM Multi-residential criteria to the campus accommodation blocks, and BREEAM Bespoke Criteria to all other buildings subject to assessment. All applicable buildings have been registered under the BREEAM 2008 assessment criteria, and would be validated against this standard.

iii. CEEQUAL 2.9.11 EDF Energy has also considered CEEQUAL, which is an environmental accreditation for civil infrastructure projects. Similar to BREEAM, CEEQUAL appraises a project on a number of criteria and scores the project from ‘Fail’ to ‘Excellent’.

2.9.12 CEEQUAL will be used to continually consider and evaluate environmental/sustainability enhancements for the project with the design team and contractors. It is proposed by EDF Energy for the following reasons:

• it sets a trajectory to delivering sustainability into particular project elements, and will help to define project tasks; and • it creates a one team approach, and will motivate staff and contractors to perform and promote inter-company team working, which is particularly important given the scale of the project.

2.9.13 EDF Energy intends to apply CEEQUAL to elements of the projects off-site associated development. ‘Very Good’ is targeted for the following proposed developments:

• park and ride, freight management and courier consolidation facility and induction centre at Junction 23 of the M5;

58 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

• park and ride, freight management and temporary postal/courier consolidation facility and induction centre at Junction 24 of the M5; • Cannington park and ride facility; • Williton park and ride facility; and • Combwich freight laydown facility.

2.9.14 CEEQUAL ‘Very Good’ has been identified as being possible through predictive CEEQUAL assessments, which are appended to the corresponding Design and Access Statements. Further details are provided there. The level of CEEQUAL has been proposed based on the post-operational strategy for those sites.

2.9.15 EDF Energy also proposes to achieve CEEQUAL Excellent for the Cannington bypass. Higher levels are sought due to the permanency of the development (see CEEQUAL Predictive Assessment appended to the Cannington Bypass Design and Access Statement ).

2.9.16 EDF Energy has taken the decision not to employ CEEQUAL accreditation for any of the works relating to Hinkley Point C (HPC). CEEQUAL is considered inappropriate here, as the construction programme and processes for managing construction will be tightly constrained in order to meet the over-riding safety, quality and security requirements integral to the development of a new nuclear power station. Notwithstanding this, many of the principles of CEEQUAL would be addressed in the development of Hinkley Point C (HPC).

c) Renewable and Low Carbon Energy Strategies 2.9.17 There are notable and significant benefits from the operation of HPC to deliver carbon reduction and security of energy supplies. Although EDF Energy is not reliant on this outcome alone, it must be recognised that the project would provide a significant contribution to the UK’s energy strategy and the Low Carbon Transition Plan. Notwithstanding this, EDF Energy will also ensure that new development associated with the project is energy efficient and, as a minimum, achieves the national timetable for carbon reduction in building development, consistent with the Building Regulations.

2.9.18 An assessment of energy and carbon emissions has been undertaken for the off-site associated development in order to inform design development. This ensures that these sites are able to meet with the prevailing policy for carbon reduction, as set out within the submission draft Sedgemoor District Council (SDC) LDF Core Strategy Policy D3.

2.9.19 For the proposed accommodation campuses, the buildings will incorporate a range of passive design measures, achieved through the application of building orientation, a thermally efficient building envelope and natural ventilation strategies. The buildings will also employ energy efficiency measures, such as energy efficient lighting and renewable energy technologies, comprising Air Source Heat Pumps and Solar Thermal panels where needed. Again, the strategy employed is dependent on the legacy of the buildings.

2.9.20 In accordance with EDF Energy’s corporate aspirations for sustainability, additional investment has been made at the legacy site, Bridgwater C, and as such this will

Sustainability Statement | October 2011 59

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

achieve greater carbon reductions by comparison with the temporary buildings at the other two accommodation sites. The application of CHP and decentralised energy via a district heating main has been evaluated for Bridgwater C, although this is not deemed viable.

2.9.21 In contrast, the approach to temporary accommodation buildings at Bridgwater A and the HPC accommodation campus has taken account of the need to address policy compliance, but at the same time minimise costs to an acceptable level, in terms of both financial and carbon costs. This is set against the backdrop of EDF Energy’s proposals to maximise the potential for future re-use of the buildings and building elements as far as practically possible, which is in accordance with EDF Energy’s re- use strategy (discussed later). Air Source Heat Pump (ASHP) systems provide the technology of choice here, based on the emerging markets for reconditioned systems.

2.9.22 For other associated development sites such as the park and rides, the energy strategy focuses on carbon reduction mainly through energy efficiency measures, although the potential for renewable energy has been considered. The exception to this is the Junction 23 site induction centre which, as a significant building, incorporates the necessary renewable energy technologies to reduce emissions in line with draft Policy D3. There are also a number of smaller buildings on the park and ride sites such as security and waiting areas. These will be simple buildings, and carbon reduction here will be achieved by following an elemental approach, for example through improving building fabrics and providing efficient lighting, rather than incorporating more advanced renewable energy technologies.

2.9.23 Lighting is an important consideration for all of these sites, and is a particular focus for EDF Energy. For security reasons lighting at the park and ride sites will be required during all hours of darkness to maintain a minimum level of 1 lux around the perimeter fence for the CCTV cameras. Elsewhere, lighting will remain at 20 lux. Whilst this is particularly challenging for energy efficiency commitments, EDF Energy is developing lighting designs which are expected to lead to approximately 50% reduction in emissions by comparison to industry best practice. This will be achieved by minimising light fittings as far as possible, ensuring lighting is only used where it is needed, reducing the height of lamp columns as far as possible and specifying of efficient fittings. Consideration was given to LED lighting, although this was rejected both on the grounds of payback and that it is expected to have a higher carbon cost. LED lighting has however been adopted in the design strategy of Bridgwater C.

2.9.24 With regard to the HPC Site, the energy strategy will make use of a private wire electrical connection from HPC, which once operational will supply electricity to all buildings onsite. HPC will have no gas supply, and therefore 100% of the site’s power supply will come from this low carbon power source. Prior to the power station becoming operational, buildings will be fed by a 275kV substation and then transferred onto the main plant network once HPC becomes operational. Evaluations were undertaken to determine whether HPB power station would be able to provide the electrical demand of the site via a private wire connection during this interim period, but this was considered to offer limited potential based on the increased power requirements in this phase of construction and commissioning.

60 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

2.9.25 The impact of the private wire low carbon power source has been taken into account for the buildings being assessed against BREEAM. It is expected that these buildings will have high Energy Performance Certificate ratings (A Ratings).

d) Waste Strategy and the Re-Use Hierarchy 2.9.26 Waste is a key issue for the project and a waste strategy has been developed to set out how options for sustainable waste management will be promoted. EDF Energy’s Waste Strategy follows the UK Government’s Waste Hierarchy, which requires prevention of waste generation in the first instance and reducing, as far as possible, the volume requiring disposal once the waste has been produced. The Waste Hierarchy (illustrated in Figure 2.3 below) gives an order of preference for waste management options to minimise the volume for disposal.

Figure 2.3: Waste Hierarchy

2.9.27 The project team has responded to the Strategy’s objectives to minimise waste and work to the waste hierarchy. The development proposals at the HPC site will achieve a zero cut and fill balance for non-hazardous waste, whereby materials will be used for re-levelling the site and landscaping bunds. Over the project as a whole, it is anticipated that the 80% of the material can be managed in this way, which will lead to significant carbon benefits from moving spoil off-site.

2.9.28 The most significant impact with regard to waste will arise during the restoration of the temporary associated development sites, once construction of the power station is complete. According to the construction programme, this waste will arise from 2022 and equate to over 160,000 tonnes per annum at its peak. ( Figure 2.4 ). In total, waste arising from restoration will total approximately 742,000 tonnes (including a 20% contingency, but excluding waste from the HPC decommissioning phase). Further details are available within the Waste Management Implementation Strategy . EDF Energy is committed to reducing this waste volume as far as possible, which may be achieved through the re-use of certain aspects of this associated development. Opportunities for re-use are largely unknown at this stage, as these will depend significantly on factors including, but not limited to, future market conditions, the condition of the materials used, and future regulations and governing requirements.

Sustainability Statement | October 2011 61

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

2.9.29 As such, opportunities for the re-use of temporary development will be explored by EDF Energy at a later date, prior to restoration commencing. Further details are available within Section 11 of the Waste Management Implementation Strategy . EDF Energy has developed a re-use strategy, which commits to identifying future uses of temporary developments prior to cessation. If, in the future, direct reuse offers limited potential, the buildings have been designed to be recyclable, with component parts being reusable.

2.9.30 Operational waste management is also considered within the strategy. EDF Energy will continue to look for innovative ways to manage waste arising during operation, and are in the process of engaging with local waste management companies to determine whether practices such as anaerobic digestion offer potential.

Figure 2.4: Waste Generation during the Construction of the HPC Project

180000

160000

140000

120000

100000

80000

Waste Waste Volumes (tonnes) 60000

40000

20000

0

1 1 2 3 3 4 5 5 6 7 7 8 8 9 9 0 0 1 2 2 12 17 1 l-11 -1 l-1 -1 -1 -1 l-16 -1 -1 l-1 -2 -2 l-21 -2 -2 r-1 u r- v-12 r-13 u v r-1 v-14 v r-1 u r- v r-18 u r-1 v- v r-2 u v J Jul J Jul-14 ar-15 Jul J Jul J Jul-19 ar-20 Jul J Jul Ma Nov-1Ma No Ma No Ma No M No Ma Nov-16Ma No Ma Nov-1Ma No M No Ma Nov-21Mar-22 No Date

e) Carbon Analysis and Low Carbon Construction 2.9.31 The construction of the HPC Project, as with any major construction project is naturally a carbon intensive process. Given the ability HPC will have to generate low carbon energy, the most important consideration for EDF Energy is the impact this has on the on carbon emissions expressed as CO 2e/kWh content of the electricity produced over the lifetime of the power station. EDF Energy has appointed an independent consultant to undertake a Life Cycle Assessment of the carbon footprint of HPC. This quantifies carbon emissions throughout the lifecycle of HPC – i.e. emissions associated with extraction, conversion, enrichment and fuel fabrication, as well as construction, operation and eventual decommissioning. Further details on its scope and assumptions made are available within the Life Cycle Assessment of the Carbon Footprint of the Proposed Hinkley Point C (HPC) Project (LCA).

2.9.32 The predicted embodied carbon within 1 kWh of electricity generated from Hinkley Point C is 4.8 g CO 2e (Paragraph 2.1 of the LCA Summary). This is significantly lower than conventional gas and coal fired generation which does not incorporate Carbon Capture and Storage (CCS), which is approximately 400 and 900g CO 2/kWh respectively. Additionally, it is substantially lower than the current average of 517g

62 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

CO 2/kWh for electricity supplied from the National Grid assumed by the Building Regulations Part L 2010.

2.9.33 The two reactors at HPC will have a combined capacity of 3260MW of electricity. Taking account of periodic maintenance outages and the requirements for electricity consumption on site; it is estimated that the annual electricity generation will be 25,987 GWh. Given the carbon footprint is 4.8g CO 2e/kWh, then the embodied carbon is some 0.125Mte CO 2 per annum. This is a saving of some 10.4 Mte CO 2 against generating the same electricity from gas and 23.4 Mte CO 2 against generating from coal (without CCS) – every year for the 60 years operating life of the station.

2.9.34 With specific regard to construction related emissions, the construction and commissioning of the plant and associated development is estimated to represent approximately 36% of the total lifecycle greenhouse gas emissions of the electricity produced (Paragraph 2.3.1 of the LCA Summary). A significant proportion of this relates to the embodied energy within the materials required. Over 430,000 tonnes of steel and 1,200,000 m 3 of concrete are predicted to be used in the construction of HPC. Both of these materials require significant quantities of energy in their manufacture and this is a major factor in the high CO 2 and GHG emissions at the construction stage. Steel is estimated to account for 36%; and concrete, 18%, of the CO 2 during construction. Transport has a relatively small impact on the construction stage at around 12% of the total GHG emissions ( Figure 2.5 ).

Figure 2.5: Breakdown of GHG Emissions during Construction: Source LCA of the Carbon Footprint of HPC.

2.9.35 With regard to reducing emissions during construction, EDF Energy is confined to operating within the design requirements for a robust plant which meets regulatory principles and standards set by the Office for Nuclear Regulation. This impinges its ability to change materials for the nuclear island and surrounding structures. Nevertheless, EDF Energy is proposing to manage and potentially reduce emissions where it is able to. The opportunities proposed for this purpose are highlighted in Part 3 . These include:

Sustainability Statement | October 2011 63

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

• Developing a Sustainable Materials Policy for issue to contractors. The purpose of the list will be to highlight sustainable materials that should be considered, where flexibility exists. • EDF Energy will require that all contractors demonstrate how this policy will be achieved by submitting back to EDF Energy, a strategy that will include information on working with their supply chains, evaluating options for Modern Methods of Construction and diverting local waste streams for re-use. It should be noted that while best endeavours will be made to use green materials, technical and safety requirements will override this ambition in some areas. • EDF Energy will expect that all contractors explore and make maximum use of standardised, prefabricated and modular buildings, particularly that form part of temporary development, to reduce embodied energy in these buildings. • Where practicable and feasible, EDF Energy commits to a neutral cut and fill balance for the majority of associated development sites. This will be possible for park and ride sites and some campuses (except BRI-A and C due to contaminated land), which will limit transport movements and associated emissions. • EDF Energy also commits to a neutral cut and fill balance for the main site, although this target aspiration does not include the handling and removal of contamination. This neutral cut and fill is estimated to save the transportation and disposal of approximately 2 million m 3 of soil. • EDF Energy will try to source materials where possible from the local and national suppliers. However this will not always be possible due to the high specification and highly specialist nature of equipment that will be needed in the construction of a nuclear power station. • EDF Energy will also require that all major contractors (Tier 1) set out a strategy for how emissions will be limited from the delivery of goods and services, and require that such contractors report their direct emissions back to EDF Energy.

f) Integration into the Procurement Process 2.9.36 It is recognised that the Project’s contractors and suppliers will have a significant role in implementing EDF Energy’s sustainability strategy. During the development of specific sustainability opportunities, it was identified that a number of opportunities could be carried forward by contractors and some involved reporting back to EDF Energy on performance. Issues such as monitoring and reporting emissions during construction, consumption of resources, BREEAM and CEEQUAL all depend on the work of contractors. Therefore these matters have been addressed in the procurement process and make a valuable contribution to the sustainable delivery of HPC.

2.9.37 The SLG and the environment team have worked to integrate sustainability into the supply chain at an early stage, developing sustainability criteria within prequalification questionnaires (PQQs) and invitation to tender documents as well as an appraisal process by which the sustainability credentials of the contractors can be assessed. This has and will continue to inform the procurement process.

2.9.38 The procurement process aims to make EDF Energy’s sustainability ambitions clear to potential contractors from the outset and EDF Energy assesses their ability to

64 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

deliver against a number of environmental management issues, EDF Energy’s supply chain management process works to ensure that all contractors comply with the UN Global Compact, of which EDF SA (the parent company of EDF Energy) is a signatory member.

g) Development of an Integrated Management System 2.9.39 It is essential that the sustainability related activities which are proposed through construction, operation and eventually in decommissioning are capable of being effectively implemented, monitored and reviewed. To ensure that there is a mechanism for delivering this, the project team has developed an Environmental Management System (EMS) for the HPC Project. The intention of the EMS is to eventually become third party verified to the ISO 14001 standard. The EMS will allow for the integration of sustainability related initiatives into the management system, which will provide stakeholders assurance that the sustainability initiatives committed to for the project are being implemented, and will also provide a long-term mechanism for sustainability related initiatives to be monitored and reviewed.

h) Monitoring and Reporting 2.9.40 EDF Energy intends to monitor performance and to report sustainability at a number of levels, which reflect different KPI’s as necessary. This will principally include reporting to the local community, site workers during construction, the Local Authorities and as part of the NNB Annual Report. The performance will also be fed back up to EDF Energy, so that this can be factored into reporting of the delivery of its ‘Sustainability Commitments’.

2.9.41 EDF Energy has developed a dashboard of KPIs that it is integrating into the project, by assigning ownership to key teams.

Sustainability Statement | October 2011 65

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

3. SUSTAINABILITY STATEMENT

3.1.1 This part, referred to as the Sustainability Statement, provides a summary of how the Hinkley Point C development complies with the sustainability objectives as outlined in the preceding chapters. It will address the scheme’s performance against the following sustainability themes:

• Air Quality. • Biodiversity and Ecosystems. • Climate Change. • Communities, Population, Employment and Viability. • Communities, supporting infrastructure. • Human Health and Well-Being. • Cultural Heritage. • Landscape. • Soils, Geology and Land use. • Water Quality and Resources. • Flood Risk. • Materials and Waste.

3.1.2 Reference is made to specific sustainability opportunities to address sustainability objectives which have been proposed as part of the HPC Project. Accordingly, this section constitutes an overall summary of performance as set out within the Sustainability Appraisal ( Part 4 ). For further details still, the reader is referred to the Environmental Statement, which addresses these issues as part of the HPC Project’s Environmental Impact Assessment.

3.2 Air Quality

a) Background 3.2.1 Major development can give rise to adverse effects on air quality. Within the Overarching NPS, air emissions are considered as one of a number of generic impacts likely to be relevant to energy infrastructure projects. Construction, operation and decommissioning phases can involve emissions to the atmosphere with potentially harmful impacts on human health, protected species and habitats, or the wider countryside.

3.2.2 According to the Government’s AoS of the Nuclear NPS, the sole objective with regard to air quality is ‘ to avoid adverse impacts on Air Quality' . This objective has been identified at a strategic level to ensure that proposals for new nuclear power stations, including associated construction activities, transport movements and the operation of the facilities, are undertaken in a manner which limits adverse impacts on air quality.

66 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

3.2.3 The purpose of this section is to summarise the potentially relevant policy drivers and key issues relating to air quality and how these have been addressed in the proposed development in the context of sustainability. It will also comment on further relevant sustainability opportunities that have been identified by EDF Energy.

b) Policy Drivers 3.2.4 The Overarching NPS identifies factors which should influence IPC decision making with regard to air quality. Thus, the IPC should:

“generally give air quality considerations substantial weight where a project would lead to a deterioration in air quality in an area, or leads to a new area where air quality breaches any national air quality limits. However air quality considerations will also be important where substantial changes in air quality levels are expected, even if this does not lead to any breaches of national air quality limits……In all cases the IPC must take account of any relevant statutory air quality limits. Where a project is likely to lead to a breach of such limits the developers should work with the relevant authorities to secure appropriate mitigation measures to allow the proposal to proceed. In the event that a project will lead to non-compliance with a statutory limit the IPC should refuse consent”. (Paragraph 5.2.9 and 5.2.10)

3.2.5 Consideration has also been given to regional and local planning policy drivers to take account of potentially relevant local issues. At these levels, policy objectives for air quality aim to reduce impacts from new development, especially the impacts on Air Quality Management Areas (AQMAs) where poor air quality is already a significant concern. The regional planning policy in Policy EN2: Air Quality of RPG10 is aligned with these objectives. At the local planning level, the West Somerset Local Plan includes saved policies to protect human health and property from impacts of air quality by ensuring the appropriate siting and layout of development. The emerging Sedgemoor LDF Core Strategy (Proposed Submission) includes policies for air quality; stating that development proposals likely to result in harmful levels of air pollution threatening other land uses, human health, tranquillity, or the built and natural environment will not be supported.

c) Sustainability Performance i. The HPC Development Site and On-site Associated Development 3.2.6 The AoS Site Report for Hinkley Point, undertaken by the Government, concluded that the development of Hinkley Point would lead to potential sustainability issues for air quality. Key ‘strategic’ issues included the potential for related impacts upon national and European designated wildlife sites, due to increases in airborne pollutants and nutrients during the construction phase. This potential impact has been identified within air quality assessments presented in Volume 2, Chapter 12 of the Environmental Statement , where results of pollution deposition at ecological receptor locations are presented. The significance of this has been evaluated within the Terrestrial Ecology and Ornithology chapter Volume 2, Chapter 20 of the Environmental Statement . Further information is provided there.

3.2.7 The AoS of the Nuclear NPS also referred to the potential for accidental releases of radioactive emissions which could have a strategically significant effect on air quality.

Sustainability Statement | October 2011 67

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Whilst accidental leakages of radioactive material could have significant repercussions for air quality, the UK Nuclear Industry is highly regulated, and emissions strictly controlled. The AoS of the Nuclear NPS therefore recognised that adequate procedures are in place to minimise risk in this area.

3.2.8 Furthermore, while the development of a new nuclear facility at HPC will involve limited aerial discharges of non-radioactive substances including PM, CO, NOx, SO 2, H2CO, NH 3 during commissioning and operation, it can be expected to make significantly fewer emissions of air quality pollutants such as NOx and SOx per kWh than a coal or gas fired power station. From a strategic perspective, the development of new nuclear as opposed to fossil fuel electricity generation, could be expected to lead to a benefit for air quality. Further details of the emissions from the HPC Project are provided within the Environmental Statement.

3.2.9 A primary issue for consideration by the IPC will be the potential for the project to exceed local air quality thresholds, put in place to protect human health and amenity. Exceedences of such thresholds are typically managed through the designation of an AQMA. The HPC development site is located in a predominantly rural setting on the coastline of Bridgwater Bay. There are no AQMA’s located within or in proximity to it. Furthermore, construction and operational impacts for the HPC Project have been assessed as part of the EIA, and expected emissions from all activities are not considered likely to contribute significantly to existing pollutant levels so as to warrant the designation of an AQMA.

3.2.10 In any case, EDF Energy is considering a series of measures to limit impacts on air quality. These will be adopted in construction, and will continue to be delivered throughout operation. Examples include:

• Using the logistics strategy to reduce potential impacts from vehicles amassing at the HPC development site during construction and causing congestion on local roads, particularly in Bridgwater. This includes management measures and new infrastructure including freight management facilities and park and ride facilities to consolidate freight and worker vehicles respectively. • Developing Air Quality Management Plans (AQMP) for the Preliminary Works and Development Site. • Designing emissions stacks so as to achieve effective dispersion of emissions to the atmosphere. • Making provision for the potential use of electric vehicles at the main site in the form of ‘passive’ provision to enable electric charging to be incorporated in the foreseeable future.

ii. Off-site Associated Development 3.2.11 The construction, operation and any removal and restoration of the proposed off-site associated developments has potential to impact air quality. Due to the varying types of development proposed, and recognising the diverse location of these developments, implications for air quality as a sustainability issue are varied. In general, however, the construction of the development may be seen to have a negative impact on the air quality sustainability objective. The adoption of Air Quality Management Plans, which identifies mitigation and best practices to be adopted will assist to reduce impacts. Table 3.1 provides commentary on the different air quality

68 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED issues and opportunities identified for off-site associated development for the various proposals. Further information on specific design proposals is also available within the Design and Access Statements.

Table 3.1: Summary of Air Quality Issues and Initiatives for Off-Site Associated Development & HPC Accommodation Campus Associated Key Sustainability Issues and Initiatives Proposed Development Site Accommodation Impacts on air quality have been assessed both during construction, Campuses operation and post-operational phases. The greatest impacts are expected to arise from construction activities and also during the operational phase from road traffic (for Bridgwater sites). In each case, the contractor would adopt various good practices through following the HPC Off-Site Associated Developments AQMP, which will include monitoring and controlling dust in accordance with BREEAM (Man 3). The energy technologies used at the sites would have no impact on air quality at site. None of the campuses would have a gas supply, ensuring that no direct combustion will occur directly on these sites. Each campus would make use of air source heat pump systems (ASHPs), which provides hot water. ASHPs are however driven by electricity derived from the National Grid. This is attributable to the generation of NOx and other air pollutants elsewhere. For each site, measures are being put forward to reduce emissions of air pollutants. These are further detailed in the Environmental Statement and the BREEAM Predictive Assessments appended to the Design and Access Statements. These include: • best practice measures to suppress dust during construction; • avoidance of VOC’s (Volatile Organic Compounds) in paints and finishes in accordance with BREEAM; • proposals for car sharing, with a car parking ratio of 1:1.6 and the provision for cycle storage for 5% of the units; and • the workforce would be required to use buses at Bridgwater A and C to transport them to the construction site, and are expected to make use of public transport outside of work hours. Cannington Bypass Typically, the construction of any road will lead to increases in emissions including air pollutants. Consequently, the location of the bypass will have a negative impact on air quality in the vicinity of the proposed route. This will occur both during construction and operation. The proposals would, however, divert traffic from the centre of Cannington, which could contribute to improving air quality within the village. The design of the bypass incorporates a cycle lane and a reduced speed limit of 40 mph in order to help offset air quality impacts. Cannington Park and The park and ride facility is proposed to consolidate traffic, reduce trips on Ride the highway network and therefore would deliver a number of benefits, including relative benefits on air quality during the construction of the HPC Project. Travel planning initiatives are being promoted to reduce the number of car journeys to the park and ride sites, thus reducing unnecessary single occupancy car journeys. Combwich wharf Combwich Wharf would play an ongoing role for EDF Energy during the refurbishment and construction and operation of HPC. Upgrades to the existing Wharf would extension and ensure that the site can receive AILs and construction materials. The associated freight operation of the wharf will reduce air quality impacts from traffic otherwise laydown facility using local roads. Notwithstanding, the construction of the laydown facility will require a

Sustainability Statement | October 2011 69

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Associated Key Sustainability Issues and Initiatives Proposed Development Site substantial volume of new material to be imported by road for the purposes of raising the site, which would have a negative relationship with the sustainability objective. This would also have an impact during the sites restoration, where material will be removed again, potentially also by road although options will be explored to use the wharf for this purpose. The operation of the laydown facility will receive materials both by road and by sea. M5, Junction 23 Park For this Sustainability Statement, the implications of both Junction 23 and and Ride, Freight 24 on air quality have been considered together, although it is important to Management and note that due to the re-use of an existing site, air quality issues for Junction Postal/Courier 24 could be expected to be less than Junction 23 in construction. Consolidation Facilities As a general principle, the freight management facilities are intended to and Induction Centre provide a physical control mechanism, required to regulate the flow of vehicles through Bridgwater to the HPC development site. The facilities are both located in close proximity to strategic transport network, aiding this M5, Junction 24 Park further. and Ride and Freight Management Facilities Transport logistics including a Delivery Management System (DMS) would and Temporary be used to facilitate the efficient movement of freight (avoiding Postal/Courier unnecessary idling of vehicles and allowing vehicle movements to be timed Consolidation Facility to avoid periods of congestion). This should provide indirect benefits for air and Induction Centre quality and on roads in Bridgwater. The postal/courier delivery centre will consolidate Light Goods Vehicles (LGV’), which will also assist to further

reduce impacts. The park and ride facilities are intended to consolidate traffic, and therefore deliver a number of benefits, including relative benefits on air quality during the construction of HPC. Travel planning initiatives are being promoted to reduce the number of car journeys to the park and ride sites, thus reducing unnecessary single occupancy car journeys. The Junction 24 site would be delivered first, picking up vehicles travelling south on the M5, this would be operated at full capacity temporarily, until the Junction 23 site becomes operational and is able to pick up the majority of vehicles travelling south on the M5. This location, coupled with the ability to make use of the site rapidly and with limited construction work will assist to reduce emissions associated with road traffic in the early years of construction of the main site. Both sites include cycle parking at a ratio of 5% of car parking spaces at the park and ride facilities and further spaces for the freight management facilities and induction centres. Williton Park and Ride The park and ride facility is proposed to consolidate traffic, reduce trips on the highway network and therefore deliver a number of benefits, including relative benefits on air quality during the construction of the HPC Project. Travel planning initiatives are being promoted to reduce the number of car journeys to the park and ride sites, thus reducing unnecessary single occupancy car journeys. As added benefit, the location of the site, on brownfield land, reduces construction work needed and subsequently will assist to reduce emissions at this stage.

d) Summary 3.2.12 Given that the proposals for the HPC Project will comply with statutory air quality limits, and that all impacts on air quality, both on and off-site will be managed to reduce impacts as far as possible, in may be seen that in general, the proposals are considered to work towards the Sustainability Objective: ‘To avoid adverse impacts

70 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

on air quality’. However, given that certain adverse impacts will remain, it cannot be claimed that the project will fully meet this.

3.2.13 The Sustainability Appraisal outlines there would be a negative impact on this objective during construction (short-term), particularly due to worker movement and dust. According to the EIA, these impacts are typically of low significance following the application of mitigation, implemented through AQMPs. Further information is available within the Environmental Statement, which outlines the assessment of impacts.

3.2.14 During operation (medium-term) the relationship with the sustainability objective is generally positive with regard to air quality, particularly given that HPC will release relatively fewer air quality pollutants, such as NOx and SOx, by comparison to other forms of fossil fuelled power generation. However, certain elements of the project, particularly operation of the Cannington bypass, will continue to create air pollution. In these cases EDF Energy has clearly taken steps to reduce impacts in accordance with the sustainability objective. Beyond this, it is anticipated that there will also be a negative impact during decommissioning (long-term) due to the impacts of deconstruction activities on air quality. Overall, given that there are limited significant impacts on air quality during construction and operation, and considering the measures that EDF Energy will employ to reduce impacts on air quality, the appraisal finds that there will be a neutral relationship with the objective.

3.3 Biodiversity and Ecosystems

a) Background 3.3.1 The Government’s Sustainable Development Strategy (2005) ‘Securing the Future’ states one of the five guiding principles for delivering sustainable development is living within our environmental limits, defined as:

“Respecting the limits of the planet’s environment, resources and biodiversity – to improve our environment and ensure that the natural resources needed for life are unimpaired and remain so for future generations”.

3.3.2 The Government’s AoS of the Nuclear NPS identifies three objectives for Biodiversity and Ecosystems:

• to avoid impacts on the integrity of wildlife sites of international or national importance; • to avoid impacts on priority habitats and species, including European protected species; and • to avoid impacts on valuable ecological networks and ecosystem functionality.

3.3.3 The siting of nuclear power stations often conflicts with biodiversity and ecosystem objectives, in part due to the demographic principle applied within the Strategic Siting Assessment to locate such facilities away from urban areas. In such areas, ecological assets are commonly more prevalent. There is also an operational preference to locate these facilities in coastal areas or near significant bodies of water for cooling water infrastructure, which may often provide valuable natural habitats. The importance given to ecological considerations is reflected in a number

Sustainability Statement | October 2011 71

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

of statutory and non-statutory instruments, ranging from international agreements for the protection of internationally significant habitats and species, through to local planning policy objectives, intended to preserve and enhance valuable wildlife areas. Accordingly, the effect of the proposed NSIP on biodiversity and ecosystems has been considered both in the EIA and a Habitats Regulations Assessment (HRA). The performance against the sustainability objectives is summarised within this Sustainability Statement

b) Policy Drivers 3.3.4 The Overarching NPS sets out key principles for the IPC’s consideration with regard to biodiversity and geological conservation. These relate to sites of varying significance for biodiversity value, from international sites, through to biodiversity within developments. The policy document states that:

“As a general principle, and subject to the specific policies [outlined within the Overarching NPS], development should aim to avoid significant harm to biodiversity and geological conservation interests, including through mitigation and consideration of reasonable alternatives; where significant harm cannot be avoided, then appropriate compensation measures should be sought... In taking decisions, the IPC should ensure that appropriate weight is attached to designated sites of international, national and local importance; protected species; habitats and other species of principal importance for the conservation of biodiversity; and to biodiversity and geological interests within the wider environment”. (Paragraph 5.3.7 and 5.3.8)

3.3.5 Other potentially relevant regional policy is found in Policy EN1 of RPG 10 which emphasises protecting and enhancing the region’s landscape, nature conservation sites and biodiversity. WSC and SDC’s respective Local Plans include policies which express the need to protect ecologically valuable sites and species outside nationally designated areas. Further information on the relevant policy drivers is found within Part 4 .

c) Sustainability Performance i. The HPC Development Site and On-site Associated Development 3.3.6 The Government’s AoS objectives of the Nuclear NPS focus on protecting existing features of national or international significance. A number of ecological studies have been conducted to determine the impacts of the project on terrestrial, marine and coastal ecology during the construction and operation of the HPC Project. The findings of these studies, and proposals for mitigation and where possible enhancements, have informed this Sustainability Statement.

3.3.7 The strategic issues identified within the Government’s AoS Site Report for Hinkley Point included:

• Visual and noise disturbance of important bird populations associated with the Severn Estuary SPA/Ramsar Site, and Bridgwater Bay SSSI and migratory fish populations associated with the River Wye SAC and River Usk SAC; • Direct loss and fragmentation of priority habitats including species rich hedgerows, and neutral grassland.

72 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

• Direct loss of designated foreshore, inter–tidal and sub-tidal habitats within the Severn Estuary.

3.3.8 Consideration was also given to air quality impacts upon the national and European designated wildlife sites.

3.3.9 These impacts have been fully evaluated within the EIA and have been the subject of an Appropriate Assessment as part of the HRA. The main findings are summarised below against the sustainability objectives of relevance to the project.

ii. To Avoid Impacts on the Integrity of Wildlife Sites of International or National Importance 3.3.10 There are a broad range of national and internationally designated sites in the vicinity of the HPC development site. Development at the scale required for the HPC Project within and around these sensitive areas has the potential to cause direct conflict with this sustainability objective. However, in general, it is considered that the significance of impacts on ecological receptors will be limited to ‘minor’ due to the application of mitigation measures, and at this stage It is not considered that the impacts identified will affect the ‘favourable’ conservation status of the internationally important wildlife designations.

3.3.11 EDF Energy has completed extensive studies of the Severn Estuary as part of ongoing work for the HRA. This has involved over four and a half years of scientific studies, looking at the complexity and interrelationship of foodwebs within the Severn Estuary to understand how the construction and operation of HPC may impact the integrity of the European wildlife site. Key areas of focus included fish entrainment from the cooling water infrastructure, and the impacts of thermal and chemical discharges from cooling water infrastructure.

3.3.12 An example of how EDF Energy has taken measures to meet this sustainability objective can be seen in the design of the cooling water infrastructure. It is recognised that the discharge of warm water into Bridgwater Bay has the potential to impact the marine environment. Measures have been taken to ensure that temperature changes to the marine environment are minimised as far as possible, which will be achieved by sensitive siting of the cooling water infrastructure. Other measures include:

• the provision of Acoustic Fish Deterrence (AFD) systems; • the utilisation of Fish Recovery and Return (FRR) systems; and • careful sitting of the temporary jetty.

3.3.13 It is also important to consider that the operation of nuclear power from HPA and HPB has occurred for over 45 years. Studies of Bridgwater Bay mudflats have shown no obvious effects of HPB operations on the species populations present.

iii. To Avoid Impacts on Priority Habitats and Species, including European Protected Species 3.3.14 The principal ecological issue identified which has a negative influence on this objective is the potential disturbance leading to displacement of bird populations within the Severn Estuary SPA, Ramsar Site and the Bridgwater Bay SSSI. The UK

Sustainability Statement | October 2011 73

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

hosts a significant number of internationally important wetland birds, and the Severn Estuary is identified as being particularly species-rich area within the UK, due to the extensive inter-tidal wetland habitats that are found there. Mitigation measures have been proposed to reduce predicted impacts, which could otherwise arise during construction, including in particular the application of sensitive construction timing and careful selection of construction methods to reduce visual and noise disturbance to wetland birds.

3.3.15 Further impacts on priority habitats and species have been summarised within the Sustainability Appraisal ( Part 4 ). For a full account, the reader is referred to the Environmental Statement Volume 2, Chapter 19 (Marine Ecology ) and Volume 2, Chapter 20 (Terrestrial Ecology and Ornithology ).

iv. To Avoid Impacts on Valuable Ecological Networks and Ecosystem Functionality 3.3.16 The development proposals will result in the permanent loss of approximately 67.5ha of greenfield land at the HPC Site. However significantly more land will be affected during construction (175.2Ha). The value of this land as a valuable ecological network has been considered within the EIA. The majority of it is utilised for agricultural purposes, and the significance of the loss is consequently generally reduced. Areas that offer ecological networks, such as linear hedgerows and watercourses will be lost, but proposals exist to minimise impacts by maintaining hedgerows and creating woodland and grassland habitats where practical during construction, and creating a new ecological network (comprises woodland, grassland, hedgerows and wetland areas) after construction. This will provide net improvements to biodiversity long-term. Further information on this is provided within the Environmental Statement and detailed within the HPC Landscape Strategy.

3.3.17 As summarised above and further identified within the EIA, where possible EDF Energy will adopt measures to ensure these losses are minimised. This will include EDF Energy adopting a wide range of careful construction methods, ensuring impacts are limited as far as possible.

3.3.18 Furthermore, whilst the sustainability objectives are geared towards protection of biodiversity assets, EDF Energy is committed to enhancing ecological value where practicable, in accordance with regional and local planning policies. A range of initiatives have been identified so that locally valuable habitats and species can be maintained and enhanced. An example of this is the proposal to extend the existing Biodiversity Management Planning operation at Hinkley A and B to include HPC. This will ensure that the re-establishment of biodiversity is promoted as far as possible.

3.3.19 As safety and security requirements for the nuclear site licence are strict, there is limited scope to provide ecological enhancements at particular locations within the permanent development site, especially the nuclear island. Restrictions on even basic landscaping preclude the opportunity for ecological enhancement within this area. However it is proposed to plant to the south of the development site, so as to act as a visual barrier from residents of Shurton whilst also providing ecological connectivity. Planting will comprise native tree and shrub species. There will also be significant habitat creation in the construction area following construction of HPC, as part of the restoration strategy. In combination, the resulting habitat creation will

74 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

deliver a net increase in tree planting as a result of the project, and a gain in biodiversity. Other key proposals include:

• Maintenance of ecological connectivity through the site during construction by protecting and enhancing ecological corridors. • Design of the landscape restoration strategy to be employed after construction activities have ceased so as to provide habitats suitable for the protected and notable species currently found on the HPC development site. These include badgers, a range of bat species, and slow-worms. The strategy includes creation of an extensive mosaic of semi-natural habitats which will provide suitable habitat for a wide range of native species, including increasing areas of woodland and calcareous grassland. • Enhancements to benefit farmland birds, including the sowing of a field of annual bird cover crop and providing winter feed. • Installation of bird boxes across the site, including boxes specifically for barn owls. • Provision of a purpose built ‘bat barn’ to provide enhanced roosting opportunities for bats. • Implementation of green roofs on certain key buildings around the permanent development site. EDF Energy has undertaken a feasibility study to identify which green roof systems to apply, and it is anticipated that a sedum type system will be most practical given considerations to environmental conditions and maintenance requirements. In total, over 14,000 m 2 of roof space will be given to these green roofs systems. Further details are provided within the HPC Development Site Design and Access Statement .

v. Off-site Associated Development 3.3.20 The effects of the off-site associated development have also been considered against the sustainability objectives ( Table 3.2 ). In general, due to the smaller scale of construction proposed and the fact that these developments are mostly located within and around existing settlements, there is more often a neutral or even positive relationship between these sites and the sustainability objectives. Notable exceptions include the impacts from construction of the Cannington bypass, which could impact protected species, and the refurbishment and extension works associated with Combwich Wharf, which could impact upon nationally significant wildlife sites. However, the application of design measures at each site will reduce impacts, and in both cases the impacts from the proposals on protected wildlife or their habitats are not considered significant.

3.3.21 Across all sites a range of appropriate mitigation measures will be applied, as indicated in Subject Specific Management Plans. As an illustration:

• An Ecological Clerk of Works (ECoW) will be available to supervise and provide advice as identified. • All of the sites have the potential to support breeding birds. Appropriate timing of construction work outside of the bird breeding season (generally March – August) is proposed to minimise the risk of contravening the relevant legislation. Further, should vegetation clearance be required during this period, a suitability qualified ecologist would survey the vegetation prior to its removal in order to check for the

Sustainability Statement | October 2011 75

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

presence of active nests. If an active nest is found, this would be left undisturbed until the young have fledged. This measure will be implemented at all sites.

3.3.22 Some of these measures extend beyond legal requirements of protection, contributing to overall ecological improvement. However the biodiversity measures that EDF Energy propose will ensure that development does not contravene the Wildlife and Countryside Act (1981) (WCA) (Ref 3.1), the Habitats and Species Regulations (2010) (Ref. 63) and Protection of Badgers Act (1992) (Ref. 64).

Table 3.2: Summary of Ecological Impacts and Identified Mitigation for Off-Site Associated Development & HPC Accommodation Campus Associated Key Sustainability Issues and Initiatives Proposed Development Site Accommodation Each accommodation campus is subject to a BREEAM assessment and Campuses as such, the sites have been assessed by a suitably qualified ecologist for this purpose. These are also subject to specific assessments as part of the EIA (see Chapter 20, Volume 2 and Chapter 14, Volumes 3 and 4 ). Both the Bridgwater A and Bridgwater C accommodation campuses are on brownfield sites, and have been judged to have low ecological value for this purpose. Of key conservation concern at Bridgwater A are reptiles, breeding birds and bats. Measures have been developed to protect these species during works. At Bridgwater C, consideration has been given to breeding birds. Appropriate measures have been developed here also. The HPC campus is located on greenfield land, but entirely on land used for agriculture and includes no trees. This site does however have some limited ecological value. Each site would be designed to enhance biodiversity, although the approach taken is dependent on the nature of the site’s post-operational use: • Bridgwater C includes proposals to offer ecological enhancements during its operation. • Bridgwater A includes some perimeter landscaping features that would be retained in the sites post-operational phase. • The HPC accommodation campus will include basic landscaping. However this will be supplemented post-operation through the implementation of a landscape restoration strategy, which will see additional tree and shrub planting and other ecological enhancements. Further details are provided in the relevant Design and Access Statements. Cannington Bypass The proposed route has been chosen to minimise impacts on biodiversity by comparison to other options (identified at Stage 1 consultation), although the development would inevitably result in habitat loss along the route (hedgerows and trees/scrub). Several protected species are found within the site area, notably bats (including barbestrelle), great crested newt, badger and otter. Appropriate measures have been developed within the scheme design, including the provision of wildlife crossings as well as new landscape planting and balancing ponds which will be ecologically beneficial. In the longer term, the development of the bypass is expected to have a minor beneficial impact on priority habitats and species, and would strengthen ecological corridors. Cannington Park and The site comprises one species-poor, closely-grazed improved grassland Ride field, which is surrounded by ditches and hedgerows. With regard to species, surveys carried out at the site indicated the presence of legally protected species, comprising breeding birds, badger, and slow worms.

76 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

3.3.23 Appropriate design measures have been developed to take account of these. Further, the landscape strategy for the site would minimise loss of habitats through supplementary planting and adopting management regimes that enhance biodiversity. Combwich wharf Impacts from refurbishment and extension to Combwich Wharf and refurbishment and associated freight laydown facilities may also conflict with objectives to extension and avoid impacts on priority habitats and species, including European associated freight protected species through disturbance. However considering the design laydown facility measures incorporated into the scheme and the additional mitigation measures, this conflict is limited. The Severn Estuary, Ramsar, SPA and SAC are adjacent to the site. There are potential effects on the interest of the area through the construction phase, primarily from disturbance leading to displacement of birds and also during the operational phase during the transportation and offloading of abnormal loads. Mitigation will include controls on lighting, restricting personnel movements and sensitive piling work. Other potential receptors include reptiles, otter, and water vole. Appropriate design measures have been developed for these species also. Direct and indirect loss of habitat will occur in the construction of the freight laydown facility, including grassland and hedgerows. Although open water ditches exist on the site, these will be largely protected, with minimal culverting. Such features will also be fenced during the sites operation. M5, Junction 23 Park The site comprises grazed, improved grassland fields and a large area of and Ride, Freight ruderal vegetation. The fields are separated by hedgerows, and a single Management and pond is located within the site. Biodiversity receptors identified at the Postal/Courier Junction 23 facilities are breeding birds, wigeon, badger, bats, water vole, Consolidation Facilities great crested newts, and grass snakes. Appropriate design measures and Induction Centre have been developed to minimise impacts on these species. Biodiversity gain will also be delivered through the creation of three new wildlife ponds and associated rough grassland and scrub that will be retained throughout all phases of the development. M5, Junction 24 Park The site is predominantly hardstanding and buildings with limited and Ride and Freight biodiversity value. Breeding birds may occur in the small amounts of scrub Management Facilities and few mature trees present. Appropriate design measures have been and Temporary developed. In general the sustainability objectives are supported. Postal/Courier Consolidation Facility and Induction Centre Williton Park and Ride The site supports limited features of biodiversity interest, restricted to the potential for breeding birds to occur in the surrounding existing landscape planting. Existing landscaping will be retained and supplemented. As identified within Table 3.2, the principal conflict with the sustainability objectives will be the impacts on ecological networks and ecosystem functionality, through the loss of hedgerows, semi-natural habitats and trees. However the impacts will be managed through retention of key features and appropriate substitution planting on the scale that will reduce the impact on these features.

3.3.24 In addition, EDF Energy is committed to delivering ecological enhancements as part of the off-site associated development. The way in which this is achieved, and the extent to which this will be provided is influenced by the post-operational strategies of the sites. However in general EDF Energy are setting out to achieve a net gain in biodiversity, either during the sites’ operation in the case or permanent development, or upon restoration, in the case of temporary development. The degree to which this is achieved varies from site to site.

3.3.25 Typical proposals include:

Sustainability Statement | October 2011 77

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

• consideration for species-rich landscaping, with a high proportion of native stock; • a range of site specific biodiversity enhancements; and • where possible, the utilisation of surface water features such as ponds and swales for combined ecological/sustainable drainage benefit, although such benefits may often only be temporary.

3.3.26 Further details on the design measures proposed to achieve a net gain in biodiversity value for the site are set out within the relevant Design and Access Statements.

d) Summary 3.3.27 The SSA process identifies Hinkley Point to be a suitable location for new nuclear power. The performance of the proposals against these objectives for biodiversity and ecosystems is a complex issue to consider, simply because the proposals could lead to the loss of, and impacts on, a varied number of habitats and species, some of which can be avoided, minimised or mitigated for more easily than others.

3.3.28 EDF Energy has demonstrated through the EIA that the majority of significant adverse effects have been reduced through scheme design and mitigation where required. For example, the majority of habitats and species that will be damaged or displaced will be managed through various proposals for careful construction and habitat recreation, thus reducing the significance of the impacts. Furthermore, the primary impacts identified to have an effect on the integrity of internationally or nationally significant wildlife sites are not expected to significantly affect the ‘favourable’ conservation status of the internationally important wildlife designations, which is a particular focus for the IPC. This is subject to the outcome of the Habitats Regulations Assessment (HRA). 3.4 Climate Change

a) Background 3.4.1 Research over recent decades demonstrates a rise in global temperatures over the last 150 years. The Stern Review Report (2006) (Ref. 65) identifies that the scientific evidence supporting climate change is overwhelming: climate change presents very severe global risks, and demands an urgent global response. Climate change will have numerous impacts in the UK, such as warmer, wetter winters and hotter, drier summers. These changes will prompt increasing risk of floods, droughts and overheating (through higher temperatures). Scientific consensus attributes this change to emissions of Greenhouse Gases (GHGs), primarily carbon dioxide (CO 2) from the combustion of fossil fuels. In 2009, the UK’s net emissions of CO 2 were estimated to be 473.7 million tonnes (Mt). The largest proportion of GHG emissions (35%) was from the energy supply sector, the remaining from road transport (22%), business (15%) and the residential sector (14%) (Ref. 66). The Government AoS of the Nuclear NPS identified a single climate change objective: ‘ to minimise greenhouse gas emissions’ . A wide range of legislative provisions, policies and targets are in place which require the UK to deliver this objective.

3.4.2 A major focus in tacking climate change has been on mitigation; taking action to reduce emissions. However, if current trends persist, average global temperatures will rise within the next fifty years and therefore, in addition to mitigation measures, climate change adaption is also required to deal with the unavoidable effects of

78 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

climate change. Adaption is the only response available for the impacts that will occur over the next several decades before mitigation measures can have an effect, and requires that EDF Energy addresses the risks of climate change through a robust design response.

3.4.3 Accordingly, in addition to the contribution the HPC Project will have towards decarbonisation, EDF Energy also recognises that the sustainability of HPC is intrinsically linked to its resilience to the effects of climate change. Whilst this is not a sustainability objective in its own right, it is of significant importance for the overall sustainable outcome of the project. This involves designing HPC to ensure it can cope with and be adaptable to the predicted effects of climate change, and that it is resilient to increases in extreme weather events such as storms, floods and droughts. Recent experience at Fukushima has re-emphasised the over-riding importance of this issue for nuclear developments.

b) Policy Drivers 3.4.4 Policies for climate change are imposed by all levels of Government and have been given statutory force in the Climate Change Act (2008). Such policies address climate change both in terms of mitigation, whereby policies are in place to reduce emissions, but also for adaption, whereby policies seek to make development resilient to the effects of future climate change. Tackling first mitigation, the UK’s strategy for climate and energy, the Low Carbon Transition Plan, was published in July 2009. In relation to the power sector, it states:

“Currently three quarters of our electricity is generated using coal and gas. By 2050 we may need to produce more electricity than we do today but must do so largely without emitting GHGs. So we will need to transform our system so that electricity is generated from clean sources such as renewables, nuclear and fossil fuel plants fitted with carbon capture and storage technology...”

3.4.5 PPS 1 - Sustainable Development (2006) and the Supplement to PPS 1 - Planning and Climate Change (2007) require that planning contributes to the reduction in emissions, helps to stabilise climate change and takes into account its unavoidable consequences. The Government also consulted on a revised PPS, Planning for a Low Carbon Future in a Changing Climate (2010), which is set to amalgamate the Supplement to PPS1 with PPS 22 - Renewable Energy (2006) in a single document.

3.4.6 Regional Policy RE6: Energy Generation and Use in RPG10 states that local authorities, energy suppliers and others should support and encourage the region to meet the national targets for reductions in GHG emissions by 2008-2012 and for carbon dioxide emissions by 2010. A number of other policy documents operate at the regional level, including the South West Climate Action Plan 2008 – 2010.

3.4.7 WSC and SDC planning policies aim to reduce emissions by ensuring that new development is designed to high standards of sustainable design and construction. For example, carbon reduction in built design should be achieved consistent with the national building regulations (emerging Policy D3, Sedgemoor LDF Core Strategy (Proposed Submission)), which will involve a holistic approach is taken to reducing emissions, including the utilisation of low carbon and renewable energy. Sustainable design codes, such as BREEAM, are also supported.

Sustainability Statement | October 2011 79

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

3.4.8 In addition to establishing a legal framework for mitigating emissions, the Climate Change Act has also introduced a new power for the Secretary of State to direct “reporting authorities”, which includes EDF Energy as a provider of energy infrastructure, to prepare reports on how they are assessing and acting on the risks and opportunities from a changing climate.

3.4.9 The Overarching NPS sets out the need to consider climate change adaption in the development of new energy infrastructure, it states:

“New energy infrastructure will typically be a long-term investment and will need to remain operational over many decades, in the face of a changing climate. Consequently, applicants must consider the impacts of climate change when planning the location, design, build, operation and, where appropriate, decommissioning of new energy infrastructure.” (Paragraph 4.8.5)

c) Sustainability Performance i. The HPC Development Site and On-site Associated Development 3.4.10 As stated above, the proposals for the generation of nuclear power are supported at the national level by policies in the Low Carbon Transition Plan and Nuclear NPS. Nuclear power is a low carbon technology, with operating CO 2 emissions comparable to offshore wind energy (Ref. 67). Nuclear power is able to provide a reliable source of electrical energy and is generally advantageous relative to wind energy in providing reliable reactive power to support the National Grid. The proposals for the HPC Project would be for two UK EPR units, generating 1,630MW (net) of low carbon electricity per unit. The electrical output will provide a low carbon source for over 6% of the UK’s electricity demand, and is expected to offset approximately 10 million tonnes of CO 2 per annum by displacing the existing mix of more carbon intensive electricity from the National Grid 3. The development of the HPC Project will therefore play a significant role in the UK’s transition to a low carbon economy, assisting the UK to meet its low carbon budgets and demonstrating consistency with the overarching sustainability objective: ‘ to mitigate climate change’ .

3.4.11 Whilst the generation of low carbon energy will have significant benefits for climate change mitigation, EDF Energy has also considered further opportunities to deliver this sustainability objective in the design and construction of buildings and infrastructure. This is explained in further detail in the HPC Development Site Design and Access Statement .

3.4.12 A summary of the proposals include:

• The land platform with which the nuclear island will be located will be approximately 14m AOD. This height has been optimised to avoid flood risk without excessively increasing the energy required to pump cooling water through the condensers. • Creating a neutral cut and fill balance across the main site (excluding hazardous waste), helping to reduce freight movements.

3 The carbon calculations which have informed this figure are available in Annex 1 .

80 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

• Once HPC is operational, site buildings will be powered by electricity derived from the generation process. This electricity is low carbon (4.8gCO 2e/kWh), which is significantly lower than the emissions attributed to grid electricity of 517gCO 2/kWh (as quoted in Part L of the Building Regulations 2010). Furthermore, because of its location in the southwest of the UK, electricity generated at HPC will reduce long-distance power flows through the National Grid and hence reduce the energy dissipated as transmission losses, which promotes energy efficiency. • EDF Energy will include the necessary cable work and ducting at the HPC development site during construction to facilitate the low carbon decommissioning of HPB. Whilst EDF Energy cannot guarantee that this will be adopted by the Nuclear Decommissioning Authority (NDA) in its decommissioning strategy, the infrastructure provides the NDA with the flexibility and opportunity to do so.

Consideration of CHP 3.4.13 The Overarching NPS states that Combined Heat and Power (CHP) must be considered alongside any proposals for thermal generating stations. The Statement advises:

“Utilisation of useful heat that displaces conventional heat generation from fossil fuel sources is to be encouraged where, as will often be the case, it is more efficient than the alternative electricity/heat generation mix… Substantial additional positive weight should therefore be given by the IPC to applications incorporating CHP…” (Paragraph 4.6.8)

3.4.14 The Nuclear NPS goes on to state that:

“In keeping with applications for other thermal generating stations, development consent applications for nuclear power stations should demonstrate that the applicant has fully considered the opportunities for CHP… However, the economic viability of CHP opportunities (see Paragraph 4.6.5 of NPS EN-1 for further details) may be more limited for new nuclear power stations because the application of a demographic criterion for new nuclear power stations can result in stations being located away from major population centres and industrial heat demand. Future industrial, residential or commercial developments may also be constrained to preserve the general characteristics of the area around the nuclear site throughout its lifecycle to ensure that the basis on which the site is licensed is not undermined.” (Paragraph 2.9.2 and 2.9.3)

3.4.15 EDF Energy has commissioned a study to identify the possibility of incorporating CHP into the power generation process (Ref 3.7). The study sets out to identify whether CHP would be economically viable for the Hinkley Point C (HPC) Project, and further identifies potential future users of heat.

3.4.16 From a practical perspective, the distance to which heat can be transferred from the HPC permanent development site is limited by various technical and economic parameters. EDF Energy’s study established a search area using a 15 Km radius around the HPC Development Site, which enables consideration of potential heat demands in Bridgwater and Burnham-on-Sea. The heat demands within the search area were split into two groups, existing buildings and potential future developments. These were further split between different sub-groups, looking at housing, education

Sustainability Statement | October 2011 81

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

leisure, healthcare commercial and industrial uses. Future demands were assessed based on a range of data sources, including consultation with the local authorities and the review of material available, such as land supply reports for Sedgemoor. From this, heat demands were estimated taking account of published benchmark data.

3.4.17 As a first conclusion, it would clearly be impractical and uneconomic to connect every heat demand within the 15Km search area. This would require significant investment in infrastructure to support what were often identified to be isolated developments. Accordingly, potential users were eliminated on a case by case basis, with the aim of developing ‘clusters’ of heat users. This minimises infrastructure costs and distribution losses. This process identified two potential clusters for a district heating network, the first located in Bridgwater and Cannington, the second; Burnham-on- Sea and Highbridge. The latter cluster was anticipated to be less viable because of its smaller size as well as other environmental and engineering constraints, including the necessity to cross the River Parrett.

3.4.18 In each case, the study considered an optimistic scenario for uptake of a future district heating network, assuming that 100% of the estimated heat demand could be met in this way. However, the study also assessed more realistic scenarios whereby only 75% connection was attained, as well as a further scenario whereby a hypothetical new settlement, incorporating 4000 new homes, could connect to the network. A detailed economic model was developed to analyse the cost of the infrastructure required.

3.4.19 Under all scenarios tested, the study concluded that the delivery of decentralised heating from HPC would be uneconomic. Even if the distribution of this heat was incentivised by Government schemes; the opportunity for CHP would be incapable of delivering energy at a price which would be competitive with gas. Furthermore the diversion of heat energy from the generation process would reduce the quantity of low carbon electricity capable of being produced by HPC, which further limits its potential.

3.4.20 In addition, the EPR units require extremely high quality water in its steam turbine water system, which draws heat from the primary reactor circuit via steam generators located within the containment building. For this reason, the district heating network would have to operate as a separate system, utilising additional heat exchangers. Such a system would be bespoke and anticipated to be extremely costly, due to the sophisticated nature of the systems incorporating leak detection and protective devices to prevent damage due to water ingress to the turbine.

3.4.21 No specific provision for extracting steam in the quantities required for a district heating system is included in the proposed HPC design. It is likely that there would be sufficient space available within the HPC site to accommodate the additional plant required, should this become economically viable. However, before it could be implemented, such an installation on a nuclear power station would require careful assessment of its potential impact on nuclear safety if inadequately conceived or executed. This would include both the design and integrity of the equipment and its compatibility with the safety-significant systems with which it would interact, and also the practical means by which it would be implemented.

82 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Construction Emissions 3.4.22 Whilst there is a generally positive relationship between the proposals and the objective of minimising GHGs, it is recognised that the construction of the power station, as with any energy source, will contribute to the emission of GHGs. This will be the consequence of a number of activities; principally the production and handling of construction materials, but also those associated with worker transport and with the operation of off-site associated developments, such as worker accommodation.

3.4.23 In light of this, EDF Energy has commissioned a Life Cycle Assessment of the Carbon Footprint of HPC , which amongst other things, assesses the embodied carbon associated with the construction phase of the project. Whilst the CO 2 emissions arising from construction are significant when considered in isolation, it is important to identify that these are very low by comparison to the benefit of generating low carbon electricity from the plant during its 60 year operation. Indeed calculations would demonstrate that this embodied carbon during construction would be offset within as little as two months generation from HPC once operational.

3.4.24 EDF Energy has considered a number of ways to reduce this embodied carbon where possible. It is important to stress however that the ability to do this is restricted by a number of factors, particularly on the choice of materials, which are governed by overriding controls for nuclear safety and quality taken as the basis for the Generic Design Assessment (GDA). Notwithstanding this, EDF Energy has given consideration to managing construction related emissions for the HPC Project where it has flexibility to do so. Proposals include:

• Requiring that Tier 1 contractors set out a strategy for managing their emissions, which will include monitoring and reporting CO 2 emissions and setting targets for carbon reduction. Such strategies are expected to include reference to the use of efficient plant items, ongoing training, use of Modern Methods of Construction, exploring innovative methods of construction and logistics, both in direct operations, but also in the supply chain, and giving consideration to the use of alternative fuels.

• EDF Energy’s transport strategy will indirectly reduce CO 2 linked to construction related transport through the provision of park and ride and freight management facilities and a temporary jetty for the delivery of aggregates by sea. The common theme of these initiatives is to reduce vehicle movements on the local road network. • Making maximum use of sea transportation via the aggregates jetty and through Combwich Wharf, and importing by these means approximately 80% of materials by weight, including bulk materials such as aggregates, sand and cement and 100% of the Abnormal Indivisible Loads (AILs). • Minimising embodied emissions through off-site prefabrication where possible and practicable.

Consideration for Climate Change Adaption 3.4.25 As previously stated, climate change adaption will form a necessary future strategy, particularly over the next few decades in which unavoidable and irreversible consequences of historic emissions may become apparent. Climate change adaption strategies require that new development is designed to respond to the

Sustainability Statement | October 2011 83

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

future predicted effects of climate change. In May 2011, the Government published the ‘Guidance Document for Climate Resilient Infrastructure: Preparing for a Changing Climate’ (Ref.68), which sets out key priorities for climate resilient infrastructure.

3.4.26 The Climate Change Act established new responsibilities for ‘statutory undertakers’ including EDF Energy to report on how it is assessing and acting on the risks to its business imposed by Climate Change. Under the 2009 Strategy for using the Adaptation Reporting Power (Ref. 69), EDF Energy qualifies as a reporting authority because company generation output is in excess of 10TWh per year. In July 2011, EDF Energy published its Report on Adaption under the Climate Change Act 2008 (Ref. 70) to the Secretary of State, setting out how it is addressing the risks of climate change in its current and future portfolio of power stations. A subsequent publication (Ref. 71) reviews the potential adaptive strategies available to new nuclear build in the UK.

3.4.27 For the HPC Project, the most significant areas of focus have been on the design and construction of the permanent development Site, particularly because the plant and associated buildings will be in operation for at least 60 years. Generating low carbon energy at HPC presents a significant step in mitigating climate change. However, such benefits can only be realised if the station is able to operate without disruptions from climatic events. An effective adaptation strategy is therefore integral to the capacity of the plant to deliver the outlined sustainability objective and fulfil its potential to mitigate climate change.

3.4.28 In this context, temporary development required to facilitate the construction of HPC is less significant, simply because such development - typically in place for a decade or less - is less likely to face potentially extreme climatic events. Notwithstanding this, good practice design principles which are common in the planning system have been addressed in the design of these facilities to ensure these factors are taken into account where necessary.

3.4.29 The UK Climate Impacts Programme (UKCIP) has identified a range of possible future impacts arising from climate change in the UK. Broadly these include hotter, dryer summers which exacerbate risk of drought, fire and building subsidence. Winters will be warmer and wetter, with greater risk of intense rainfall events and flash flooding, as well as higher wind speeds and increased frequency and intensity of storms. Sea levels will also rise, causing greater risk of tidal flooding.

3.4.30 The design development of HPC has taken into account these important consequences to ensure that it the Plant is sufficiently resilient to these effects.

5. Hotter Summers 3.4.31 This will increase drought risk, water demand, and summer cooling demand. In building design terms, this may result in an increased reliance on active cooling systems (air conditioning) and energy intensive building services strategies. However, more important in the context of the HPC Project will be the availability of the large volumes of cooling water required for the electricity generation process.

3.4.32 Increased summer temperatures will result in additional heat at ground level, particularly in developed areas. The permanent development site introduces a significant area of hard surfacing and concrete, which has higher thermal mass than

84 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

the green space around it. It is not possible to introduce significant landscaping around the plant buildings to provide shading in summer months. Notwithstanding this, the location of the site, with a rural backdrop and adjacent to the sea is not expected to be at a significant risk from this increased temperature. In addition, a number of buildings incorporate sedum roofs to reduce this affect. Furthermore, the design of the building services strategies for occupied buildings to ensure occupant comfort has been designed in accordance with recognised best practices, drawing from CIBSE standards where possible.

3.4.33 With regard to drought, the Government guidance document for climate resilient infrastructure identifies a key risk to energy infrastructure is the reduced availability of cooling water for inland power stations. This issue is of reduced significance for the HPC Project as the main water requirement will be for cooling water provided from the sea (further details available in Section 3.11). Notwithstanding, the station will require significant mains supplied water to be provided to the site to constitute ‘process water’ in the primary and secondary circuits and other cooling systems, as well as to supply potable water for the site occupants.

3.4.34 Wessex Water, the statutory undertakers for the site’s water supply, has set out to Government how it will adapt to the effects of climate change, in accordance with its obligations under the Climate Change Act. The Wessex Water Climate Adaptation Report (2011) (Ref. 72) clearly details expected climatic changes according to UKCP09 projections. Modelling allows literal interpretation of expected impacts. Building on this, adequate adaptation and contingency plans are proposed to minimise these adverse impacts up to 2040. Its activities in this area will be subject to future monitoring reviews and updates as necessary.

3.4.35 Other published risks posed by climate change include fire and subsidence. The risk of fire spreading to the main site is limited by the requirement to include limited landscaping within the security perimeter fence. Operational procedures to cover emergencies such as fire are in place through the Outline Contingency Response Arrangements (OCRA). Subsidence is not a significant issue for the HPC Project, as the building design and foundations require significant groundwork which will restrict subsidence risk. Further information is available in the Construction Method Statement .

6. Wetter Winters 3.4.36 This will see increased risks from flash flooding events. Accordingly, PPS 25 (2010) encourages development to be made to be resilient to increased rainfall, requiring attenuation measures to be put in place to deal with larger volumes of water during peak rainfall events. The site will include drainage infrastructure which has been designed to manage greater intensity rainfall in the future. The strategy for the permanent development site will ensure rainwater is diverted off the site to Bridgwater Bay via the cooling water outfalls. Furthermore underground drainage measures will also be put in place to ensure groundwater does not affect building foundations.

7. Sea Level Rise 3.4.37 This will present increased flood risk to power station sites located at the coast. As already discussed, the design of the HPC Project has been developed in accordance with the Overarching NPS and the Nuclear NPS . This demonstrates that the site is

Sustainability Statement | October 2011 85

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

acceptable in accord with the sequential test, and that the design of the land platform is consistent with the upper projections for sea level rise in UKCP09. Further information is available within the Hinkley Point C Development Site FRA. The design of the sea wall, in place to protect the seaward frontage from erosion is able to be adapted in the future, to take account of sea level rise.

3.4.38 The HPC design takes into account the risks posed by climate change, providing a high level of resilience to the various hazardous involved from the outset. Routine reviews of both local monitoring data and the best available scientific advice will provide a means of adaptive management throughout its life-cycle. Additionally, wider risks identified by UKCIP, such as health impacts and impacts on supply chain, are being addressed by EDF Energy at the broader level, for example within the Health Impact Assessment .

ii. Off-site Associated Development 3.4.39 The proposed off-site associated developments will have both positive and negative impacts on Green House Gas (GHG) emissions. Table 3.3 provides an evaluation of impacts of emissions arising from the off-site associated development. The design of these facilities has been informed by energy assessments which quantify energy use and associated emissions. EDF Energy has evaluated a number of options for carbon reduction, which is informed by factors such as the building typology, their longevity (i.e. post-operational uses) and environmental constraints.

3.4.40 Some key measures that have been adopted:

• Setting CO 2 targets in accordance with emerging policy within the draft SDC LDF Core Strategy Policy D3. • Adopting recognised sustainable design and construction standards for associated development, using BREEAM and CEEQUAL, which include requirements for emissions reductions. • Design measures for buildings and lighting to reduce emissions. • Utilisation of Air Source Heat Pumps on various buildings over 50m 3. • Adoption of standardisation, prefabrication and modularisation principles in design and construction of buildings, to reduce their embodied energy.

Table 3.3: Summary of Issues and Measures to Reduce Greenhouse Gas Emissions for Off- Site Associated Development & HPC Accommodation Campus Associated Key Sustainability Issues and initiatives proposed Development Site Accommodation The performance of the three accommodation campuses can be Campuses considered together, as broadly they have similar issues associated. It is notable that the scale of Bridgwater A, as opposed to Bridgwater C and the HPC accommodation campus means that this site would consume the greatest amount of energy in operation. Further, given the post-operational strategy for Bridgwater C, the energy performance of this site is marginally better, and includes proposals for energy efficiency, such as Light Emitting Diode (LED) lighting, which would not be applied at the other sites. This site will also achieve BREEAM Excellent. Notably, all accommodation campuses will be designed to achieve Part

86 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Associated Key Sustainability Issues and initiatives proposed Development Site L2a of the Building Regulations 2010, and in doing so, would demonstrate consistency with the requirements established within the draft Sedgemoor Core Strategy Policy D3, which specifies a timetable for carbon reduction. A hierarchical approach to energy has been applied by EDF Energy in developing the energy strategies for these sites. This is consistent with recognised best practices and includes reducing energy use, through passive design strategies, natural ventilation and daylight, before applying energy efficient plant and renewable energy technologies. Details of the carbon savings and broad measures proposed are outlined within the Design and Access Statements. Cannington Bypass Increases in emissions can be expected from construction. Once operational, traffic (and therefore CO 2 emissions) will be displaced from elsewhere, including Cannington, whereby the route may provide a more direct journey with greater potential to maintain constant speeds. Over the longer term emissions may increase as bypass usage rises, although it is not known to what extent this would occur. The development includes road lighting which will be adopted by Somerset County Council. This lighting has been specified to their standards. Combwich wharf The upgrading of Combwich Wharf to facilitate delivery by sea may assist refurbishment and to reduce emissions associated with land based freight. The wharf would extension and receive 100% of the AILs, including bulky construction materials to be associated freight imported by sea. (See Freight Management Strategy, appended to the laydown facility Transport Assessment ). The construction of the laydown facility is expected to be fairly carbon intensive, as EDF Energy is required to raise the site level by approximately 1 metre, achieved through importing approximately 300,000 tonnes of material ( See Waste Management Implementation Strategy ). This would later be removed upon the sites restoration. EDF Energy would limit carbon impacts from this as far as possible, for example by attempting to minimise the distance from which this material is sourced, and limiting the multiple handing of soil through a Soil Management Plan . During operation, lighting would be required. Emissions from this would be limited through applying energy efficient lighting and ensuring appropriate controls. ASHP’s would be used on buildings over 50m 2. Cannington Park and The four sites each include park and ride facilities. There would be Ride emissions associated with construction of the facilities; however the principle of park and rides – which would result in consolidated staff travel M5, Junction 23 Park (40 workers per bus) – would reduce emissions associated with private car and Ride, Freight travel that would otherwise travel to the HPC development site. Management and Postal/Courier EDF Energy aims that the very large majority of the construction workforce Consolidation Facilities (approximately 96%) would access the HPC development site by park and and Induction Centre ride or other sustainable form of transport. Combined with other proposed sustainability initiatives, for example the inclusion of cycle parking at the M5, Junction 24 Park park and ride facilities, this would help to secure more sustainable access. and Ride and Freight Freight management facilities are proposed to help manage delivery of Management Facilities equipment and materials to the HPC development site. They would and Temporary incorporate electronic delivery management systems to optimise deliveries Postal/Courier both to these facilities, and also onward journeys to the HPC development Consolidation Facility site. This may reduce vehicle idling time. and Induction Centre Lighting would be required at these facilities. This would be designed in order to reduce energy and emissions, as well as meet with EDF Energy’s Williton Park and Ride operational requirements. The design exceeds industry best practices, and would lead to substantial associated carbon reductions. Certain buildings would also be subject to BREEAM and buildings over 50m 2 would be designed to limit carbon emissions in accordance with Building Regulations, which would require that ASHP systems are installed.

Sustainability Statement | October 2011 87

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

d) Summary 3.4.41 A new nuclear power station will make a significant contribution towards Government objectives to augment the low carbon power sector. The sustainability objective: to minimise greenhouse gas emissions is strongly supported by EDF Energy’s proposals, which is consistent with the conclusions made by the Government during the AoS of the Nuclear NPS. The benefits of a new nuclear power station at Hinkley Point are much lower GHG emissions during the operational stage compared to fossil fuel sources, with positive long-term effects on climate change.

3.4.42 During construction (short-term), and the decommissioning phase (long-term), CO 2 and other GHG emissions will increase due to construction related activities. However, carbon emissions during construction are negligible compared to the emissions displaced by the operational output of the plant. Indeed, failure to deliver the project will prevent this objective being achieved. This is a crucial dimension in the sustainability of the HPC Project; vital when considering wider climate goals.

3.5 Communities: Population, Employment and Viability

a) Background 3.5.1 Establishing prosperous and inclusive communities is a key tenet of sustainable development. The AoS of the Nuclear NPS identified three objectives for sustainably developing Communities; Population, Employment and Viability, which are to:

• create employment opportunities; • encourage development of sustainable communities; and • avoid adverse impacts on property and land values and avoid planning blight.

3.5.2 EDF Energy has evaluated the socio–economic implications of the project, with particular focus on regional and local communities within Sedgemoor, West Somerset and Taunton Deane. This Sustainability Statement reports on the work undertaken. However, for further detail the reader is referred to the Socio Economic chapters within the EIA.

b) Planning Policy 3.5.3 The Overarching NPS states that the IPC should have regard to the potential socio- economic impacts of new energy infrastructure identified by the applicant. Further, the Nuclear NPS advises that the IPC should give the potential socio-economic benefits significant weight when assessing DCO applications; and should consider any positive provisions the developer has made and any options for phasing development in relation to the socio-economic impacts.

3.5.4 Planning policies for population, employment and viability are embedded at all levels of decision-making. At the national level PPS 4 – Planning for Sustainable Economic Growth (2009) seeks to ensure growth that can be sustained and is within environmental limits, but which also enhances environmental and social welfare and avoids greater extremes in future economic cycles. To help achieve sustainable development, the Government has detailed a number of planning objectives, including building prosperous communities by improving the economic performance of cities, towns, regions, sub-regions and local areas, both urban and rural. At the

88 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

regional level, RPG 10 Policy EC 1: Economic Development advises local authorities and other bodies to support the sustainable development of the regional economy by, among other things, positively promoting and encouraging new economic activity in the areas where it can bring the greatest economic and social benefit and make the greatest contribution to reducing regional disparities in prosperity. This is supported by the Sustainable Community Strategy for Somerset 2008-2026 which sets the long- term vision to broaden and strengthen the local economy through increasing overall employment rate, average earning of employees in the area, and new business registration rate. At the local level, WSC and SDC planning polices promote business development by identifying employment areas and planning and allocating housing sites.

c) Sustainability Performance 3.5.5 The sustainability objectives under the theme of Communities: Population, Employment and Viability are broad in their scope, and for clarity, have been considered separately below. For the purposes of this Statement it is not practical to separate those impacts that relate to the HPC development site and those relating to the off-site associated development. Their socio-economic impacts are inextricably linked and are therefore considered in conjunction. Notwithstanding this, Volume 2, Chapter 9 of the Environmental Statement details further the breakdown of employment occurring at the main site and associated development. Further details are available there.

ii. To Create Employment Opportunities 3.5.6 This objective is clearly achieved by the project. When considering impacts on local employment, construction of HPC will have a very positive effect. 20,000-25,000 individual jobs are expected to be provided over the lifetime of the construction programme, of which, 5,000 of are expected to be filled by Somerset residents. The average monthly headcount is expected to peak at 5,600 in 2016 and early 2017. Thus the local recruitment potential is substantial.

3.5.7 EDF Energy is committed through its Construction Workforce Development Strategy (CWDS) to maximising benefits to West Somerset, Sedgemoor and Somerset. The strategy was produced in consultation with partners and reflects jointly held priorities for action. The CWDS comprises seven key projects through which EDF Energy and partners will work to achieve these objectives. They are:

• Jobs Brokerage: Developed with JobCentre Plus and will match vacancies with contractors to local residents; • Outreach: Outreach projects will engage with local communities, particularly hard to reach groups, so that they are aware of opportunities at HPC and supported in gaining the necessary motivation and skills to access jobs. EDF Energy is funding community outreach workers in Sedgemoor and West Somerset who will liaise with their own outreach co-ordinator. They will identify specific interventions relating to clients needs and will link with the brokerage service; • Construction Skills Centre: EDF Energy has been working in partnership with Bridgwater College to enable local, demand led training to be delivered at a Construction Skills Centre in Cannington. The centre will be able offer courses ranging from basic health and safety and card schemes through to advanced training in specific skills;

Sustainability Statement | October 2011 89

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

• Constructionarium: Constructionarium is a hands-on construction experience for students following civil engineering and built environment courses. It allows the students to learn practically from industry - their future employers. It is designed to be part of a 21st Century engineering education which links academic theory with contractors and consultants from the construction industry. It will be established in partnership with education providers and based at the Construction Skills Centre; • Hinkley Ready: Hinkley Ready will enable residents of West Somerset to get the skills they need to work at HPC. It has been developed in partnership with West Somerset Community College, and will combine physical investment in buildings with a curriculum designed to meet the needs of HPC contractors; • Apprenticeships: EDF Energy aims to at least meet the national benchmark for construction apprenticeships. EDF Energy will produce a specific Apprenticeship Strategy and work with its supply chain and other agencies to maximise apprenticeships for local residents; and • The Enterprise Project: EDF Energy is working with West Somerset Community College and West Somerset Council on a feasibility study for an enterprise project, to support local residents and businesses in providing services to the incoming workforce and prepare for other new markets (e.g. visitors and tourists) that may arise as a result of the HPC development.

3.5.8 EDF Energy’s Education ‘Inspire’ Strategy will involve working with schools, other education providers and young people in Somerset to engage and inspire young people in Somerset to follow a pathway in Science, Technology, Engineering and Mathematics, with the primary aim of raising aspiration and attracting school leavers into a career in Construction or Engineering. It will have a tailored approach to address the needs of children from primary school through to school leavers and will engage with all primary schools in West Somerset and Sedgemoor and secondary schools throughout Somerset.

3.5.9 During the operation phase (medium-term) recruitment potential reduces, but it will still represent an overall increase from the present situation, with expected employment of 900 staff, 700 directly and 200 through contractors. Approximately half are likely to be recruited locally but ultimately all are expected to live in one of the immediate districts (West Somerset, Sedgemoor and Taunton Deane). EDF Energy will source approximately 200 of the 300 trained technicians required during the operation phase through the EDF Energy four-year apprenticeship programme.

3.5.10 In the future employment opportunities may also arise indirectly as a result of benefits flowing along the supply chain. EDF Energy has appointed a local procurement specialist to establish a strategic relationship with the Somerset Chamber of Commerce, in order to identify and match Somerset companies to supply chain opportunities. In addition, EDF Energy has set up the Local Business Engagement Forum which has performed a number of functions including:

• Launching the HPC Project Supply Chain website as an information portal for Somerset companies interested in receiving news and information on the status of the project. • Holding, and continuing to hold supplier days in Somerset, arranging activities to maximise economic benefit through:

90 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

− business supplier events and skills training; − engagement with schools and colleges in the local area in order to help them plan the education and trainings requirements of their students; − an on-going commitment to local procurement and training to up-skill the workforce; and − a dedicated supply chain representative in EDF Energy’s Bridgwater office. This representative is undertaking an outreach programme with local businesses, including a series of ‘supply chain’ events for local businesses to provide a clear understanding of EDF Energy’s requirements of suppliers. • Visiting local companies and support seminars to provide Somerset businesses with key information; and providing contacts and guidance to help them develop to meet the requirements of EDF Energy and its contractors.

3.5.11 The socio-economic assessment identified the following prospective benefits of the project for the local economy:

• Indirect economic benefit, by creating demands for goods and services from local firms, stimulating additional employment. This is estimated to generate £100 million per annum during each year of construction. • Additional economic benefit, anticipated to be in the order of £40 million per annum during operation.

3.5.12 The summary provided above clearly demonstrates the significant employment potential, made more sustainable by the delivery of long-term skills and investments within the area. Accordingly, there is a strong relationship with the objective to create employment opportunities.

iii. To Encourage the Development of Sustainable Communities 3.5.13 This objective is broad, involving and influenced by a range of factors. The Government’s guide questions for this objective focus primarily on the capacity for introducing new immigrant workers to the area, and the implications this will have for sustainable communities. However, the UK Government’s Sustainable Development Strategy identifies that the sustainability of communities in England will be influenced by a range of other factors. Sustainable communities are recognised to be:

• inclusive, facilitating involvement and security; • efficiently and appropriately managed; • environmentally sensitive; • built and designed to a high standard; • good quality infrastructure; • economically, socially and environmentally progressive; • appropriate, efficient and accessible provision of services; and • present equality of opportunities and inclusion to all parties.

3.5.14 These factors are broadly in line with those appearing within the Sustainable Community Strategy for Sedgemoor 2009-2026.

Sustainability Statement | October 2011 91

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

3.5.15 EDF Energy’s approach to achieving these objectives involves firstly seeking to avoid, and where necessary mitigate, any impacts on existing communities, and secondly through investment in the area which will, in part, meet the needs of the EDF Energy non-home based workforce, but also provide immediate and longer term benefits for local communities.

3.5.16 EDF Energy’s assessment of the likely timing and phasing of workers who move into the area to work on the project (the non-home based workforce) has allowed it to develop a “campus based” approach to meeting accommodation needs which involves the provision of three accommodation campuses – one on-site, and two in Bridgwater. These will be phased to ensure that at no time should the demand for local accommodation exceed capacity in the area.

3.5.17 However EDF Energy recognises that there are uncertainties in forecasting and therefore is also proposing to manage the local impacts of the workforce through its Accommodation Management Strategy and provide a £5 million Housing Fund to allow local partners to identify investments which can “pre-mitigate” the impacts of the workforce but also provide long lasting benefits to the area.

3.5.18 EDF Energy is also committed to managing and mitigating potential impacts on local public services and local conditions in areas in which there is a concentration of workers. It has been working with public service providers through a number of groups to identify and plan to address potential impacts and has proposed a comprehensive package of mitigation to address these issues. This includes:

• Campus accommodation will be of a high standard, providing a range of amenities and leisure activities for the construction workforce. The campus accommodation has been designed to be inclusive and safe, with clear distinctions between public and private spaces. Where possible, all spaces within the development sites have been designed to ensure they are overlooked by active building elevations. EDF Energy has liaised with local Crime Prevention Design Advisors for this purpose. • Adopting design and layout principles of accommodation campuses to reduce noise and disturbance to neighbouring communities and establishing community liaison facilities, to ensure complaints and community concerns are addressed rapidly. • Site security will go hand in hand with the establishment of a code of conduct for all employees and the contracted workforce, which will be part of the induction process, and reinforced throughout the process. • EDF has also consulted with the police and other emergency services throughout the development of the proposals. This has resulted in the production of a Community Safety Management Plan and EDF is making contributions to support policing and community safety initiatives in the area. • EDF Energy will also work with Councils to monitor and mitigate impacts on local schools and make substantial contributions to local leisure provision. These will both provide immediate benefits to local people and a long-term investment in the area; • Certain construction sites would be registered with the UK Considerate Constructors Scheme – an initiative which commits companies to be considerate

92 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

and good neighbours, as well as clean, respectful, safe, environmentally conscious, responsible, and accountable. The principles of this scheme will be applied throughout.

3.5.19 EDF Energy recognises that the development will also have “qualitative” or intangible” impacts on areas on which construction activities or the workforce are most concentrated. For this reason a £20 million Community Fund is proposed, to be spent locally on a range of community initiatives chosen by the community and local authorities. This aims to mitigate effects on local quality of life which are not addressed by other mitigation measures.

3.5.20 As noted above, a major legacy of enhanced skills will be left, which will be delivered in partnership with others via the implementation of the Construction Workforce Development Strategy. This will also leave a substantial physical legacy through investment in local education infrastructure. EDF Energy has a strong track record in delivering skills; the corporate strategy – ‘Our Sustainability Commitments’ – outlines how these initiatives, including supporting the National Nuclear Skills Academy, are being delivered.

3.5.21 EDF Energy, alongside all other major energy suppliers, is actively involved with the Community Energy Saving Programme (CESP). The programme means that at the company level, EDF Energy is delivering energy saving measures to domestic consumers in specific low income areas of Great Britain, helping to tackle fuel poverty through a whole-house approach to tackle domestic energy efficiency. A number of communities within the south-west region, including Sedgemoor, benefit from this scheme.

3.5.22 More broadly, independent of the HPC Project, EDF Energy already makes significant contributions to the communities in which it operates. This is recognised, for example, through its Platinum Plus status recently re-awarded by Business in the Community (BiTC). This commitment is also evident through EDF Energy’s investments in low carbon and energy saving, which include;

• In 2010 under Carbon Energy Reduction Target (CERT) programme it installed over 205,000 loft insulations and over 147,000 cavity wall insulations. • It is contributing to the industry’s £250 million of support to its most vulnerable customers under the Government’s social tariff scheme to help low income families. • As part of this project, it will give a £120 electricity rebate to around 100,000 of its most vulnerable customers, in addition to over 160,000 vulnerable customers who receive support through its special discounted tariff, Energy Assist. Energy Assist was launched in 2006 as the first special tariff to support customers living in or at risk of fuel poverty. • It donated over £4 million to the EDF Energy Trust Fund in 2010, bringing total donations to over £17 million since 2003, allowing the Trust to help over 21,000 households to break free from serious household debt.

3.5.23 Each of these initiatives is continuing into the future, demonstrating EDF Energy’s commitments to this objective.

Sustainability Statement | October 2011 93

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

iv. To Avoid Adverse Impacts on Land Values and Avoid Planning Blight 3.5.24 Impacts on land values and planning blight are an important consideration for EDF Energy and have been subject to analysis and separate consultation with residents around affected areas. In general, the proposals for the HPC Project are not thought to impact significantly upon land values or to cause planning blight to a significant degree. This is primarily due to the proposed location of HPC next to HPA and HPB, but also because of the extensive mitigation that is being put forward as part of the DCO application process. Notwithstanding this, it is accepted that construction activities will be disruptive for local residents.

3.5.25 EDF Energy is offering various initiatives which reduce impacts from planning blight and disruption. This has included the development of a neighbourhood support scheme, which includes a property price support scheme and a Noise Insulation Scheme for eligible residents. Such offerings are extensive and can be considered best practice; for example EDF Energy will offer home owners within the boundary of the main site the difference between the ‘without Hinkley Point C’ value and the ‘with Hinkley Point C’ upon sale of their property and include a sum of £5,000 to assist them with their move. For eligible properties affected by noise, EDF Energy will offer free secondary glazing to fit existing windows; or free double glazed PVC-U replacement windows or appropriate replacement windows for existing listed buildings to reduce noise impacts.

d) Summary 3.5.26 The objectives under the theme Communities: Population, Employment and Viability are largely supported by the proposals. There is a particularly strong relationship between the development proposals and the Government’s aim to create employment opportunities. This is based on the number of jobs that will be provided during construction and operation of the facility. 20,000-25,000 jobs will be created over the project lifecycle, many of which will be sourced locally and made more sustainable by local skill enhancement and indirect economic activity, including further development of a low carbon technology research cluster in the vicinity. When considering the wide ranging community benefits proposed, coupled with the legacy benefits of some of the off-site associated developments proposed, the objective to encourage the development of sustainable communities is also supported by the proposals.

3.6 Communities: Supporting Infrastructure

a) Background 3.6.1 This sustainability theme relates to the effects of NSIPs on transport infrastructure and other basic services including water, sanitation and power. The development of a significant infrastructure project such as the HPC Project has the potential to impact upon these basic services within the locality of the site. In the case of transport infrastructure effects may be felt at a wider scale, particularly where there are cumulative effects as a consequence of further development in the region. In response to this, the Government has focused on two sustainability objectives under this theme:

• to avoid adverse impacts on the function and efficiency of the strategic transport infrastructure; and

94 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

• to avoid disruption to basic services and infrastructure.

b) Planning Policy 3.6.2 The planning policies for supporting infrastructure are broad. The Overarching NPS acknowledges that new NSIPs may give rise to substantial impacts on the surrounding transport infrastructure, and states that the IPC should ensure that the applicant has sought to mitigate these impacts, including impacts during the construction phase of the development. RPG10 contains a number of policies advising local authorities and others to have regard to infrastructure needs when planning development. At the local level policies for transport are set by Somerset County Council as the local highway authority, and specific policies for transport planning for new developments are set by WSC and SDC.

c) Sustainability Performance 3.6.3 In the AoS Site report for Hinkley Point, the Government has identified the potential for a significant adverse effect on national road infrastructure through increased congestion or disruption of traffic on the M5 motorway and local road networks in Bridgwater, as well as potential cumulative effects with planned residential development at Bridgwater and the decommissioning of Hinkley A and B. A Transport Assessment has been undertaken which investigates impacts on the transport environment.

ii. To Avoid Adverse Impacts on the Function and Efficiency of the Strategic Transport Infrastructure 3.6.4 The construction of HPC will require the significant movement of people and materials to and from the HPC development site, which could have an adverse impact on the transport network if not properly managed. Key issues relating to the transportation of materials and the workforce include:

• During peak construction in 2016, the workforce may be 5,600 people. The majority of the workforce will be transported to and from the site on a daily basis. • EDF Energy estimates that 7.3 million tonnes of materials will be transported to/from the HPC project sites during the construction phase, the very large majority (approximately 5.4 million tonnes) will be required for the HPC development works.

3.6.5 EDF Energy has developed a Freight Management Strategy (appended to the Transport Assessment ) which includes proposals to manage the movement of materials in a sustainable way. The measures which are proposed to reduce the impact upon transport infrastructure include:

• Refurbishment and extension of Combwich Wharf to facilitate the water-borne transport of AILs. These materials will be shipped by sea and taken to site via a private road and the C182. • Provision of a temporary jetty at the HPC development site for bulk aggregate delivery. This will receive construction materials required for the HPC Project. • EDF’s Energy commitment to deliver a minimum of 80% (by weight) of materials for on-site concrete production comprising sand, aggregate, cement and PFA via the jetty (once available) and 100% of the largest AILs to Combwich Wharf.

Sustainability Statement | October 2011 95

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

• Introduction of off-site freight management facilities at Junction 23 and Junction 24, to control incoming freight traffic flow and hold freight vehicles in the event of an incident on the local network or on-site. • EDF Energy proposals for four park and ride facilities and its commitment to promote car sharing to these facilities. This would enable the large majority of the construction workforce to be transported to the HPC development site by bus. • Regulation of traffic flow by using a project-wide delivery management system (DMS) to regulate flows and move away from peak time congestion. • Reduction of the impact of construction traffic in Cannington by constructing a bypass around the western side of the village, linking the A39 directly to the C182. • Reduction of the impact of construction traffic by providing a package of road improvements where required. • Shift patterns for construction workers developed with the aim of moving workers to and from the site outside peak traffic hours.

iii. To Avoid Impacts on Basic Services and Infrastructure 3.6.6 The key impacts addressed under this objective are those that relate to services such as water, power and sewerage. Impacts on health care provision are considered in Section 3.7 - Health and Wellbeing , and addressed in more detail within the Socio- economics Chapters of the Environmental Statement and the Health Impact Assessment . Implications for policing and education have been addressed in the previous section, and are considered in more detail in the Environmental Statement .

3.6.7 The development of the HPC Project, although placing demands on service infrastructure – particularly water – is not predicted to cause significant disruption to basic services available to surrounding communities. The HPC development site is largely self-sufficient in terms of core services. By way of example, HPC will have no gas supply, whilst sewerage will be managed on site directly, without causing disruption to or pressure on existing facilities available in the locality. Of all services, the provision of additional water infrastructure is most likely to create disruption. Wessex Water is undertaking the necessary upgrades to support the new demand created by the HPC Project. This will include upgrades to pipe work, and the increasing capacity of a reservoir, located approximately 2km south of Hinkley Point.

3.6.8 With regard to emergency services, EDF Energy has undertaken extensive work with the emergency services and local authorities in respect of community safety in developing the project’s Outline Contingency Response Arrangements (OCRA). An overview of this can be seen appended to the Community Safety Management Plan (CSMP).

3.6.9 The effect of off-site associated development on these objectives has also been considered. Located within or in close proximity to existing settlements, these developments have the potential to impact local transport networks and services during construction, although this will be minimised by adopting best practices in construction to limit disturbance. Considerations regarding the movement of workers to and from HPC are detailed above.

96 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Table 3.4: Summary of Impacts and Proposals Relating to Community Infrastructure for Off- Site Associated Development & HPC Accommodation Campus Location Sustainability Impacts/Mitigation Accommodation Campus accommodation in Bridgwater will be designed to limit impacts on Campuses transport infrastructure through travel planning and limiting numbers of car parking spaces to a ratio of 1:1.6. Various measures are put forward to encourage sustainable transport, for example cycle storage would be provided for 5% of workers. Out of hours workers are expected to make use of public transport. Cannington Bypass The bypass is part of a package of transport measures designed to relieve pressure on local road networks during the construction and operation of HPC. The bypass would avoid impacts that might otherwise occur in Cannington. Combwich wharf The refurbishment and extension of Combwich Wharf to receive 100% of refurbishment and the AILs would help to reduce impacts on the strategic transport extension and infrastructure. In addition, the Wharf may also be used to take receipt of associated freight other bulky construction goods. This would be distributed to the laydown facility development site via a private road and the C182. Cannington Park and The park and ride at Cannington has been identified as a necessary Ride element of the project’s transport strategy. The purpose of the facility, as with all park and ride facilities, would be to consolidate workers and visitors and transport them to the construction site. The site’s strategic location, immediately accessible from the A39, means that it is well located to serve the immediate catchment of the HPC development site. The park and ride facility would be delivered alongside a new gravel footpath linking into an existing Public Right of Way (PRoW). The site’s proximity to Cannington would also enable residents to walk and cycle to the facility. The site would include cycle parking for 5% of the spaces. M5, Junction 23 Park EDF Energy’s proposals for Junction 23 and Junction 24 have been and Ride, Freight specifically included to address impacts that would otherwise occur on the Management and strategic road network, particularly in Bridgwater. Postal/Courier The park and ride facility is intended to transport construction workers to Consolidation Facilities the HPC development site in a way which minimises disruption to local and Induction Centre road networks and consolidates vehicle movements. Similarly, the consolidation facility for postal/courier deliveries would provide a single point of delivery for all postal items to the HPC construction site, helping to M5, Junction 24 Park reduce individual vehicle movements, particularly of LGV’s. and Ride and Freight Management Facilities The freight management facility would provide a physical control and Temporary mechanism to regulate the flow of vehicles through Bridgwater to the HPC Postal/Courier construction site. The freight routes linking the sites to HPC have been Consolidation Facility selected based on the following: and Induction Centre • the appropriateness of the roads to carry heavy goods vehicles (HGVs); • the potential to avoid congested areas of Bridgwater; and • the directness of routes. These controls and measures to reduce impacts are further detailed within the Freight Management Strategy, appended to the Transport Assessment . Williton Park and Ride The park and ride at Williton has been identified to intercept workers travelling to the site from settlements to the west of the HPC development site. Its location, outside of the village means that buses would be diverted from the A39 to access the site. The park and ride would include a bus route however, which picks up workers at stops in Williton on the way to HPC, reducing the number of vehicle movements from local residents. The site would also include cycle storage for 5% of the car parking spaces.

Sustainability Statement | October 2011 97

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

d) Summary 3.6.10 The Communities: Supporting Infrastructure theme has been identified by the Government to ensure that disruption to basic services from the project is properly evaluated and impacts mitigated. Under the theme, the primary impact identified in the studies undertaken by EDF Energy is on transport infrastructure. However, EDF Energy has put forward a number of physical controls, including four Park and Ride sites, the construction of the Cannington bypass and Combwich Wharf laydown facility as well as freight management facilities at Junctions 23 and 24, to reduce impacts and ensure construction can occur without significant perturbations. This is delivered in occurrence with other road improvements and a range of soft management measures, such as a project wide Delivery Management System and Travel Planning.

3.7 Human Health and Well-Being

a) Background 3.7.1 Energy production has the potential to affect the health and well-being of the population. In its AoS the Government considered three sustainability objectives under the theme of Human Health and Well Being. These are:

• to avoid impacts on physical health; • to avoid impacts on mental health; and • to avoid the loss of access and recreational opportunities, their quality and user convenience.

3.7.2 In assessing conformity with these objectives, this Sustainability Statement has drawn on information in the Health Impact Assessment . Various other assessments have also been conducted, including socio-economic assessments, the work undertaken through the GDA, and the process of Regulatory Justification which are closely linked with the protection of human health.

b) Planning Policy 3.7.3 In the Overarching NPS human health impacts are considered at a strategic level. In simple terms, access to energy is beneficial, but its production may have negative impacts on some people’s health. It states:

“where the proposed project has an effect on human beings, the ES should assess these effects for each element of the project, identifying any adverse health impacts, and identifying measures to avoid, reduce or compensate for these impacts as appropriate.” (Paragraph 4.13.2)

3.7.4 Further information relating to human health and nuclear safety is provided within the Nuclear NPS:

“The IPC should act on the basis that the risk of adverse effects resulting from exposure to radiation for workers, the public and the environment will be adequately mitigated because of the need to satisfy the requirements of the UK’s strict legislative and regulatory regime as well as the ONR’s

98 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

implementation of the Government’s policy on demographics”. (Paragraph 3.12.11)

3.7.5 Given the potential for positive employment opportunities as a result of the development of a new nuclear power station, the IPC are also advised to give significant weight to the effect of employment on human health and well-being.

3.7.6 RPG10 includes a number of policies requiring human health and well-being to be taken account of, including policies EN4: Quality in the Built Environment, EN5: Health, Education, Safety and other Social Infrastructure and TCS2: Culture, Leisure and Sport. The effects of development on residential amenity and on recreational resources are also considerations at the local policy level.

c) Sustainability Performance i. To Avoid Impacts on Physical Health 3.7.7 Concerns for human health arising from the development of a new nuclear power station focus on exposure to radioactive discharge. Whilst the accidental release of radiation could cause adverse impacts on health, the delivery of new nuclear power will be subject to the strictest controls in the design, construction and operation of the power station. This ensures the risk of accidental release and the magnitude of any such release are minimised. As stated in the AoS of the Nuclear NPS:

“As part of the site licensing process, a potential operator will be required to demonstrate that the nuclear facility is designed and can be operated such that several levels of protection and defence are provided against significant faults or failures, that accident management and emergency preparedness strategies are in place and that all reasonably practicable steps have been taken to minimise the radiological consequences of an accident”. (Paragraph 7.2.73)

3.7.8 Accordingly, EDF Energy employs a range of measures to ensure the highest degree of safety, which broadly fall into two groups:

• ‘Protective barriers’: placing a series of physical barriers between the radioactive reactor core and the environment. • ‘Defence-in-depth’: identifying threats to the integrity of the protective barriers, and providing successive lines of defence to protect them from failure. This includes the provision of multiple safety systems, each with backup and designed to accommodate human error.

3.7.9 The protective barriers and procedures for defence in depth are significant and are monitored continually. Indeed, diverse systems will also be installed for safe reactor shutdown in the event of any faults, and essential buildings will be designed to withstand a range of human and natural hazards. In summary, controls will be incorporated in the design process that complies in every respect with Government guidelines and the extensive regulatory regime for delivering new nuclear power stations. Additionally, all nuclear operators are obliged to specify and implement adequate arrangements for dealing with an incident or emergency, and its effects arising on the site.

Sustainability Statement | October 2011 99

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

3.7.10 In addition, under its Nuclear Site Licence EDF Energy is obliged to undertake Periodic Safety Reviews. These are a periodic holistic review of the condition of the plant and its compliance with current regulatory standards, together with the identification and implementation of any reasonably practicable improvements. This ensures that the design of the HPC Project will not only comply with current standards when constructed, but will also keep abreast of future changes and opportunities to improve.

3.7.11 The operation of a UK EPR reactor unit produces radioactive waste, of differing levels of radioactivity, in solid, liquid and gaseous form. The AoS of the Nuclear NPS dealt with the management of radioactive waste in the following terms:

“New nuclear power stations will produce low level waste (LLW), liquid and gaseous discharges, and non-radioactive wastes. Arrangements already exist for the effective management and disposal of wastes in these categories, as demonstrated by the experience of dealing with such wastes from existing nuclear power stations… New nuclear power stations will also produce higher activity wastes, which are intermediate level waste and spent fuel (on the assumption that spent fuel from new nuclear power stations will not be reprocessed). Geological disposal is the way higher activity wastes will be managed in the long term. This will be preceded by safe and secure interim storage until a geological disposal facility can receive waste. The framework to implement this policy was set out in the Managing Radioactive Waste Safely (MRWS) White Paper published in June 2008… Radioactive waste will need to be transported. The UK has robust legislative and regulatory systems in place for the transport of radioactive wastes, including higher activity wastes. Transport of radioactive wastes is, and will continue to be, required to meet a number of national and international requirements to ensure the safety and security of such materials.” (Paragraph 3.8.1, 3.8.2 and 3.8.3 )

3.7.12 At HPC, new and spent fuel would be handled in the fuel building. Spent fuel is highly radioactive and would be stored underwater in a fuel pond for approximately 10 years before transfer to the on-site Interim Spent Fuel Store, pending final disposal in the proposed national geological disposal facility.

3.7.13 EDF Energy’s proposals for HPC accord with the Government’s position on Regulatory Justification of the UK EPR design, which is summarised in Part 2 .

3.7.14 Information from the Health and Safety Executive demonstrates that the construction industry in general, presents one of the most hazardous working environments within the UK. However, this does not relate to major infrastructure projects such as Hinkley Point C, which employ significant risk prevention and occupational health promotion initiatives to facilitate a safe, healthy, and cost effective workforce with minimal downtime or impact on surrounding health care services.

3.7.15 EDF Energy operates a zero harm policy within the organisation, which is underpinned by staff training and awareness raising, management programmes and health and well-being campaigns. The zero harm policy will be extended to the HPC Project. In addition, EDF Energy is promoting a series of initiatives to reduce impacts on physical health, which include:

100 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

• Compliance with CDM Regulations and relevant health and safety policies. • A medical centre on site during construction and operation of HPC. EDF Energy will also support healthcare provision within the communities surrounding Hinkley Point. • EDF Energy is developing a Health Action Plan, which will support local healthcare initiatives and address community concerns on health. The Action Plan expands upon the standard recommendations section within Health Impact Appraisal guidance, establishing recommended protocols and monitoring regimes to be implemented during construction and operation to further reduce and remove potential negative health impacts, while maximising opportunities to increase the uptake of health benefits. • Further strategies and protocols will be in place to maintain the physical health of the workforce and local communities, including emergency planning and a Community Safety Management Plan .

ii. To Avoid Impacts on Mental Health 3.7.16 The impact of the HPC Project on well-being is being evaluated within the HIA. It is recognised that a key mechanism for reducing impacts will be through raising awareness in partnership with local healthcare providers. The HIA explores what additional initiatives can be implemented to reduce factors affecting mental well- being, including stress and anxiety. Recommendations for improving community well-being have been outlined in the Health Action Plan.

3.7.17 As with all development, the construction and operation of the proposed development at HPC will comply with environmental standards set to protect the environment and community health. It is appreciated, however, that construction will be disruptive to local communities, and although significant mitigation and a community impact fund will be provided, ongoing and meaningful community engagement will be necessary to respond to and address the more intangible aspects important to mental health and well-being. This is set out in the Health Action Plan.

iii. To Avoid the Loss of Access and Recreational Opportunities, their Quality and User Convenience 3.7.18 The potential of the project to impact access to recreation and amenity has been assessed within the EIA and is presented with the Environmental Statement , Volumes 3 to 11, Chapter 17, and for the HPC development site within Volume 2, Chapter 25 . Overall the project will not impact access and recreational facilities within and around the HPC Development Site to the extent that opportunities for recreation and outdoor activities are precluded. Measures are being established to divert footpaths during construction, ensuring their access, quality and convenience is maintained as far as possible.

3.7.19 Recreational provision and amenity space will be available on the accommodation campuses which will be available during the operational phases of these developments. A number of Public Rights of Way (PRoWs) will be affected at the HPC development site and at some of the off-site associated development sites. Appropriate diversion routes will be put in place wherever an obstruction to a PRoW occurs and, wherever possible, PRoWs will be reopened in the post-operational phase.

Sustainability Statement | October 2011 101

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

3.7.20 Where community space falls within associated development sites, EDF Energy proposes significant mitigation measures to alleviate impact. These are fully explored within the Environmental Statement. Various proposals will also be made to enhance provision, which in turn may be linked to a health benefit. Table 3.5 outlines these.

Table 3.5: Key Issues Relating to Human Health and Well-being for Off-Site Associated Development & HPC Accommodation Campus Associated Key Sustainability Issues and Initiatives Proposed Development Site Accommodation At Bridgwater A, there will be direct and permanent impact on Bridgwater Campuses Sports and Social club, affecting the entire club. EDF Energy will financially compensate the Club for loss of facilities to mitigate this loss prior to construction. Furthermore, to mitigate the loss of community space, the new campus accommodation will provide a full sized outdoor football pitch and two all-weather outdoor 5-aside football pitches, as well as a sports club, with public access. These amenities will still be available for the public following handover of the site to any future developer. At Bridgwater C there will be the loss of one pitch for Bridgwater and Albion rugby football club. The club will receive adequate compensation enabling them to replace the lost ground with another facility elsewhere. EDF Energy is assisting with the application for a replacement facility. The rugby club will also experience a minor increase in noise levels. Long-term, the associated infrastructure for both Bridgwater A and C will be retained, making the sites more attractive to future developers. This provision will assist in promoting healthy communities, both for the workforce but also the wider population through the increase in access. At the HPC accommodation campus, there will be facilities provided for the construction workers. Cannington Bypass The bypass will bisect an existing Public Right of Way (PRoW) (BW5/8); however a diversion will be constructed and a new cycle lane along the route of the bypass will be introduced, which will benefit the area long-term. More broadly, the bypass may be regarded to have a benefit for those living in the centre of Cannington, as the bypass will divert traffic which would otherwise cause noise and detract from amenity. Cannington Park and It is not expected that the proposed Cannington park and ride facility would Ride impact on amenity and recreation. There are presently no sports and recreational facilities or public open space around the facility. Two PRoWs are located partially within or immediately adjacent to the site boundary, although these will not be impacted and enhancement measures proposed to improve access. Combwich wharf During the construction of the site, there will be temporary obstruction for refurbishment and PRoW BW25/31, and disturbance of recreational sailing groups is expected. extension and EDF Energy proposes to mitigate this by creating a diversion for the PRoW associated freight trail, the original PRoW being restored in the post-operational phase, and laydown facility providing alternative boat storage space for the sailing club. The implications of noise in relation to annoyance and sleep disturbance on communities at Combwich have been assessed as part of the HIA. A Noise Insulation Payment Scheme for eligible properties around Combwich has been considered by EDF Energy. M5, Junction 23 Park During the construction of the proposed development, a short section of the and Ride, Freight PRoW that runs alongside the River Parrett would be diverted for a Management and temporary period to allow for an improvement to the River Parrett flood Postal/Courier defences to be undertaken. It is anticipated that the PRoW would be Consolidation diverted for approximately 8 weeks and that the diversion would be located Facilities and within the site boundary. Induction Centre

102 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Associated Key Sustainability Issues and Initiatives Proposed Development Site M5, Junction 24 Park There is a PRoW which runs along the northern boundary of the site. This and Ride and Freight would be maintained. The scheme provides new access routes. In general Management there are no issues for accessibility for the site. Facilities and Temporary Postal/Courier Consolidation Facility and Induction Centre Williton Park and In general no impacts are expected to occur from Williton on health and Ride well-being objectives. There will be no loss of access to open space and no impacts on amenity anticipated.

d) Summary 3.7.21 This topic is broad and addresses direct impacts on health and indirect impacts on recreation. With regard to physical health, accidental release would pose a health risk from radiation exposure for both workers and the public. However, given the stringent requirements imposed under the nuclear site licence regime, and the other safety and environmental regulatory mechanisms in place, the sustainability appraisal does not consider that there will be a conflict with human health and well- being objectives. This concurs with the Government’s position. Furthermore, in the extremely unlikely event of a radiological incident, HPC would implement an established and exercised emergency plan, working with the Local Authorities, Health Board and other emergency services to ensure any impacts were minimised through the Outline Contingency Response Arrangements.

3.7.22 The health benefits linked to the employment potential arising from the HPC Project, as well as proposals for skills enhancement and measures to deliver sustainable communities are expected to be substantial. Given the strict controls, the positive effects of these could be expected to considerably outweigh any potential negative consequences of the HPC Project in terms of the likelihood of occurrence and significance of an incident. It is therefore expected that the objectives for Human Health and Wellbeing will be exceeded for the Project.

3.8 Historic Environment

a) Background 3.8.1 Historic environment (identified within the AoS as Cultural Heritage) is outlined by the Government as a core sustainability theme. It relates to those elements of the natural and built environment of archaeological, architectural and historic importance. The construction, operation and decommissioning of energy infrastructure has the potential to adversely impact the historic environment, and so the Government has established the following sustainability objectives to take minimise this:

• avoiding impacts on internationally and nationally important features of historic environment; and • avoiding impacts on the setting and quality of built heritage, archaeology and historic landscapes.

Sustainability Statement | October 2011 103

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

b) Planning Policy 3.8.2 The Overarching NPS states that in determining an application for a DCO, the IPC should seek to identify and assess the significance of any heritage asset that may be affected by the proposed development. They should take into account the desirability of enhancing the significance of heritage assets and securing their conservation for the longer term. The IPC:

“should take into account the particular nature of the significance of the heritage assets and the value that they hold for this and future generations. This understanding should be used to avoid or minimise conflict between conservation of that significance and proposals for development.” (Paragraph 5.8.12)

3.8.3 PPS5 sets out planning policies on the conservation of the historic environment. It states that planning has a central role to play in conserving our heritage assets and utilising the historic environment in creating sustainable places. At the regional level, Policy EN 5: The Historic Environment in RPG10 seeks the protection and preservation of heritage assets, as do Structure and Local Plan policies, which in some cases refer to settlements or particular heritage assets of significance to the county or districts.

c) Sustainability Performance i. The HPC Development Site and On-site Associated Development 3.8.4 The AoS site report for Hinkley Point anticipated impacts on Wick Barrow Pixies’ Mound Scheduled Ancient Monument (SAM), which is of national heritage significance. The SAM is located immediately adjacent to the existing site. The Environmental Statement has considered the impacts on Pixies Mound as well as wider archaeology and cultural heritage assets within and surrounding the site, and its findings have informed the Sustainability Appraisal.

ii. To Avoid Impacts on Internationally and Nationally Important Features of Historic Environment 3.8.5 Detailed assessment, including desk-based and field surveys, has been undertaken for the project as part of the EIA. These ascertained that there are no Scheduled Monuments, Listed Buildings, Conservation Areas, Registered Parks and Gardens within the HPC development site boundary, however as stated above, the Wick Barrow SAM is located close to the site boundary. The setting of the monument will be affected by the proposals, particularly during construction, which is predicted to be of major adverse significance. Impacts are also predicted to occur during operation, prior to the application of mitigation. A Monument Management Plan has been prepared to ensure the long-term conservation of the site and setting of the monument. Further details are available within Volume 2, Chapter 23 Historic Environment .

iii. To Avoid Impacts on the Setting and Quality of Built Heritage, Archaeology and Historic Landscapes 3.8.6 As a prerequisite of the main construction works, topsoil stripping will take place across all areas where site works are planned, including temporary work areas and areas to be used for storage of spoil. This soil stripping will take place over much of

104 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

the HPC development site and would lead to the destruction of any archaeological remains below ground and historic buildings and historic landscape features above ground, with the exception of the central and western sections of the east-west trackway. EDF Energy will undertake preservation by record of heritage assets that will be lost due to the development. Where suitable archaeological material is recovered, EDF Energy intends to include an exhibit in the PIC (designed in conjunction with Somerset Museum) describing the history of the site from prehistoric times to the present. The exhibition would also include archaeological artefacts from the site excavations as well as information on the retained heritage assets. Heritage trails and interpretation boards would be included throughout the restoration landscape.

3.8.7 EDF Energy would apply mitigation, where possible to reduce impacts on the setting of important features. As an illustration, the setting of the Fairfield House (a Grade II* Listed Building dating from the 16th century) and gardens, which forms part of the Fairfield Estate, has the potential to be impacted during the construction and operational phases of HPC development site. Here landscaping and on-site and off- site screen planting would be supplied to reduce potential impacts from the change in setting.

iv. Off-site Associated Developments 3.8.8 As the developments are located in different areas, the impacts on cultural heritage vary. Table 3.6 sets out potential issues and highlights where mitigation efforts have been made.

Sustainability Statement | October 2011 105

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Table 3.6: Implications for Cultural Heritage Objectives arising from the Off-Site Associated Development & HPC Accommodation Campus Associated Key Sustainability Issues and Initiatives Proposed Development Site Accommodation Due to the location and former use of the Bridgwater accommodation Campuses campuses, it is not considered that there will be significant implications of development on the sustainability objectives. The Sydenham Manor House, a Grade II listed building falls outside of the development site boundary. In general this site is screened from Bridgwater A. The construction activities may also have the potential to impact on peat deposits; however preservation by record would be adopted in accordance with relevant planning guidance. There are no issues relating to historic environment and Bridgwater C. An assessment of the historic environment has also been made on the HPC accommodation campus. In general, due to the location of the campus, in relation to the HPC, similar implications with the performance of the HPC development site. Cannington Bypass There are no designated heritage assets within the site, although there are however, three previously unrecorded sites of medium importance have been identified which would be lost. It is proposed that all three would be removed during construction and preserved through record. In addition, the development would impact upon a fourth site (a ride) which is of low importance in its own right, but important in the setting of Brymore School, which is Grade II listed. A small section of the ride would be lost, but the remaining preserved in situ. The Cannington conservation area is located to the east of the site includes a number of listed buildings. Scheduled Monuments are also found within 500 metres of the proposed site. The construction of the bypass is expected to affect the setting of two Scheduled Monuments for a temporary period. The diversion of construction traffic away from the main high street in Cannington is regarded as beneficial to the conservation area and the setting of listed buildings fronting the high street. Cannington Park and There are no cultural heritage assets of significance within the boundary of Ride the site. Cannington Conservation Area is located to the east, and includes a number of listed buildings. The facility will be screened with landscaping which will help to reduce impacts on the conservation area during its operation. Combwich wharf Topsoil stripping, site raising and levelling, fencing, and vegetation refurbishment and clearance would take place across the laydown area. The implications of extension and these activities to affect locally significant archaeology have been assessed associated freight as part of the EIA. laydown facility M5, Junction 23 Park No key issues have been identified with respect to the historic environment. and Ride, Freight There is one scheduled monument within 100 metres from the north- Management and eastern corner of the site, across the A38 (Bristol Road); however this is not Postal/Courier anticipated to be significantly impacted and therefore no mitigation is Consolidation required. Facilities and Induction Centre M5, Junction 24 Park The location of the site, on brownfield land, is not anticipated to impact and Ride and Freight archaeology of the setting of heritage assets. The performance of the Management Facilities objectives is therefore considered to be neutral. and Temporary Postal/Courier Consolidation Facility and Induction Centre

106 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Associated Key Sustainability Issues and Initiatives Proposed Development Site Williton Park and Ride The location of the site, on an existing lorry park is not anticipated to impact archaeology of the setting of heritage assets. The performance of the objectives is therefore considered to be neutral.

d) Summary 3.8.9 The most significant cultural heritage impacts at HPC would be on Pixies’ Mound (a scheduled monument) and on buried archaeological remains. The development of HPC is likely to impact the setting of this nationally significant feature. Given the location of existing HPA and HPB, however, this impact is not predicted to significantly exacerbate the current position. Furthermore, this monument will be preserved in-situ in accordance with relevant planning policies. When considering the measures taken to preserve this feature, and considering the importance of the proposed development relative to the impacts, this objective is largely supported, especially over the medium and longer term. In addition, buried archaeology, which is generally of regional or local importance would be preserved in-situ or preserved by record.

3.8.10 Off-site associated development has a varying impact on these objectives. Impact on the sustainability objectives, particularly at the Cannington Bypass warrant mitigation. Monitoring during construction will be undertaken to ensure that any uncovered remains are identified and recorded. EDF Energy will also exhibit any recovered archaeology within the PIC.

3.9 Landscape

a) Background 3.9.1 The Overarching NPS states that the landscape and visual effects of energy projects will vary for each individual case according to the type of development, location and landscape setting. Nuclear power station sites are commonly located in less populated areas in accordance with the demographic principle established by the HSE and maintained within the Government’s Strategic Siting Assessment. These landscapes may be valued for their visual amenity and landscape resources. Hinkley Point is situated in north Somerset, adjacent to Bridgwater Bay to the north, the Quantock Hills to the west and south, and the Polden Hills to the east. The Development Site lies within National Landscape Character Area 142 – Somerset Levels and Moors: a broad area of low lying farmlands and wetland surrounded by low level hills and ridges.

3.9.2 The Government has put forward two sustainability objectives for landscape preservation:

• to avoid adverse impacts on nationally important landscapes; and • to avoid impacts on landscape character, quality, tranquillity, diversity and distinctiveness.

3.9.3 The proposals for the HPC Project have been developed to limit, as far as possible, the likely impacts on existing landscape character and important landscapes. This

Sustainability Statement | October 2011 107

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

has been achieved through careful consideration of location, design and appropriate screening, in accordance with relevant policy drivers for the project.

b) Planning Policy 3.9.4 Regarding landscape, the Overarching NPS states that:

“Landscape effects depend on the existing character of the local landscape, its current quality, how highly it is valued and its capacity to accommodate change. All of these factors need to be considered in judging the impact of a project on landscape. Projects need to be designed carefully, taking account of the potential impact on the landscape. Having regard to siting, operational and other relevant constraints the aim should be to minimise harm to the landscape, providing reasonable mitigation where possible and appropriate.” (Paragraph 5.9.8)

3.9.5 The IPC is guided to consider impacts which may have significant effects on national designations in advance of less sensitive receptors. The Overarching NPS outlines that:

“The aim should be to avoid compromising the purposes of designation and such projects should be designed sensitively given the various siting, operational, and other relevant constraints. This should include projects in England which may have impacts on National Scenic Areas in Scotland. The fact that a proposed project will be visible from within a designated area should not in itself be a reason for refusing consent.” (Paragraph 5.9.12 and 5.9.13)

3.9.6 RPG policies SS 20: Rural Land (including Urban Fringe Uses) and EN 1: Landscape and Biodiversity seek to protect and promote important landscapes, both in the formulation of planning policy and in the determination of planning applications. Structure and Local Planning policies also seek to conserve designated landscapes, as well as the distinctive character of the Somerset countryside.

c) Sustainability Performance i. The HPC Development Site and On-site Associated Development 3.9.7 The AoS Site report for Hinkley Point identified that adverse effects may occur on the surrounding elevated local landscape and associated distant views. These include some potentially lasting adverse effects on the setting and views from within the Quantock AONB to the west. Direct adverse impacts on landscape character were found at the local level, on and immediately around the HPC site. However, opportunities have been identified for mitigation. Given the potential for strengthening the positive wooded characteristics of the lowland, there is also high potential to mitigate the impacts on near views arising from the new power station. Impacts on landscape have been evaluated in the Landscape and Visual Assessment, Volume 2, Chapter 22. The performance of off-site associated development has also been assessed.

ii. To Avoid Adverse Impacts on Nationally Important Landscapes 3.9.8 Several national landscape designations are referred to in the Landscape and Visual Effects Chapter in the Environmental Statement . These primarily include

108 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

the Exmoor National Park and the Quantock and Mendip Hills AONBs. The latter is located within 4km of the HPC development site. The visual relationship of the HPC development site to these areas, and the presence of HPA and HPB within the landscape, mean that the HPC Project is likely to have a limited impact on these landscape receptors. The proximity of the Quantock Hills AONB to certain associated development sites presents a potential conflict with this objective. However, even when visibility is good, the impact of development is still limited. In many cases this will be screened by vegetation, which will mature over time rendering the impact negligible.

iii. To Avoid Impacts on Landscape Character, Quality, Tranquillity, Diversity and Distinctiveness 3.9.9 The Overarching NPS recognises that all energy infrastructures are likely to have visual effects for many receptors surrounding a site. Those effects can be minimised through careful building design, layout and landscaping. Applicants should demonstrate that they have considered criteria for good design in order to reduce environmental impacts, including those on the landscape. Energy infrastructure should be as visually attractive as possible, delivered through high-quality architecture and appropriate landscaping.

3.9.10 Paragraph 4.5.5 of the Overarching NPS states that applicants and the IPC should consider professional, independent advice on the design aspects of a proposal, in particular from the Government’s advisor on architecture, urban design and public spaces, the Commission for Architecture and the Built Environment (CABE). EDF Energy has undertaken consultation with all relevant stakeholders including CABE, who have undertaken a design review and provided feedback to EDF Energy. The extent to which the design responds to CABE’s feedback has been outlined within the Consultation Report . This has included, amongst other things, increasing the provision of green roofs on the development site.

3.9.11 Inevitably however, the HPC Project is an engineering-led project, ensuring that practicality and functionality are at the centre of the design. Nonetheless, the proposals have been subject to a masterplan design vision, which delivers the important requirements for functionality, and ensures that the aesthetic appearance of the buildings is to the highest possible standard.

3.9.12 The wider landscape strategy aims to recreate the landscape character of the area as far as possible, to ensure an appropriate transition between the HPC development site and adjacent land. This has been influenced by surrounding landscape characteristics, including field patterns with hedgerows and trees. Existing hedgerows will be retained and enhanced where possible - on Green Lane, for example - and new woodland areas created. EDF Energy also proposes to shape the landform to achieve a degree of visual mitigation wherever possible, which will involve the retention of spoil on site.

iv. Off-site Associated Development 3.9.13 The integration of off-site associated developments into the landscape has also been key to the proposals. EDF Energy has actively attempted to reduce impacts on landscaping, and has altered its proposals for certain associated development to be located on brownfield sites. Certain facilities however, namely Cannington park and ride, the HPC accommodation campus, the Cannington bypass, Combwich laydown

Sustainability Statement | October 2011 109

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

facility, and the proposals at Junction 23 are located on greenfield sites, where the impacts on the landscape are potentially more profound. Accordingly, a number of steps have been taken to try to achieve the most sympathetic design:

• EDF Energy has undertaken extensive consultation with regard to landscape impacts and potential receptors, which has influenced the layout and siting of the off-site associated development. Based on the topography of the sites and their proximity to urban settings and road networks, impacts could be considered to be reduced. CABE and other statutory consultees have been consulted on these elements and the designs reflect this accordingly. • Landscape strategies have been developed to screen new development from sensitive receptors. • Landscape restoration strategies have been illustrated to demonstrate how post- operation, the sites may lead to enhanced landscaping. • Where possible, landscape mitigation will be designed to serve multiple functions, by contributing where appropriate to ecological connectivity, recreation and amenity, sustainable drainage and climate change adaptation.

Table 3.7: Summary of Issues and Measures to Protect and Enhance Landscape for Off-Site Associated Development & HPC Accommodation Campus Associated Key Sustainability Issues and Initiatives Proposed Development Site Accommodation The Bridgwater campuses are located in north-east Bridgwater, which is Campuses currently undergoing regeneration, and so construction of the accommodation sites is in keeping with improving the townscape. At Bridgwater A, the landscaping strategy focuses on providing enhanced landscape boundary treatments to the perimeter of the site that would be left as legacy, which would be designed to support the wider masterplan for North East Bridgwater. The design will also improve the appearance of the site from the Bath Road and leave an enhanced ‘gateway’ into Bridgewater. The Bridgwater C proposals will also be designed to provide enhanced landscaping. The design of the HPC accommodation campus includes specific consideration to receptors in Shurton and other viewpoints from south. Landscaping strategies in conjunction with proposals to limit the heights of buildings have been developed to reduce landscape impacts. Furthermore, the lighting strategies for all accommodation campuses will be designed in accordance with ILE Guidance. Cannington Bypass The proposed route crosses mostly open fields, and would cause adverse visual impacts locally and further afield. The setting of heritage assets, notably Cannington Park would be adversely affected during construction. The bypass would include landscaping to ensure effects are screened as far as possible, but remains appropriate within the context of the wider landscape. As vegetation matures over time the impacts would decrease. Noise attenuation bunds will provide further protection. Cannington Park and The site lies within open greenfield land, adjacent to a green wedge of land, Ride which is a local landscape feature. Opportunities have been considered to screen the site from sensitive residential receptors within Cannington. Good design coupled with site management will ensure visual effects are minimised, for example the location of landscape spoil mounds has been used to screen the site. Furthermore, the lighting design would adopt the CIBSE dark skies standards.

110 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Associated Key Sustainability Issues and Initiatives Proposed Development Site Combwich Wharf The Parratt Estuary adjacent to Combwich Wharf is potentially a sensitive Refurbishment and landscape receptor. The most significant impacts are likely to be impacts on Extension and tranquillity from the construction of the freight laydown facility. Working Associated Freight hours will be confined to 07:30 – 18:30 to minimise disruption and a white Laydown Facility light scheme will be in place at the access to the site, and lighting will be subject to management controls to ensure that is only used when needed. M5, Junction 23 Park This site is low lying, and screened to an extent by existing landscape and Ride, Freight features, and so its visibility is limited. The development will introduce Management and further landscaping including new hedgerows and native tree planting to Postal/Courier screen the proposed development, as well as a grassed bund with trees. Consolidation There will be a post-operational landscape strategy put in place. In addition, Facilities and landscaping planted for EDF Energy’s use of the site would be retained for Induction Centre the post-operational phase. M5, Junction 24 Park In general, the proposals to incorporate the facility on an existing developed and Ride and Freight site, which forms part of a larger corridor of development incorporating Management storage, distribution and light industrial development means that the site Facilities and demonstrates consistency with landscape objectives. Furthermore, the Temporary proposals to make use of the existing ‘ambient building’ for car parking, may Postal/Courier further assist to support the objectives. Consolidation Facility and Induction Centre Williton Park and EDF Energy has relocated its proposals for a park and ride facility in Williton Ride from a greenfield site to a brownfield site in response to consultation. The site is now located on an existing lorry park/depot and storage area, on the B3190. The previously developed site includes existing landscape screening, which would be supplemented with additional landscape planting. In general the sustainability objectives to protect the landscape will be met through EDF Energy’s proposals. This will be supported by good site management practices, implemented through an EMMP, which will further reduce impacts on local receptors.

d) Summary 3.9.14 The size and location of HPC will inevitably impact the surrounding landscape. The proposals for the HPC Project will not significantly affect nationally important landscape features, but nonetheless there will be minor adverse impacts on landscape character and tranquillity. National advice is that projects should be designed carefully, taking account of environmental effects on the landscape and siting, operational and other relevant constraints, to minimise harm to the landscape, including by reasonable mitigation. The proposals for the HPC Project accord with this advice. Given the status of the designations, arguably the most important objective under this theme could be considered to be to avoid adverse impacts on nationally important landscapes, which will subsequently be met overall. With regard to performance of the project against the objective on landscape character, quality and tranquillity, in general there will be a negative relationship during construction (short–term) due to the impacts from construction activities, however during operation there is generally a neutral relationship with this objective.

Sustainability Statement | October 2011 111

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

3.10 Soils, Geology and Land Use

a) Background 3.10.1 The conservation of soil quality and maintenance of greenfield land are key sustainability objectives in the UK. Due to the potential impacts that might arise from a construction project of the scale of the HPC Project, the Government has identified three sustainability objectives under this theme:

• to avoid damage to geological resources; • to avoid the use of greenfield land and encourage the re-use of brownfield sites; and • to avoid contamination of soils and adverse impacts on soil functions.

b) Planning Policy 3.10.2 A broad range of policies that are relevant to these objectives are given in Part 4 . The UK Sustainable Development Strategy - Securing the Future, identifies the prudent use of land as a priority for the UK. The Overarching NPS promotes the use of brownfield sites and the efficient use of land where possible. However it acknowledges that this may be impractical for the majority of new energy infrastructure projects:

“Although the re-use of previously developed land for new development can make a major contribution to sustainable development by reducing the amount of countryside and undeveloped greenfield land that needs to be used, it may not be possible for many forms of energy infrastructure”. (Paragraph 5.10.3)

3.10.3 Where development on greenfield sites is necessary, the Overarching NPS identifies the importance of protecting the best quality agricultural land:

“Applicants should seek to minimise impacts on the best and most versatile agricultural land (defined as land in grades 1, 2 and 3a of the Agricultural Land Classification) and preferably use land in areas of poorer quality (grades 3b, 4 and 5) except where this would be inconsistent with other sustainability considerations.” (Paragraph 5.10.8)

3.10.4 The Overarching NPS also states the following:

“Applicants should also identify any effects and seek to minimise impacts on soil quality taking into account any mitigation measures proposed. For developments on previously developed land, applicants should ensure that they have considered the risk posed by land contamination.” (Paragraph 5.10.8)

3.10.5 Policies for the protection of land, soil and geological resources are to be found in RPG10 and in local planning policies.

112 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

c) Sustainability Performance i. To Avoid Damage to Geological Resources 3.10.6 The construction work required for the HPC Project has the potential to damage geology. This is particularly the case with the construction of the sea wall, which will protect HPC from coastal erosion. The Sea Wall would obscure the cliff exposure for the lifetime of the sea defence system and the toe and rock armour protection of the structure would extend a small way onto the foreshore and would have a limited but permanent impact on the foreshore geology. Whilst this is the case, such geology is not unique to Hinkley Point. High quality replication of the geology found within the cliffs and characteristics of the foreshore can also be observed elsewhere within the local area. As such, the Environmental Statement (Volume 2, Chapter 14) concludes that the loss of cliff exposure and foreshore as a result of these works does not result in a significant loss of the relevant geological or geomorphological features present at Hinkley Point.

ii. To Avoid the Use of Greenfield Land and Encourage the Re-use of Brownfield Sites 3.10.7 The development proposals will inevitably require additional land take and loss of greenfield land relative to the present situation. A sustainable approach to design has been a principal consideration from the outset in developing the master plan. The first proposals for the permanent site development involved a site area of approximately 110ha. As iterations for the master plan developed, a consideration for the strategic development has been to limit the site development area to create a proposal with an optimum site area and a minimised site boundary. Accordingly, the final master plan proposals have an area of 67.5ha for the permanent development. This is a reduction in footprint of approximately 40% from those considered at the outset of the design process, reflecting how EDF Energy has maximised the efficiency of land use.

3.10.8 Furthermore surveys carried out at the main site indicate that the majority of the HPC development site falls within ALC Grade 3b, which is soil of moderate quality. The development of this land would be in accordance with the Overarching NPS, which seeks to avoid the loss of the best and most versatile agricultural land.

3.10.9 Whilst the proposals for using greenfield land are not supported by a number of planning policies, the Overarching NPS acknowledges that the re-use of previously developed land may not be possible for many forms of energy infrastructure. The Government has shown a preference through the SSA for locating nuclear new build next to existing nuclear sites. The AoS Site Report for Hinkley Point was therefore based on the nomination of land next to the existing HPA and HPB complex. Key attributes of Hinkley Point which led to its nomination include:

• The site is adjacent to an existing nuclear operation. There has been a nuclear power station at Hinkley Point since 1965 and the community is familiar with the technology and the employment opportunities it offers. • Hinkley Point is connected to the National Grid transmission system, although upgrades and reinforcement will be required. • The provision of direct cooling using water from Bridgwater Bay is established, and is the preferred option for new nuclear development.

Sustainability Statement | October 2011 113

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

• Ground conditions are considered suitable for development. • Environmental impacts are considered to be less significant in comparison with impacts from alternative sites.

3.10.10 These attributes are considered to be in accordance with national policy.

3.10.11 Whilst acknowledging that some impact on greenfield land will occur, EDF Energy has demonstrated its intent to minimise this impact. It is proposed that a large area of land (approximately a third) required for the construction of the HPC Project will be reinstated following decommissioning of the construction areas. Temporary development will also be reinstated. Further details are provided below.

iii. To Avoid Contamination of Soils and Adverse Impacts on Soil Functions 3.10.12 The Soil Strategy for England (2009) states that the gradual build up of pollutants in soil over many decades is a serious threat to soil functioning. The presence of pollutants can adversely affect soil biota necessary for a healthy functioning soil, as well as plants and other animals. The construction activities at the HPC development site and a number of off-site associated development sites will involve the stripping of a significant amount of top soil and various other earthworks. Further soil pollution may also be incurred during general construction and operation of the HPC Project. These impacts will be minimised by utilising best practice in the management of soils throughout the construction process:

• All soils will be managed in accordance with Soil Management Plans which will conform to CL:AIRE Code of Practice: The definition of Waste: Development Industry Code of Practice. • Soils will be stored in the short and longer term in accordance with best practice for soil storage. For example, spoil heaps and soil stockpiles will conform to latest Environment Agency standards and Defra (2009) guidance to limit their height and bank profile, and will be seeded with native grass mix and fenced.

iv. Off-site Associated Development 3.10.13 A number of off-site associated developments are located on agricultural land. EDF Energy has attempted to minimise land take as far as possible with the proposals, aiming to use land as efficiently as possible. It has also demonstrated a commitment to using brownfield sites, and since the Stage 2 Consultation it has preferentially moved the facilities at Junction 24 and Williton to brownfield sites and reduced the size of the HPC accommodation campus. It is also of relevance to note that the large majority of the associated development is proposed to be temporary. The intention will be to return the sites to greenfield land, unless a more beneficial alternative is favoured. Table 3.8 below provides a summary of key issues for off-site associated development. Further details on the choice of sites are detailed within the Alternative Sites Assessment (ASA). This sets out the process for the selection of the most suitable and appropriate sites for the associated development. The methodology is described in Section 1.2 of that document.

114 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Table 3.8: Implications for Objectives for Soil, Geology and Land Use from Off-Site Associated Development & HPC Accommodation Campus Associated Key Sustainability Issues and Initiatives Proposed Development Site Accommodation The worker accommodation at Bridgwater A and C is located on brownfield Campuses land. Particularly for Bridgwater A, due to the former use of the sites for heavy industrial processes, soil contamination is highly likely. Remediation is proposed to a standard to allow for residential use of the site. The design of the accommodation campuses will maximise development density as far as possible, and remediate land where necessary. The on-site accommodation campus would be located on greenfield land. The preparation of the site would require levelling. Best practices would be followed to protect soils. Cannington Bypass The bypass would be constructed on predominantly agricultural land, the majority of which ranges from Grade 2, very good agricultural Land, to Grade 3b, moderate quality agricultural land, although some best and most versatile land (BMVL) will be taken for the bypass during construction. Notwithstanding this, the development uses less land than previous options considered and dismissed following Stage 1 and Stage 2 consultation. In particular, it is 1.5 km in length, compared with 3.5 km for the potential eastern route. Cannington Park and The site is located on greenfield land with ALC Grade 3b, which is not BMVL. Ride It is proposed that the site will be restored to greenfield land following the construction of the HPC Project. A post-Operational Scheme will be enacted and soil will be stored in accordance with the HPC Off-Site Associated Developments Soil Management Plan. Combwich Wharf The development of the Combwich freight laydown facility and the Refurbishment and enhancement to the access road will be sited on greenfield land of ALC Extension and Grade 3b, which is not BMVL. Associated Freight Stringent soil protection measures will be employed, involving storing topsoil Laydown Facility and subsoil separately during operation of the facility, and reinstating them appropriately in the restoration phase to re-establish natural soil profiles. Best practice measures will be employed at all times to prevent leaching and degradation of soil quality, for example not carrying out soil work in wet conditions. M5, Junction 23 Park The site is located on greenfield land. The land to be developed is classified and Ride, Freight as ALC Grade 3b, which is not BMVL. Management and Stringent soil protection measures will be employed, involving storing topsoil Postal/Courier and subsoil separately during operation of the facility, and reinstating them Consolidation appropriately in the reconstruction phase to re-establish natural soil profiles. Facilities and Best practice measures will be employed at all times to prevent leaching and Induction Centre degradation of soil quality, for example not carrying out soil work in wet conditions. M5, Junction 24 Park The Junction 24 site is located on brownfield land, previously occupied by and Ride and Freight Somerfield. Due to the limited construction works needed, it is not Management anticipated that impacts will occur on soils or a greater threat of Facilities and contamination to arise. EDF Energy’s proposals to locate the site on Temporary brownfield land following Stage 2 Update consultation demonstrate Postal/Courier consistency with the objective to avoid Greenfield sites. Consolidation Facility and Induction Centre Williton Park and Williton park and ride is located at the site of a former lorry park. EDF Ride Energy’s proposals to locate the site on brownfield land following Stage 2 consultation demonstrate consistency with the objective to avoid Greenfield sites.

Sustainability Statement | October 2011 115

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

d) Summary 3.10.14 EDF Energy nominated the HPC site into the Government’s SSA Process. The Government’s position on the siting of nuclear power stations has been to make use of existing sites. In the case of HPC, the Government’s SSA concluded that the nominated site was an appropriate location. However, in order to develop HPC it will be necessary to make use of greenfield land, both at the HPC development site and for certain off-site associated development. Whilst this conflicts with the objective to avoid the use greenfield land, national policy recognises that this may be unavoidable. EDF Energy has taken steps to reduce the use of greenfield land wherever possible, and has demonstrated that it is working towards this objective by moving a number of sites during the planning process onto brownfield land. It has also attempted to minimise land-take wherever practicable.

3.11 Water Quality and Resources

a) Background 3.11.1 Water quality is a key issue identified by the Government in the AoS of the Nuclear NPS. The Government identify that infrastructure development can have adverse effects on the water environment, including groundwater, inland surface water, transitional waters and coastal waters. During the construction, operation and decommissioning phases, it can lead to increased demand for water, involve discharges to water and cause adverse ecological effects resulting from physical modifications to the water environment. Accordingly, the following objectives have been developed to avoid impacts on:

• surface water hydrology and coastal geomorphology; • water quality, including coastal and marine water quality, and assist in the achievement of Water Framework Directive objectives; • supply of water resources; and • groundwater quality and distribution.

b) Planning Policy 3.11.2 The Water Framework Directive (WFD) establishes a framework for the protection of surface fresh water, estuaries, coastal water and groundwater. The purpose of the directive is to enhance the status and prevent further deterioration of aquatic ecosystems and associated wetlands. The IPC is guided towards the protection of water quality within the Overarching NPS as well as nuclear specific impacts outlined within the Nuclear NPS. In general:

“The IPC will generally need to give impacts on the water environment more weight where a project would have an adverse effect on the achievement of the environmental objectives established under the Water Framework Directive”. (Paragraph 5.15.5)

3.11.3 Policies for water quality and resources are also identified at regional planning level through RPG 10 and Environment Agency River Basin Management Plans, which attempt to deliver desirable environmental outcomes by establishing policies for ground and surface water quality. Local planning policies aim to reduce impacts on

116 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

water quality through appropriate design and location of development, and reduce pressure on water as a resource by giving specific consideration to water efficiency.

c) Sustainability Performance i. The HPC Development Site and On-site Associated Development 3.11.4 The AoS Site Report for Hinkley Point has identified potential adverse effects from new coastal defence work and installation of cooling water pipes on coastal processes, hydrodynamics and sediment transport, which may have indirect effects on internationally designated habitats. Additional strategic impacts were identified to include:

• thermal and chemical impact of cooling water discharges and the potential impacts this may have on internationally designated sites; • increased demand on water during construction phase, with similar impacts associated with wastewater production on site; • the cumulative effects through interrelations with other projects such as Oldbury and the Severn Tidal Barrage; and • potential impacts on local groundwater bodies.

ii. To Avoid Impacts on Surface Water Hydrology and Coastal Geomorphology 3.11.5 The Environmental Statement outlines a number of potential impacts on surface water hydrology as a result of the construction of the HPC Project. These impacts have been assessed by giving appropriate weight to the importance of the surface water hydrology in relation to sensitive receptors and the ability of the water body to withstand impacts.

3.11.6 With regard to surface water, Holford Stream and Bum Brook are surface water features that supply the Bridgwater Bay Site of Special Scientific Interest (SSSI). The Holford stream will be culverted alongside its entire length. Water quality and quantity will be maintained during construction through the application of Water Management Zones located at either end of the culvert length. These will restrict sediment laden water from entering the stream, and ensure that greenfield run off rates may be maintained, causing a stable water supply to the SSSI. During all phases of the development, the surface water drainage systems will be fully compliant with applicable legislation, regulations and guidance. The primary measures EDF Energy is putting forward include:

• The development of an Incident Response Plan; • Site specific Water and Sediment Management Plans; and • Designation of a series of Water Management Zones across the HPC development site to attenuate and treat water to ensure that flow rates and chemical quality are acceptable prior to discharge into local surface water features.

3.11.7 Coastal hydrodynamics and geomorphology has been assessed as part of the EIA. The Bristol Channel and Severn Estuary have been extensively studied with regard to coastal geomorphology and hydrodynamics. It is considered that the principal issues include the construction of the sea wall and construction drainage across the

Sustainability Statement | October 2011 117

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

foreshore as well as the construction, operation and dismantling of the temporary jetty. Further details are available within the EIA.

iii. To Avoid Impacts on Water Quality, including Coastal and Marine Water Quality, and Assist in the Achievement of WFD Objectives 3.11.8 Activities associated with preliminary works and construction activities at HPC that could impact on water quality have been evaluated within the Environmental Statement.

3.11.9 During construction, the movement of heavy plant, stripping and exposure of soil areas, levelling of ground, and stockpiling and placement of fill materials, have the potential to generate sediment laden surface water run-off. The release of sediment will be managed, where possible, by adopting working practices through an Environmental Management and Monitoring Plan (EMMP). This includes:

• adopting watercourse buffer zones and restricting access for plant movement; • the adoption of relevant Environment Agency Guidance; • employing grit trap/oil interceptors designed and constructed to be suitable for the proposed facilities; and • further details are available within the HPC Site Preparation Works ; Ground Water and Surface Water Management Plan , and the equivalent document for the HPC Development Site.

3.11.10 The discharge of sediment into the marine environment has also been considered. The Bristol Channel in the vicinity of Hinkley Point is characterised by high suspended solid concentrations. As a result the marine waters have a relatively low sensitivity to potential change associated with sediment disturbance and discharges of sediment-laden water.

3.11.11 Impacts from accidents and spillages during construction and operation have also been considered. The potential risk of accidents and incidents occurring, and the avoidance and minimisation of their potential effects on water quality would be managed through the adoption of best practice procedures. For example, fuels will be stored within bunded areas, refuelling will only be undertaken in designated areas, and the plant will be well maintained and regularly serviced. In addition, an Incident Management Plan will be put in place to respond to spillage incidents swiftly and effectively. Pollution management equipment will be made available in order to minimise the severity of a potential spillage.

iv. To Avoid Adverse Impacts on Supply of Water Resources 3.11.12 HPC will obtain water supplies from the local water company (Wessex Water). Typical uses of ‘townswater’ on a power station are domestic (for example, for drinking, laundry, showering) and industrial (such as fire protection, pump sealing and process water). The greatest industrial demand will be for process water to be used in the turbine in the form of steam, and in the reactor systems, pumped through closed circuits. The process water is produced by passing the raw 'townswater' through a demineralising system to produce water of very high purity, which protects the power station from corrosion. HPC will require approximately 2,000,000 litres of

118 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

townswater per day to support this process. This will be supplied from a rainwater catchment in the Quantocks.

3.11.13 EDF Energy has considered opportunities to produce potable water through desalination, but has concluded that this not feasible based on the quality of water within the Bristol Channel. Consequently a mains supply will be required to cater for this need. Using a mains supply is preferential to other systems as water will be gravity fed from the Quantocks, and apart from the energy required for its treatment will have a relatively low carbon footprint compared to energy intensive desalination. In addition, HPC will use water more efficiently than the existing station at HPB, which combined with HPA requires approximately 3,000,000 litres per day and generates less electricity.

3.11.14 Furthermore, the largest proportion of water required in operation will be supplied from sea water, which would be circulated at a rate of approximately 65m3/sec for each intake tunnel and reactor unit, cooling the turbines and condensing steam back into water for re-use. This would be pumped into the site through the cooling water infrastructure and will be returned to the Bridgwater Bay. Hinkley Point’s coastal location ensures there is a constant and renewable cooling water source.

3.11.15 The construction of the development will also require a substantial quantity of fresh water. This will be used for concrete batching and other key construction activities, as well as to support the workforce. EDF Energy is exploring a range of measures to manage and where possible, reduce water demand, including:

• the design of facilities to use less water as standard during operation, by introducing best practice water efficiency measures; and • monitoring water use through construction and establishing KPI’s for water use in accordance with industry best practices, with the aim of reducing water use where possible.

3.11.16 The utilisation of rainwater harvesting has been evaluated by EDF Energy, with the aspiration to include this technology where feasible, safe and cost effective. Rainwater harvesting proves most practical on buildings with high occupancy, where water demand to cater for sanitary use is highest. The largest and most occupied building during operation will be the OSC. Due to the necessity of this building to act as a mustering point, in the event of a nuclear incident, rainwater harvesting is not deemed suitable as this presents another pathway for the ingress of radiological material into the building. In any case, the OSC incorporates a substantial green roof, rendering rainwater harvesting less practical. On other buildings forming part of the permanent development site, the suitability of this technology is reduced as a result of concern on feasibility, maintenance considerations or their lower water demand. EDF Energy does however consider that rainwater harvesting will be suitable for the simulator building/training centre. This building will have a relatively high and frequent occupation, and it is subject to fewer constraints than other buildings. It will include collection and storage system designed in accordance with BREEAM credit Wat 5, to provide harvested rainwater to the buildings WCs.

3.11.17 Whilst water usage is expected to increase, Hinkley Point is not within a water stressed area as identified by the Environment Agency (Ref. 73). The Site falls within the Bristol Water region which has a relatively low water stress in comparison to much of the UK. Wessex Water has been consulted on the proposals due to the

Sustainability Statement | October 2011 119

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

needs for upgrade works, and have identified that the demands of the project can be met.

v. To Avoid Impacts on Groundwater Quality Distribution 3.11.18 According to Volume 2, Chapter 15 of the Environmental Statement, the water table at the HPC development site is approximately 8-15 m below the surface. During the construction of HPC, deep excavations will need to be made to facilitate elements of the power station. It will be necessary to undertake dewatering activities to lower the groundwater, enabling a safe working environment. In general ground water quality within and around the HPC development site is good. Assessments have been made as to the potential impacts from the drawdown of contaminated waters and their impacts on the Wick Moor SSSI and other surface water receptors. It is considered that there are generally low risks for potential contamination to migrate to these receptors based on the underlying geological features.

3.11.19 Groundwater has also been considered in operation. HPC will include a sub-surface drainage gallery, to ensure that groundwater does not rise causing potential impacts on building foundations.

vi. Off-site Associated Development 3.11.20 The location of the off-site associated development means it will have minimal impacts on coastal processes, and a number of other water quality impacts that could be expected to arise from the HPC development site. Issues are considered in Table 3.9.

Table 3.9: Implications from Off-Site Associated Development & HPC Accommodation Campus on the Objectives for Water Associated Key Sustainability Issues and Initiatives Proposed Development Site Accommodation The Bridgwater accommodation sites would deliver the objectives. The sites Campuses would be designed to be water efficient, and incorporate efficiency measures in accordance with BREEAM. With regard to water quality, the sites would be designed with the relevant measures to protect surface water from contamination through the adoption of a Water Management Plan. Care will be taken during remediation works to prevent contamination. Cannington Bypass The bypass would be designed to CEEQUAL standards with the aim of limiting water use in construction. Contamination will be limited by adopting management procedures to limit spills and protect surface and groundwater. Furthermore, the northern balancing pond has been designed to include a reed bed system to provide water quality attenuation prior to discharge to field drains. Cannington Park and Recognising the location of Cannington Brook, a number of control Ride measures are being put forward to manage potential impacts. In general care will be taken to limit spillage and sedimentation by following appropriate pollution prevention, careful management of equipment, and adherence to relevant Pollution Prevention Guidance (PPGs). Combwich Wharf A number of watercourses will be maintained during the construction and Refurbishment and operation of the freight laydown facility, achieved through the use of culverts. Extension and Culverts will help to protect these features in the unlikely event of accidental Associated Freight contamination. In general care will be taken to limit spillage and Laydown Facility sedimentation by following appropriate pollution prevention, careful management of equipment, and adherence to relevant Pollution Prevention

120 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Associated Key Sustainability Issues and Initiatives Proposed Development Site Guidance (PPGs). Impacts on marine water have also been evaluated. This primarily includes discharge of contaminated surface water during construction and operation, and sediment mobilisation through Wharf extension and refurbishment. Proposals exist to mitigate these impacts through management techniques, including proposals to reduce sedimentation during construction. M5, Junction 23 Park The facility will incorporate features to prevent contamination of and Ride, Freight watercourses, including all necessary hydrocarbon traps and gullies to Management and prevent pollution during operation. As with other sites, care will be taken to Postal/Courier limit spillage by following appropriate pollution prevention, careful Consolidation management of equipment, and adherence to relevant Pollution Prevention Facilities and Guidance (PPGs). Induction Centre M5, Junction 24 Park The location of the facility on an existing brownfield site, coupled with the and Ride and Freight proposals to largely re-use buildings and infrastructure means that the Management relationship with objectives for water are typically positive. Facilities and Temporary Postal/Courier Consolidation Facility and Induction Centre Williton Park and The location of the facility on an existing brownfield site, coupled with the Ride proposals to largely re-use existing infrastructure means that the relationship with objectives for water are typically positive.

d) Summary 3.11.21 The various objectives for water quality and resources have been considered within the Environmental Statement . In general the impacts have been minimised by giving appropriate consideration to the design and operation of the facility. This has also been an important consideration for off-site associated development. 3.12 Flood Risk

a) Background 3.12.1 Flood risk is a significant sustainability issue and numerous policy documents are in place to limit risks from flooding on new and existing development. Policy aims regarding development and flood risk ensure that flood risk is taken into account at all stages in the planning process to avoid inappropriate development in high-risk areas, and to direct development away from such areas. Where new energy infrastructure is necessary in such areas, policy aims to promote safety without increasing flood risk elsewhere, and where possible, reducing flood risk overall. Long-term, climate change is expected to cause sea levels to continue to rise. This will lead to increased and new risks of flooding within the lifetime of the HPC Project. A single sustainability objective has been identified:

• to avoid increased flood risk (including coastal flood risk) and seek to reduce risks where possible.

3.12.2 In order to address this objective, EDF Energy has considered issues of flooding and has designed its proposals to meet the demanding standards of policy.

Sustainability Statement | October 2011 121

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

b) Planning Policy 3.12.3 The Overarching NPS identifies considerations for the IPC in determining development consent relating to flood risk. As a minimum, the DCO application:

• is supported by site-specific Flood Risk Assessments as appropriate; • incorporates a sequential approach at the site level to minimise risk by directing the most vulnerable uses to areas of lowest flood risk; • gives priority, where possible, to the use of sustainable drainage systems (SuDS); • has incorporated the sequential test as part of site selection; and • ensures that the project is appropriately flood resilient and resistant in flood risk areas, including safe access and escape routes where required, and that any residual risk can be safely managed.

3.12.4 The Nuclear NPS further identifies nuclear specific considerations, which must take into account tsunami and storm surge risk, and be based on upper projections for flood risk from the UK CIP (2009). The requirements of the NPS’s are similar to the requirements set out in wider planning policy. PPS 25 sets out the Government’s objectives for managing flood risk in the planning process. The PPS specifies use of the sequential test to ensure that new development gives full consideration to the risk of flooding. In areas where new development is necessary, policy aims to make it safe without increasing flood risk elsewhere and where possible, reducing flood risk overall. RPG 10 requires that priority will be given to defending existing properties, and suggests that new development should be located in areas with little or no flood risk. Priority will also be given to protecting flood plains and land liable to flooding from development, and using development to reduce the risk of flooding through location, layout and design. There are also local planning policies established by WSC and SDC. The draft SDC LDF Policy D1 identifies that all development proposals in Flood Zones 2 and 3 as defined by the Environment Agency’s Flood Map will only be permitted where the Sequential Test is passed as outlined in PPS25.

c) Sustainability Performance i. The HPC Development Site and On-site Associated Development 3.12.5 In accordance with guidance within the Nuclear NPS, as well as in PPS 25 (2010), a FRA has been prepared which identifies the flood risk from a range of flood sources. In addition, a separate study has been progressed by EDF Energy to identify the risks from nuclear specific impacts, including tsunami and storm surge.

3.12.6 The existing Hinkley Point power station complex is protected from coastal flooding due to the height of the land platform, which itself is protected by defences along the seafront. The risk of flooding from climate change has the potential to threaten the development. To ensure this does not occur, EDF Energy is proposing to raise the principal land platform of HPC to approximately 14m AOD, and to construct a new sea wall to protect the land platform from erosion. The land platform has been specified to tolerate the upper projections identified within the UK CIP 2009 for sea level rise, (H++ scenario).

122 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

3.12.7 The Nuclear NPS and PPS 25 also require that Sustainable Drainage Strategies (SuDS strategies) are promoted as far as possible. SuDS are designed to drain surface water in a sustainable manner, utilising infiltration, storage and attenuation. They are preferred to conventional drainage systems such as underground pipes, which convey water away from a development and to local watercourses as quickly as possible. SuDS were primarily conceived as a means of:

• managing surface water and the associated flood risks in a sustainable manner; • providing water treatment functionality to promote pollution reduction; • providing amenity and aesthetic benefits; and • providing ecological and biodiversity benefits.

3.12.8 SuDS are arranged in a hierarchy which determines the order in which particular innovations should be considered. The HPC permanent development site will result in a significant loss of greenfield land, replaced with hard surfacing. In order to manage increased surface water flows as a result of this, EDF Energy is proposing to collect surface water run-off and divert it to the sea. Whilst this is not a recognised SuDS measure, it will ensure sustainable management of surface water, posing no risk to other developments. During construction, there will be significant temporary impermeable surfacing. SuDS strategies will be implemented to ensure greenfield run-off rates are maintained during construction.

ii. Off-site Associated Development 3.12.9 The flood risk associated with off-site associated development varies between sites located in Flood Zones 1 to 3a.

3.12.10 The sequential approach has been applied to each site, and the Sequential Test implemented where necessary. EDF Energy, in consultation with the Environment Agency considers that the Sequential Test is satisfied by Cannington bypass, Cannington park and ride, Combwich freight laydown facility, the Junction 24 facilities, and the Williton park and ride facility. The application of the Sequential Test at Bridgwater A and C accommodation campuses and Junction 23 identified that these sites provide the most suitable locations for the off-site accommodation campuses within and around Bridgwater and that they can meet a number of wider sustainability benefits; and that there are no suitable campus sites in Bridgwater within Flood Zones 1 or 2. EDF Energy has also demonstrated the need for a park and ride facility in the vicinity of Junction 23 of the M5; and there were no suitable sites available in Flood Zones 1 or 2.

3.12.11 Risks associated with development of these sites include loss of greenfield land, increased impermeable surfacing, and potential losses to functional flood plains. Table 3.10 identifies key aspects from each of the off-site associated development sites, and their assessment against the sustainability objective.

Sustainability Statement | October 2011 123

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Table 3.10: Implications from Off-Site Associated Development & HPC Accommodation Campus on Objectives for Flood Risk Associated Key Sustainability Issues and initiatives proposed Development Site Accommodation The approach taken to drainage strategies varies between the sites. Much of campuses Bridgwater lies within Flood Zone 3a, which is land at risk from flooding. The Flood Risk Assessments utilise the results of available flood risk modelling to help inform the setting of raised floor levels for the developments. A flood evacuation plan has been prepared which conforms to the existing Bridgwater Major Incident Plan (MIP). The Bridgwater A development includes an increase in the permeable site area, reducing run-off considerably. The proposals for the drainage strategy aim to align with the long-term drainage strategy with the North East Bridgwater Masterplan. However there is no guarantee this will be implemented in time; thus EDF Energy’s measures are capable of independent implementation. The Bridgwater C development includes an increase in the impermeable site area, increasing run-off considerably. This is combined with limited potential for SuDS as a result of a number of constraints – particularly the made ground and domestic waste which underlie the site and may be contaminated, leading to potential mobilisation into surface and/or groundwater. Notwithstanding this, the design does include permeable paving on the access road. Additional considerations include the application of an underground holding tank, which discharged surface water into a combined sewer at an agreed rate with Wessex Water. Although this is less favourable against the SuDS hierarchy. The on-site campus is located in Flood Zone 1. In all cases, the proposals for drainage will be designed to standards within PPS 25, including adopting drainage strategies which make use of SuDS where practical. Developments are designed to withstand particular exceedance thresholds, ensuring they are not affected by the 1 in 100 year flood. Cannington Bypass The development site lies mainly within Flood Zone 1 (I.e. an area of low probability of flooding) although where the route crosses Mill stream, the land is located in flood zone 2 and 3a. The scheme has been designed to take account of flood risk, including increased intensity of future rainfall and incorporate culverts and surface water drainage, which includes filter drains and balancing ponds to reduce discharge to greenfield rates. Cannington Park and Cannington park and ride has been designed to avoid a flood risk area to the Ride west of the site. There is also a functional floodplain (Flood Zone 3b) which follows the Cannington Brook to the south of the site. The proposals for the park and ride include permeable paving and a detention pond to ensure greenfield rates are maintained. Combwich Wharf The proposals for Combwich freight laydown facility will introduce a Refurbishment and significant area of new surfacing to the existing site. Sufficient attenuation Extension and capacity will be delivered by four attenuation ponds. Impermeable surfacing Associated Freight is unavoidable due to the substantial loadings and turning movements of Laydown Facility AILs and HGVs. To provide a simple and easily maintained system, combined kerb and drainage blocks (Beany Blocks) will be used to collect runoff, by bounding each area and conveying any flows to connecting pipework to the upstream ends of the ponds. The combination of measures is intended to maintain greenfield run-off rates for the site, including increased attenuation for climate change (5%) in accordance with PPS 25. Drainage from Combwich Wharf will occur into Combwich Pill. M5, Junction 23 Park The site is within an area at high risk of flooding (Flood Zone 3a) due to its and Ride, Freight location close to the River Parrett. Discharge into the river is unrestricted at Management and certain stages of the tide, to ensure that flood risk is not exasperated. An

124 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Associated Key Sustainability Issues and initiatives proposed Development Site Postal/Courier engineered drainage solution is required during the ‘tidal lock-in’ time period Consolidation when direct discharge is not possible. The proposals include increased Facilities and attenuation capacity by way of a detention pond. Permeable paving will be Induction Centre utilised where practical. Design considers the legacy of the proposed development, and enables the site to be reinstated to arable use if this is ultimately required. M5, Junction 24 Park This site is located completely in Flood Zone 1, meaning it has a low risk of and Ride and Freight flooding. There will be no increase in impermeable area associated with EDF Management Energy’s proposals to utilise the site. The proposals would make use of Facilities and existing drainage infrastructure currently serving the site, which is considered Temporary appropriate. Postal/Courier Consolidation Facility and Induction Centre Williton Park and This site is located completely in Flood Zone 1, which is a low risk of Ride flooding. Due to the current uses it is proposed that the drainage strategy ties into existing uses as far as possible. The proposed strategy involves draining surface water from the site using an attenuated connection into the existing ditch located to the south of the site. This existing ditch is particularly shallow, and thus slot and kerb drains will be adopted to collect and convey surface water before this drains into a swale, and then a piped network. The maximum discharge rate will allow for the 1:100 year runoff rate.

d) Summary 3.12.12 The most significant issue is the development and flood resilience of HPC. This has been achieved in design, which includes a strategy which takes account and where necessary is adaptable to future climate change. The development of the site meets with the sustainability objective to avoid increased flood risk, and whilst increased impermeable surfacing has been included, it will be appropriately attenuated, ensuring no risks to others. All other sites meet with the Sequential Test and address SuDS where possible. 3.13 Materials and Waste

a) Background 3.13.1 The Sustainability theme for materials and conventional waste was not identified by the Government during the AoS of the Nuclear NPS, although has been identified as a separate theme within this Sustainability Statement because of the wide range of regional and local policy objectives which support this. These are outlined below, and further presented within the Sustainability Appraisal ( Part 4 ). EDF Energy has established two objectives under this joint theme, which are:

• to promote the sustainable use of materials; and • to minimise waste and apply principles of Waste Hierarchy.

3.13.2 These sustainability objectives were presented at Stage 2 consultation on the preferred proposals, where their inclusion was noted and welcomed.

3.13.3 This section identifies the measures that EDF Energy would employ to deliver these sustainability objectives. It should be read alongside the Waste Management Implementation Strategy .

Sustainability Statement | October 2011 125

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

b) Planning Policies and Guiding Strategies 3.13.4 The Waste (England and Wales) Regulations 2011 (Ref 3.14) sets out the Government’s overall approach to the collection, recovery, transport and disposal of waste. It provides a framework to implement the waste hierarchy. The main elements the which are to provide a guide for sustainable waste management, identifying how waste should be managed through prevention of waste; preparing for reuse; recycling; recovering energy from waste in preference to final disposal (landfill), which is regarded to be the least sustainable outcome. This has long been demonstrated in PPS 10: Planning for Sustainable Waste Management (2005), which identifies policy aims to produce less waste. Furthermore it suggests using waste as a resource wherever possible.

3.13.5 Regional policies imposed by RPG 10 state that the Government’s aim is that plans and decisions on waste management should choose the Best Practicable Environmental Option (BPEO) based on three considerations: the waste hierarchy; the proximity principle; and regional self-sufficiency.

3.13.6 Policies relating to materials are directed in particular at the use of minerals, including aggregates. The use of recycled and secondary aggregates is encouraged within RPG 10. Local planning policies, including West Somerset District Council policy BD 8 - Reuse of materials, encourages developers to maximise the use of reusable materials on site, including building waste and soil. SDC’s LDF Core Strategy (proposed Submission) Policy D3 requires that sustainable construction principles should be incorporated, including requirements for the sustainable sourcing of materials and their efficient and appropriate use, including their durability, and for efforts to be made to minimise waste and maximise recycling.

c) Sustainability Performance i. To Promote the Sustainable Use of Materials (New Objective) 3.13.7 Given the significant construction work associated with the project, material use is an important sustainability issue of relevance to EDF Energy. It is important to note however, that the ability to achieve this objective varies across the project. Certain elements that constitute the Nuclear Island are required to be constructed from a very specific set of materials, which have been fixed through the stringent safety requirements as assessed in the Generic Design Assessment (GDA) process. EDF Energy has no flexibility to modify these elements to take account of sustainability standards. Nevertheless, where practical and possible to achieve, the design of the main site embodies sustainability principles. Examples include:

• Taking advantage of its favourable properties, it is intended to utilise a significant volume of pulverised fuel ash (PFA), a secondary aggregate derived from coal fired power stations. This proposal will reduce the demand for primary aggregates in the construction project, helping to conserve natural resources. Furthermore, using PFA as an addition to concrete mixes can result in significant CO 2 reductions. • The majority (80%) of bulky materials composing sand, gravel, cement and PFA required for the construction of the HPC will be delivered by sea, via the temporary jetty, which is expected to reduce embodied emissions in transport.

126 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

• EDF Energy will develop a sustainable materials policy, which will be issued to main contractors. The policy will set out EDF Energy’s aspiration for achieving high standards of sustainability where flexibility exists to do so. This will include the application of a materials blacklist. EDF Energy will require that all contractors demonstrate how this policy will be adhered to. This will be in the form of a strategy submitted back to EDF Energy and including information detailing, but not limited to, how contractors will work with supply chains and how Modern Methods of Construction have been maximised and opportunities will be explored for diverting local waste streams for re-use. • 100% of Tier 1 suppliers will have an EMS. • At least 90% of timber for the project will sourced in accordance with FSC requirements across the project.

3.13.8 The above requirements and targets for sustainable materials will also be adopted for off-site associated development. In this instance, the specification of materials is more directly influenced by the BREEAM and CEEQUAL methodologies, which are being used as a principal way of demonstrating the sustainability of these sites. Both assessment methodologies award credits for sustainable material use, and this has been considered by the design team. EDF Energy intends to select major building elements, hard landscaping and fencing which rate highly against the BRE Green Guide to materials (targeting A-C). Where possible, aggregate will be reused directly on site (such as in the case of Bridgwater A), or alternatively sourced from within the region. Further information on the sustainability of the materials proposed is available in the Design and Access Statements.

ii. To Minimise Waste and Apply Principles of the Waste Hierarchy (New Objective) 3.13.9 Sustainable waste management involves minimising the amount produced and dealing with it effectively to minimise its impact on the environment. The Waste Hierarchy provides the framework for sustainable waste management in the UK. These principles will be reflected during site preparation, construction and operation, and the re-instatement of the temporary associated developments. They will eventually be considered in the Site’s decommissioning. The sustainable management of waste for the project is also informed by principles of using Best Available Techniques (BAT); compliance to relevant regulatory requirements; and giving consideration to a full range of health, safety, environmental, economic and social issues. A Waste Management Implementation Strategy has been developed which sets out how waste will be addressed.

3.13.10 There are a number of targets identified from regional planning which require that waste is diverted from landfill to recycling. Within the South West Regional Waste Strategy 2004 – 2020 (SWRA), a strategic target exists that by 2020, 45% of the waste arising in the region is recycled and reused and less than 20% produced in the region is sent to landfill. The proposals for the HPC Project will exceed these standards. Calculations presented by EDF Energy demonstrate that in excess of 90% of engineering, construction and demolition materials (including excavated soils, but excluding hazardous wastes) could be diverted from landfill by following a hierarchical approach to waste management. The following illustrations highlight how EDF Energy will achieve this:

Sustainability Statement | October 2011 127

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

• EDF Energy proposes to reuse all material arising from preliminary works (with the exception of hazardous waste or unsuitable material) on the HPC development site. This will be redistributed to create a land platform and also be used for landscape bunding. • Due to the scale of the project, it is proposed that the very large majority of waste will not be treated directly on-site (the exception being vegetative waste which may be composed or mulched for use on landscaping). Instead, it will be sent to existing waste management infrastructure within the surrounding and wider area around Hinkley Point. EDF Energy has undertaken an analysis of local and regional waste management facilities to identify the availability of such facilities, selecting favourable sites according to their proximity. There are presently very limited local facilities to cope with this waste, which requires EDF Energy to look more widely within the region for waste management facilities. To ensure that these sites are not unduly overburdened, EDF Energy proposes to spread its demand across a number of facilities. • There is also a proposal to segregate materials and sell direct to market, reducing impact on Materials Recycling Facilities (MRFs) and Waste Transfer Stations (WTSs). • EDF Energy will require contractors to explore the opportunity for maximum use of standardisation, prefabrication and modularisation techniques in construction. This reduces wastage of materials during construction. A practical example is the proposal to utilise modular buildings for the construction of the accommodation campus buildings. Separate from this, many of the components of the UK EPR design are based on modular systems, structures and components fabricated away from the HPC development site. • Buildings employed only for the construction period will be subject to pre- demolition audits to identify re-usable and recyclable materials to reduce waste during the demolition process. Demolition materials will be subject to WRAP quality protocol to demonstrate that they are fit for purpose before they are reused. • All construction projects will prepare and implement a Site Waste Management Plan (SWMP).

3.13.11 When analysing the waste profile of the project, a particular issue is associated with reinstating temporary associated development sites. EDF Energy will attempt to reduce this peak waste through its developed re-use strategy for temporary buildings. This commits EDF Energy to identifying future uses for temporary developments prior to cessation. In the event that, in the future, direct reuse offers limited potential, the buildings have been designed to be recyclable, with component parts being reusable. However, it is difficult to commit at this stage as markets and demand may change, therefore a re-appraisal will be required prior to the post-operational phases.

128 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Table 3.11: Considerations for Waste and Sustainable Materials objectives for Off-Site Associated Development & HPC Accommodation Campus Associated Key Sustainability Issues and Initiatives Proposed Development Site Accommodation Waste will be generated from the accommodation campuses during Campuses construction, operation and during the post-operational phases. The detailed quantities and procedures in place to reduce waste are outlined in the Waste Management Implementation Strategy . In general the design of each site will follow BREEAM standards, and will look to score highly in the materials and waste sections of BREEAM. The performance against BREEAM in this area is identified within the relevant Predictive BREEAM Assessments, appended to the Design and Access Statements. This will include the application of Site Waste Management Plans, targeting 12.9 m 3 of waste per 100 m 2 of floor area. This is thought possible based on modular construction methods, which will minimise wastage through standardisation and off-site fabrication. The design incorporates a range of measures to reduce waste in operation. It is anticipated that a recycle rate of 50% can be achieved for the accommodation units, which will be facilitated by refuse bins for segregation of waste. In addition, the sharing of waste management facilities across Bridgwater A and C will ensure the efficient management of waste. The HPC accommodation campus will seek to achieve similar recycle targets. The restoration of the Bridgwater A and the HPC accommodation campus presents the greatest concern for waste generation. EDF Energy will identify opportunities to re-use these buildings and plant in accordance with the Waste Hierarchy. Cannington Bypass The most significant waste issue associated with Cannington bypass will be through the surplus overburden created. The design has been optimised to limit the amount of material that will be need to be exported offsite, however it is estimated that approximately 65,000 tonnes of would need to be taken off-site. EDF Energy is exploring opportunities to send this soil material direct to local market (e.g. through a broker) or a materials recycling facility (MRF). With regard to sustainable materials, the design of the bypass uses materials that will meet the standards for adoption by the local Highway Authority (Somerset County Council). This includes blacktop asphalt and a granular sub base, which will include a proportion of recycled material. The site is also being taken forward through CEEQUAL. Cannington Park and The development uses greenfield land, involving soil stripping and storage. Ride Best practice to minimise waste will be implemented – including storage of stripped soils on-site for re-use during restoration of land. There would be some small buildings, including security and welfare facilities, which would be of modular construction. These may lend themselves to direct re-use at a future date. EDF Energy will also explore the opportunity to send stripped vegetation to a local composting facility. Combwich Wharf Given the need to raise the land platform, the construction and restoration Refurbishment and of Combwich laydown facility is expected to have significant requirements Extension and for materials and give rise to significant volumes of waste. Opportunities Associated Freight that will be explored include: Laydown Facility • storage of stripped soils on-site for re-use during restoration of the land; • assessment of the various modular type buildings proposed for their potential for re-use at the end of use on site; • during restoration, sorting of waste and recycling where appropriate. EDF Energy will explore opportunities to sell materials direct to market, which will reduce pressure on local material recycling facilities; and • the sustainability of materials will be considered through CEEQUAL.

Sustainability Statement | October 2011 129

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Associated Key Sustainability Issues and Initiatives Proposed Development Site M5, Junction 23 Park The development uses greenfield land, involving soil stripping and storage. and Ride, Freight Best practice to minimise waste will be implemented – including storage of Management and stripped soils on-site for re-use during restoration of land. Buildings would Postal/Courier typically be of a modular construction. These may lend themselves to Consolidation Facilities direct re-use at a future date. CEEQUAL will be applied to this site. and Induction Centre M5, Junction 24 Park EDF Energy is promoting the Somerfield site at Junction 24 which includes and Ride and Freight an existing developed site with buildings and hard standing. The proposals Management Facilities to make use of this site will limit material requirements and waste relative to and Temporary development on a greenfield site. The site can be taken forward with Postal/Courier relatively limited modifications to the buildings and infrastructure, although Consolidation Facility it will include the construction of a steel parking deck within the ‘ambient and Induction Centre building’, enabling the two storey parking of cars. This will be removed at the end of the operational period of the site. The site may be reused by others, limiting waste. CEEQUAL will be applied to this site.

Williton Park and Ride EDF Energy is also proposing to develop an existing lorry depot and storage area for the purposes of a park and ride. This can be taken forward with relatively limited modifications to the site, again saving materials and waste.

d) Summary 3.13.12 EDF Energy has developed comprehensive plans for the management of waste, which have been taken forward through consultation with the Somerset County Council, the Environment Agency and Somerset Waste Partnership and various waste management suppliers and operators within the locality of Hinkley Point. The project would divert a significant proportion of materials from landfill (over 90% of engineering, construction and demolition wastes), which represents industry best practice. With regard to the performance against the objective for waste. During construction (short-term) and again in decommissioning (long-term), there will inevitably be waste produced, particularly with the restoration of temporary off-site associated developments. However EDF Energy has demonstrated how it is applying the Waste Hierarchy effectively to minimise waste as far as possible.

3.13.13 With regard to sustainable materials, where flexibility exists, EDF Energy will actively pursue the application of these. This will be demonstrated through the proposed application of BREEAM and CEEQUAL standards to certain elements of the project, and also through procurement contracts for suppliers and contractors. This ambition will therefore be realised and continue to be monitored by EDF Energy. These proposals demonstrate that the project meets the objective for sustainable materials, although further details as to how far this can be achieved will be developed with contractors.

3.14 Conclusions of the Sustainability Statement

3.14.1 Sustainability is at the forefront of EDF Energy's corporate strategy, which in turn translates into a Vision and commitment to ensure that the Project is delivered in a sustainable way, meeting social, economic and environmental objectives - the three pillars of sustainability. This Sustainability Statement demonstrates how EDF Energy has sought to achieve sustainability objectives relevant to the Hinkley Point (HPC) Project.

3.14.2 A series of sustainability objectives, 27 in total, have been used to appraise the sustainability of the HPC Project. These have been derived from the Government’s

130 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Appraisal of Sustainability (AoS) applied to the revised draft Nuclear NPS (EN-6), and have been addressed in a framework which ensures that local policies, relevant to the communities of Hinkley Point have been taken into account. In turn, this appraisal process has assisted EDF Energy to develop a sustainability strategy, which is able to identify additional sustainability opportunities available.

3.14.3 Protecting and enhancing the environment is an important element of sustainable development. During its planning process, EDF Energy has undertaken a range of environmental studies and has applied a comprehensive Environmental Impact Assessment (EIA), consulted on widely with statutory and non statutory consultees. EDF Energy’s approach has been firstly to attempt to avoid environmental impacts from occurring, aiming that that the necessary elements of the project are implemented in a way which avoids the most environmentally sensitive features. In addition to this, EDF Energy has applied the EIA process to identify potential impacts that might arise from the HPC Project. Where potential impacts have been identified, the process aims to present appropriate mitigation to reduce the significance of effects. EDF Energy’s activities to avoid impacts from occurring, combined with its proposals for environmental mitigation, have been key to demonstrating how environmental objectives can be accomplished.

3.14.4 Social and economic outcomes are also an important dimension for EDF Energy. The development of HPC has strong potential to deliver social and economic objectives. EDF Energy has developed a series of strategies, and is undertaking various activities to ensure that the project is able to deliver positive social outcomes and meet economic objectives.

3.14.5 The sustainability appraisal finds that the HPC Project may be particularly strong at delivering the following:

• The objective to minimise greenhouse gas emissions will be significantly exceeded by the project. The proposals for the long-term, safe, reliable generation of low carbon energy is considered to achieve this, and will be further promoted by EDF Energy’s proposals to manage emissions during the construction of the project. • The objective to create employment opportunities is significantly exceeded by the proposals for the HPC Project. The long-term sustainability of these jobs will be assisted by EDF Energy’s construction workforce development strategy, local business engagement strategy and education inspired strategy as well as by continued support for economic development in Somerset through the Low Carbon Delivery Team. • Objectives relating to human health and well-being will be exceeded, particularly during the operation of HPC. The employment opportunities created by the HPC Project, and enhanced further by EDF Energy’s community based initiatives, reflected in a range of strategies, including a Health Action Plan will play a large part in helping to meet these objectives.

3.14.6 Further details on the appraisal process are available within Part 4 , which includes the Sustainability Appraisal. In sum, the Sustainability Statement demonstrates how EDF Energy, through the development of the Hinkley Point C Project, is demonstrating a triple bottom line approach by meeting social, economic and environmental objectives relevant to the project.

Sustainability Statement | October 2011 131

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

132 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

4. SUSTAINABILITY APPRAISAL

4.1.1 This Part, which is presented as an appendix to the preceding parts, provides the Sustainability Appraisal for the Hinkley Point C project, which is made against the comprehensive Sustainability Framework developed by EDF Energy and described in Part 2 . It contains the detailed sustainability considerations which have informed the Sustainability Statement presented in the preceding Part 3 .

4.1.2 The purpose of the appraisal is to provide a transparent and objective process by which the sustainability of the proposed new nuclear power station at Hinkley Point C can be assessed.

4.1.3 The project level Sustainability Framework for Hinkley Point C has been updated and amended subsequent to the Stage 2 consultation, where an initial Sustainability Evaluation was undertaken. This updating has included a review of the AoS of the Nuclear NPS which was later approved by Parliament and designated by the Secretary of State in July 2011. Additionally, it has also been informed by the AoS Site Report for Hinkley Point C, which fed into the Government’s Strategic Siting Assessment (SSA) for new nuclear power stations. The Sustainability Framework therefore draws on both documents.

4.1.4 The review of the AoS of the Nuclear NPS was undertaken to formulate the sustainability objectives, which form the basis of the Sustainability Framework. A total of 25 objectives have been identified from this review, which relate to a range of social, economic and environmental aspects of sustainable development. The Framework has been structured as a simple set of tables, one per objective, and these are grouped and presented under 13 sustainability themes.

4.1.5 A comprehensive desk based review has been undertaken to identify relevant national, regional and local policy drivers, and their associated objectives, which themselves contribute to the sustainability objectives. The regional and local objectives are typically more specific. Together, the national, regional and local objectives provide the context for which the sustainability of the proposed new power station is assessed.

4.1.6 This review also identified that two additional sustainability objectives should be formulated, with regards to the issues of materials and conventional waste. These objectives were not considered by the Government at a strategic level, however are considered of relevance in accordance with regional and local planning policies and in the context of specific scheme proposals. Overall, a total of 27 objectives have been identified. These were first presented at Stage 2 consultation.

4.1.7 Drawing together both the policies and overarching sustainability objectives to forge a coherent Sustainability Framework has allowed the scheme proposals to be systematically assessed by demonstrating the extent to which compliance with the relevant sustainability objectives are being achieved.

Sustainability Statement | October 2011 133

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

4.2 Sustainability Appraisal Methodology

4.2.1 There is no specific guidance on the methodology to follow for a sustainability appraisal of projects. Different approaches can be taken. The approach taken by EDF Energy has been developed based on recognised best practices, and is largely consistent with the approach taken by the Government in the AoS. Certain modifications have been made to the scoring system to take account of applying the objectives at the project level. Much of the data which has informed this appraisal has been derived from relevant information arising from the EIA process, other technical environmental reports and additional supporting information, all of which have been prepared to support the application for Development Consent as described in Part 2 .

a) Identifying Appraisal Questions 4.2.2 Following the identification of the relevant sustainability appraisal objectives, a series of appraisal (guide) questions were defined and used to determine the way in which the proposal would be appraised. In line with recognised best practice, EDF Energy has adopted the same guide questions that were used by the Government in the AoS. A number of additional guide questions have been formulated to identify how the proposals meet with relevant regional and local issues. The aim was to identify guide questions that are simple, practical and able to demonstrate whether the objective has been achieved. They also need to be feasible and relevant to the Project. Guide questions have been included within the relevant appraisal sections of this appendix. Additional guide questions, formulated specifically for this appraisal are marked with an asterisk (*).

b) Assigning timescales 4.2.3 Sustainability appraisals typically assess performance against objectives over time, allowing an assessment to be made of different stages of the project. Accordingly, the appraisal considers how the project meets the sustainability objectives over short, medium and long timescales. For the purpose of the appraisal, short-term (S) relates to the period of construction, medium-term (M) to the operational life of the facility, and longer term (L) considers the decommissioning phase/restoration and beyond.

4.2.4 Applying timescales effectively and consistently has been a particular challenge for this appraisal. This is because of the differing lengths of time over which the development will be in use. By way of example, the construction, operation and decommissioning of temporary associated development will broadly occur within the same timescale as the construction of the main site. When referring to the performance of the sustainability objectives over time, the reader should note that this is indicative of the stage of each component of the project, and not linked to any specific dates.

c) Define Scoring System and Significance 4.2.5 The aim of the scoring system is to provide a transparent appraisal process, enabling a clear and demonstrable approach to the allocation of scores. This approach allows consistency in addressing the different sections of the appraisal and provides appraisal results that can be clearly understood. As stated, modifications were made to the scoring system to take account of applying the appraisal at the project level.

134 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

The scoring system adopted is detailed in the table below, which shows the Government’s approach and that taken for this appraisal. These are as follows:

Table 4.1: Sustainability Appraisal Scoring Criteria and Comparison Key to Sustainability Appraisal Significance Category of Effect at Outcome Category of Effect Adopted National Level for HPC Appraisal ++ Major Development actively

Significantly The delivery of the project as Significant encouraged as it would Exceed the a whole will make significant resolve an existing Objective headway in contributing to sustainability problem. sustainability at the Effect considered as regional/local level. The being of objective is significantly national/international exceeded. significance. + Minor No sustainability
Exceeding EDF Energy has supplied Significant constraints and the Objective essential mitigation to reduce development impacts as well as acceptable. Effect sustainability initiatives, and considered of thus the objective is national/international exceeded. significance. 0 No Neutral effect 0 Neutral Mitigation has been applied to Significance (meeting the reduce significant adverse objective effects although there are no however no sustainability issues to additional resolve. On balance the sustainability delivery of the project will benefit) have a neutral effect. - Minor Potentially  Not Meeting The objective has not been Significant sustainability issues; the Objective met, and on balance, there mitigation and/or are impacts from the project negotiation possible. which cannot be mitigated. Effect considered of national/international significance. -- Major Problematic because  Significantly The delivery of the project as Significant of known sustainability below a whole will create significant issues; mitigation or meeting the and unresolvable negotiation difficult Objective sustainability problems at the and/or expensive. regional/local level. Effect considered of national/international significance. ? Uncertainty Where the significance ? Uncertainty Where the outcome against of an effect is the objective is unknown in particularly uncertain, general, or additional i.e. insufficient information would be required information is available in the future to more to fully appraise the accurately determine the effects of the outcome, the score is development or the qualified with a ?. potential for successful mitigation, the significance category is qualified by ‘?’.

Sustainability Statement | October 2011 135

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

4.2.6 The appraisal process has been an important element of EDF Energy’s sustainability strategy, as presented in Part 2 . The Framework on which the appraisal is based has been used to identify sustainability opportunities available for the project. The way in which it has influenced the sustainability of the scheme is shown diagrammatically in Figure 4.1 .

Figure 4.1: Approach to the Sustainability Appraisal for HPC and its influence on the Sustainability Strategy

136 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

4.3 Sustainability Summary

Sustainability Theme Sustainability Objectives Sustainability Outcome S M L

Air Quality • To avoid adverse impacts on air quality. 0 0 0? Biodiversity and • To avoid adverse impacts on the integrity of wildlife sites of international and 0? 0? 0? Ecosystems national importance. • To avoid adverse impacts on priority habitats and species including European 
0? protected species. • To avoid impacts on valuable ecological networks and ecosystem functionality. 0

Climate Change • To minimise greenhouse gas emissions. 

 Communities: • To create employment opportunities.



Population, Employment •

0? and Viability To encourage the development of sustainable communities.  0 0? • To avoid adverse impacts on property and land values and avoid planning blight. Communities: • To avoid adverse impacts on the function and efficiency of strategic transport 
0? Supporting infrastructure. Infrastructure • To avoid disruption to basic services and infrastructure. 0 0 0 Human Health and Well- • To avoid impacts on physical health.



Being 0

? • To avoid impacts on mental health. 0
0? • To avoid loss of access to recreational opportunities, their quality and user

convenience. Historic Environment • To avoid adverse impacts on the internationally and nationally important features if  0 0? historic environment. • To avoid impacts on the setting and quality of build heritage, archaeology and  0 0 historic landscapes.

Landscape • To avoid impacts on nationally important landscapes. 0 0 0

• To avoid impacts on landscape character, quality and tranquillity, diversity and distinctiveness.  0 

Sustainability Statement | October 2011 137

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Sustainability Theme Sustainability Objectives Sustainability Outcome S M L

Soils, Geology and • To avoid damage to geological resources.  0 0 Land Us   0 • To avoid the use of greenfield land and encourage the reuse of brownfield sites.  0 0? • To avoid the contamination of soils and adverse impacts on soil functions. Water Quality and • To avoid impacts on surface water hydrology and channel geomorphology 0 0 0 Resources (including coastal geomorphology). • To avoid adverse impacts on water quality, including coastal and marine water   0 quality, to assist in the achievement of Water Framework Directive Objectives. • To avoid adverse impacts on the supply of water resources.   0?

• To avoid adverse impacts on groundwater quality, distribution and flow and assist achievement of Water Framework Objectives. 0 0 0

Flood Risk • To avoid increased flood risk (including coastal flood risk) and seek to reduce risks 0
0 where possible.

Materials and Waste* • Sustainable use of materials.
0 0

? • To minimise waste and apply principles of the Waste Hierarchy.

138 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

4.4 Air Quality

Policy Drivers Observations/Conflicts between policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts on Air Quality Planning Policy Statement 23: Regional Planning Guidance for the West Somerset District Local Plan All levels of planning policy share the Planning and Pollution Control South West (RPG 10) (2001). Policy (2006) (‘saved’ policies) common objective to limit impacts from (2004) EN2: Air Quality Policy PC/1: Air Pollution new and existing development on air quality. Key to this is the prevention of The PPS provides advice on when air Local authorities should: Developments that generate atmospheric quality should be a material impacts on air quality thresholds, in • Include in their development plans emissions which would cause harm or consideration for planning purposes. place to protect human health, and proposals policies on the location offence to human health, senses or Appendix 1G to Annex 1 of PPS23 vegetation and ecosystems. The of potentially polluting developments property will not be permitted and where states that any air quality Overarching NPS states that the IPC and of sensitive developments in the such uses exist the local planning authority consideration that relates to land use will generally need to give air quality vicinity of existing polluting will not permit sensitive other uses within a and its development is capable of considerations more weight where a developments, in line with guidance reasonable distance of such uses. being a material planning project would have an impact on air in PPS23 (as and when it is updated) Sedgemoor District Local Plan (2004) consideration, and that the impact on quality inside, or adjacent to, an Air and in Air Quality and land use (‘saved’ policies) ambient air quality is likely to be Quality Management Area (AQMA). planning LAQM.G3 (00). particularly important: No relevant objectives or policies. However it is also recognised that • Designate air quality management Sedgemoor District Local Development impacts on air quality should be • Where the development is areas where required as part of the Framework Core Strategy (Proposed considered, even where thresholds are proposed inside, or adjacent to, an local air quality management Submission) (September 2010) unlikely to be breached. air quality management area process. (AQMA) designated under Part IV Policy D4 Renewable and Low Carbon of the Environment Act 1995. • Ensure that air quality considerations Energy Generation are properly considered along with The Council will support proposals that • Where the development could in other material considerations in the itself result in the designation of an maximise the generation of energy from planning process, particularly where AQMA. renewable or low carbon sources, provided any air quality management areas that the installation would not have • Where to grant planning have been designated. significant adverse impact on, amongst permission would conflict with, or other things, the generation of emissions render unworkable, elements of a and noise. local authority air quality action plan.

Sustainability Statement | October 2011 139

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Draft Revised Regional Spatial Policy D9 Sustainable Transport and Strategy (RSS) for the South West Movement Incorporating the Secretary of State’s Proposals will, amongst other things, Proposed Changes for Public contribute to reducing adverse Consultation (July 2008) environmental issues, including air Policy RE9: Air Quality pollution through appropriate mitigation The impacts of development proposals measures. on air quality must be taken into account Policy D10 Managing the Transport and Local Authorities should ensure, Impacts of Development through LDD’s that new development will Developments that will have a significant not exacerbate air quality problems in transport impact should, amongst other existing and potential AQMAs. things, be supported by an appropriate Air This should include considerations of the Quality Assessment. potential impacts of new developments Policy D16 Pollution Impact of and increased traffic levels on Development internationally designated nature Development proposals that are likely to conservation sites, and adopt mitigation result in levels of air pollution that would be measures to address these impacts. harmful to other land uses, human health, Somerset & Exmoor National Park tranquillity, or the built and natural Joint Structure Plan Review 1991- environment will not be supported. 2001 (2000) (‘saved’ policies) No relevant objectives or policies. Appraisal Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts on Air Quality Guiding Question - Will it result in the release of low level radionuclides that may adversely affect human health or biodiversity? With regard to the impacts from radiological emissions on human health, the UK Nuclear Industry is highly regulated, which extends to the strict control of emissions. Operational impacts of HPC have been assessed and process emissions from all activities will not contribute significantly to existing pollutant background concentrations. The assessments follow the work already done during the Generic Design Assessment (GDA) process. The GDA has determined the potential doses to members of the public and a range of non-human species from the operation of an UK EPR reactor unit for a ‘generic’ new build nuclear power station site in the UK.

140 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives The purpose of this work is to demonstrate to the regulatory authorities, that doses to members of the public due to discharges of radioactivity from the UK EPR reactor design will be within relevant regulatory limits. In July 2011, EDF Energy applied to the Environment Agency for Radioactive Substances Regulations (RSR) and Combustion Activity Environmental Permits for the operation of HPC. This included demonstrating how Best Available Techniques (BAT) is applied to optimise the environmental performance. With regards to impacts on biodiversity, this is also assessed as part of the RSR application, which considered impacts on non –human receptors. An assessment of broader, non-radiological pollutants has been undertaken at ecological receptor locations. The principle pollutants, (including Nitrogen and acidic pollutants) linked to nutrient loading has been presented within the Air Quality Assessment, Volume 2, Chapter 12. This has been further analysed within the Terrestrial Ecology and Ornithology 22, Chapter 20 . Guiding Question - Will it contribute to an increase in the number or expansion of AQMAs? The proposed development at HPC is located in a predominantly rural setting on the coastline of Bridgwater Bay. There are no AQMAs located within or in proximity to the Development Site. With the exception of HPA and HPB, which are already subject to strict controls and licensing, there are no other industrial areas within the vicinity of the site which contribute to air quality impact. Air quality impacts arising from the HPC Project have been assessed in Chapter 12, Volume 2 of the Environmental Statement. The significant impacts identified are broadly categorised as follows: • Air quality impacts arising during construction, such as the migration of dust. • Impacts from construction and transport plant. • Releases of pollution, such as the release of NO 2 during periodic testing of backup generators. Emissions associated with HPC are predicted to be most considerable during the construction phase of the development. Key mitigation includes: • Siting development and construction activities away from sensitive receptors. • Using logistics to reduce impacts from vehicles amassing at the development site during construction. This includes management measures and new infrastructure such as four park and ride sites, used to consolidate worker vehicles. • Developing AQMPs for the Preliminary Works and Development Site. • Ensuring landscape planting and bunding is incorporated where appropriate. Air quality modelling identifies that emissions from the routine operation of the EPR units do not pose a significant concern with regards to air quality. Furthermore, the use of diesel powered backup generators for periodic testing will not exceed air quality thresholds based on the duration of their use. Air quality has also been considered for off-site associated development. All areas that have been considered for associated development are not designated to be within, or in proximity to an existing AQMA. Air quality assessment undertaken within the project EIA identifies that there are a number of potential air quality impacts arising from the off-site associated development; these mainly arise during construction activities, however transport related air quality impacts may also occur, particularly in Bridgwater which experiences high levels of NO 2. Further information is provided within Chapter 10, Volumes 3-11 of the Environmental Statement.

Sustainability Statement | October 2011 141

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Summary The Government’s sustainability objective for air quality is to avoid adverse impacts on air quality, in particular to avoid S M L breaching existing air quality thresholds further, and to ensure that no new AQMAs are designated as a result of the proposals. The supporting EIA demonstrates that mitigation has been put in place through Air Quality Management Plans, to assist that air quality is not significantly affected as a result of the proposals. EDF Energy has also considered a range of additional measures which should deliver relative enhancements to air quality. When considering how the proposals meet with this objective, the greatest impacts on air quality are considered to be during 0 0 0? construction, however these effects will be temporary in nature and generally mitigation has been applied to reduce their significance. Impacts are also lessened given existing background levels. Over the medium-term the relationship with the objective is generally neutral in that air quality impacts have generally been avoided. Indeed, the operation of HPC over more polluting power generators may be regarded as a pollution benefit. However, it is important to note that elements of the project, particularly the operation of the bypass will continue to generate air quality pollutants. The relationship of decommissioning the plant longer term has not been formally assessed in the EIA, and therefore there is no evidence base to draw conclusions from. However it is possible to assume that similar impacts will be experienced during the decommissioning phases, as with construction. The relationship has however been qualified.

142 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

4.5 Biodiversity and Ecosystems

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts on the Integrity of Wildlife Sites of International and National Importance Council Directive 92/43/EEC on the Regional Planning Guidance for the West Somerset District Local Plan Within the Overarching NPS, the IPC Conservation of Natural Habitats and South West (RPG 10) (2001) (2006) (‘saved’ policies) are guided by the weight that should be of Wild Fauna and Flora (the EC EU A key objective of RPG is to safeguard Policy NC/1: Sites of Special given to impacts upon biodiversity, Habitats Directive) and enhance the quality and diversity of Scientific Interest particularly on sites of national and international importance. The Directive, also known as the Habitats the natural, cultural and built environment Development proposals which may, Directive, provides a framework for the across the region, giving the highest level directly or indirectly, adversely affect As a general principle, development conservation and management of natural of protection to designated areas and SSSIs will not be permitted unless: should aim to avoid significant harm habitats, wild fauna (except birds) and features of national and international to biodiversity and geological flora in Europe. Its aim is to maintain or importance (Paragraph 4.3). • there are no alternative means of conservation interests, including meeting the development need; and restore natural habitats and wild species RPG 10 Policy EN 1: Landscape and through mitigation and consideration at a favourable conservation status. Biodiversity • the reasons for the development of reasonable alternatives. Where significant harm cannot be avoided, The Conservation of Habitats and Local authorities and other agencies in clearly outweigh the value of the site then appropriate compensation Species Regulations 2010 (the Habitats their plans, policies and proposals, and the national policy to safeguard measures should be sought. In and Species Regulations) should, amongst other things: the nature conservation value of the taking decisions, the IPC should the Habitats and Species Regulations are national network of such sites. • provide for the strong protection and ensure that appropriate weight is the principal means by which the EC EU West Somerset Local Development enhancement of the region’s attached to designated sites of Habitats Directive is transposed into Framework Core Strategy internationally and nationally important international, national and local national law for England, Wales and the Sustainability Appraisal Objectives landscape areas and nature importance; protected species; territorial seas. The Habitats and Species conservation sites. • Protect and enhance biodiversity at habitats and other species of Regulations, inter alia , provide for the all levels. principal importance for the designation and protection of 'European conservation of biodiversity; and to sites', the protection of 'European • Increase the land area of UK biodiversity and geological interests protected species', and the adaptation of Biodiversity Action Plan habitats within the wider environment. planning and other controls for the within the district. protection of European Sites. Offensive This is consistent with other policy • Maintain and improve the actions can be made lawful through the documents, such as PPS 9. conservation status of selected granting of licences by the appropriate At the regional and local planning designated and non-designated authorities. policy levels, emphasis is still given nature conservation sites. to protecting the most valuable habitats, and enhancing habitats in line with national targets.

Sustainability Statement | October 2011 143

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Planning Policy Statement 9 (PPS9) Draft Revised RSS for the South West Sedgemoor District Local Plan (2004) Biodiversity and Geological Incorporating the Secretary of State’s (‘saved’ policies). Conservation (2005) Proposed Changes for Public Policy CNE9 Consultation (July 2008) One of the key principles of PPS 9 is that The nature conservation value of land planning decisions should aim to Policy ENV1: Protecting and outside nationally designated sites will maintain, enhance and restore Enhancing the Region’s Natural and be a material consideration. biodiversity interests. Local Planning Historic Environment Development which would cause Authorities are required to ensure that Where development and changes in land damage will not be permitted unless the appropriate weight is attached to use are planned which would affect these need for the development in that location designated sites of international, national assets, Local Authorities will first seek to is unavoidable and of overriding and local importance; protected species; avoid loss of or damage to the assets importance. and to biodiversity and geological then mitigate any unavoidable damage, Sedgemoor District Local interests within the wider environment and compensate for loss or damage Development Framework Core (p.3). through offsetting actions. Priority will be Strategy (Proposed Submission) UK BAP given to preserving and enhancing sites (September 2010) of international or national landscape, The overall goal of the UK Biodiversity Policy D4 Renewable and Low Carbon nature conservation, geological, Action Plan (UK BAP) is to conserve and Energy Generation enhance biodiversity within the UK. The archaeological or historic importance. The Council will support proposals that UK BAP identifies the most threatened Somerset & Exmoor National Park maximise the generation of energy from biodiversity assets and includes action Joint Structure Plan Review 1991-2011 renewable or low carbon sources, plans for the recovery of priority species (2000) (‘saved’ policies) provided that the installation would not and habitats. Policy STR1 (Sustainable have significant adverse impact taking Development) into account the impact of the scheme, Development in Somerset and the together with any cumulative impact on, Exmoor National Park should, amongst amongst other things, biodiversity other things, conserve biodiversity and Policy D14 Natural Environment environmental assets, particularly All development proposals should nationally and internationally designated contribute to enhancing and maintaining areas. biodiversity, taking into account climate change and the need for habitats and species to adapt to it.

144 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Policy 1 (Nature Conservation) Where development is necessary and The biodiversity of Somerset and the could result in significant indirect or Exmoor National Park should be direct adverse impacts to nature maintained and enhanced. The greatest conservation appropriate mitigation and protection will be afforded to nature compensation measures should be conservation sites of international and provided. national importance. Bridgwater Bay to Bideford Bay Shoreline Management Plan 1998 Where possible, maintain designated Priority habitats (of national and International importance and natural features within the subcell in line with relevant legislation policies. Where possible, preserve critical Natural Capital in situ, maintain the stock of constant natural assets, identify opportunities to create new inter tidal habitats to compensate for past and anticipated future loss, and wherever possible preserve species and wildlife habitats in line with the UK Biodiversity Action Plan. Appraisal Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts on the Integrity of Wildlife Sites of International and National Importance The sustainability objective requires that consideration is given to the how the project impacts upon the integrity of wildlife sites. In this case, ‘integrity’ is taken as: the coherence of its ecological structure and function, across its whole area, that enables it to sustain the habitat, complex of habitats and/or the levels of populations of the species for which it was classified. Guiding Question - Will it result in the loss of habitats of international/national importance? A number of ecological studies have been undertaken to determine the impacts of the project on terrestrial, marine and coastal ecology during the construction and operation of HPC. The principal ecological issue identified by these studies will be the loss of semi-natural habitats and habitat corridors within the HPC development site. An example of this will be habitat loss associated with permanent land take of part of the Bridgwater Bay SSSI.

Sustainability Statement | October 2011 145

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Guiding Question - Will it adversely affect the achievement of favourable conservation status for internationally and nationally important wildlife sites? International and nationally designated sites of nature conservation, including those found in the study area used within the EIA are awarded conservation status based on a range of designation criteria. The Environmental Statement identifies the impacts on sites, by considering how the designation criteria have been affected by the proposal. The principal impacts on the integrity of nationally/internationally important wildlife sites include the loss of sub-tidal habitat for cooling water infrastructure, affecting the SAC; and construction impacts on birds, affecting the SPA and Ramsar site. Mitigation has been proposed these impacts. Further information can be found within the Environmental Statement, Volume 2, Chapters 19 and 20 . Guiding Question - Will it result in thermal discharges that could adversely affect aquatic ecosystems? The development proposals involve the construction of cooling water infrastructure, which has been evaluated for its potential effects on sub tidal habitat, foreshore and intertidal areas. The Environmental Statement identifies that the principal potential effect is the warming of intertidal habitats used by bird species forming the cited interest of the Severn Estuary SPA and Ramsar Site and the Bridgwater Bay SSSI, due to the discharge of cooling water. This could potentially result in changes to foraging resources (intertidal/benthic communities and component species distribution) that could have resulting effects on bird distribution and abundance. The British Energy Estuarine and Marine Studies [BEEMS] programme has modelled likely effects on intertidal and sub-tidal habitats. These studies conclude that the weight of evidence does not support the proposition that the thermal plume will have an effect on the structure of bird prey populations in Bridgwater Bay. It is recognised that thermal regime change is the ecological effect that has the greatest potential to effect the coherency of the ecological structure and function of the European protected site (the integrity of the designation) leading to an effect on the conservation status of one or more bird species forming part of the cited interest of the SPA. This is considered further in the Report to Inform the Appropriate Assessment for the Severn SPA, SAC and Ramsar Site that accompany the application for Development Consent. Further, HPB presently contributes thermal discharge into these ecosystems, and has done so, along with HPA for over 45 years, and studies of Bridgwater Bay mudflats have shown no obvious effects of HPB operations on the populations present. Warming by the HPC thermal plume is thus unlikely to present a major issue. Summary Effects with the potential to have an impact on the integrity of internationally or nationally significant wildlife sites have been identified and an S M L appropriate level of mitigation applied where necessary. In general, it is considered that the significance of impacts on ecological receptors will be limited to ‘minor’ due to these mitigation measures. Such measures include appropriate engineering design and siting of key elements of infrastructure (e.g. the Low Velocity Side Entry (LVSE) cooling water intake design) as well as the incorporation of best practice measures, such as the integration of a Fish Recovery and Return (FRR) system into the engineering design of the cooling water system, 0? 0? 0? such as the use of Acoustic Fish Deterrence (AFD) systems at the intakes themselves. At this stage It is not considered that the impacts identified will affect the ‘favourable’ conservation status of the internationally important wildlife designations, which is a particular focus for the IPC. This has been subject to ongoing assessment work, including an Appropriate Assessment. The impacts on land take for the Bridgwater Bay SSSI will result in the loss of habitats of a nationally important designation which cannot be fully mitigated, although proposals will be put forward to extend habitat under management, to reduce impacts on these habitats as far as possible. Consequently, impacts on construction (short-term) are considered to deliver potential conflicts with the sustainability objective, however not to the extent that a negative relationship is determined. During the medium term, the operation of the power station is not expected to yield significant impacts on the integrity of these internationally and nationally significant designations, and therefore this objective is anticipated to be met, subject to the outcomes of the HRA. During the longer term, the impacts of decommissioning HPC have not been assessed within the EIA and therefore there is a degree of uncertainty surrounding this objective.

146 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts on Priority Habitats and Species including European Protected Species Council Directive 2009/147/EC on the Regional Planning Guidance for the West Somerset District Local Plan All levels of policy place greatest Conservation of Wild Birds (the EC EU South West (RPG 10) (2001) Policy (2006) (‘saved’ policies) emphasis on the protection of most Birds Directive) EN 1: Landscape and Biodiversity Policy NC/4: Species Protection significant ecology as a priority. The Directive, also known as the Birds Local authorities and other agencies in Development proposals which may have Directive, provides a framework for the their plans, policies and proposals, an adverse effect on badgers, otters and conservation and management of wild should: other species protected by law will not be birds in Europe. The most relevant • Draw up policies for the protection permitted unless harm to the species can provisions of the Directive are the of nature conservation interests of be avoided through the use of planning identification and classification of Special regional and local significance; and conditions and/or planning obligations Protection Areas (SPA) for rare or which seek to: vulnerable species listed in Annex I of • Encourage the maintenance and the Directive and for all regularly enhancement of the biodiversity • facilitate the survival of individual occurring migratory species (required by resources of the region, having members of the species affected by the Article 4) and the establishment of a particular regard to the targets set proposal; general scheme of protection for all wild out in tables 3, 4 and 5. • reduce disturbance to a minimum; and birds (required by Article 5). The • Directive requires national Governments provide adequate alternative habitats to to establish SPA’s and to have in place sustain at least the current level of mechanisms to protect and manage population. them. Policy NC/5: Wildlife Habitats The Conservation of Habitats and Habitats and other features of the Species Regulations 2010 (the landscape identified as priorities in the Habitats and Species Regulations) West Somerset BAP, or otherwise of major The Habitats and Species Regulations importance for wildlife, will be protected are the principal means by which the EC and their management and enhancement EU Birds Directives is transposed into encouraged by not permitting damaging national law for England, Wales and the development and where development is territorial seas. The Habitats and permitted, by the use of planning Species Regulations, inter alia , provide conditions, obligations and management for the designation and agreements.

Sustainability Statement | October 2011 147

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives protection of 'European sites', the West Somerset Local Development protection of 'European protected Framework Core Strategy Sustainability species', and the adaptation of planning Appraisal Objectives. and other controls for the protection of • Maintain, restore and enhance European Sites. Offensive actions can populations of focal species. be made lawful through the granting of licences by the appropriate authorities. Sedgemoor District Local Plan (2004) (‘saved’ policies) Policy CNE10 Development proposals which would harm protected or priority species, or their habitats, will only be permitted if the proposal would: • facilitate the survival of a sustainable population of the affected species. • reduce disturbance to affected species to an acceptable minimum; and/or • provide adequate alternative habitats, preferably in situ, to sustain at least the current population levels of affected species. Sedgemoor District Local Development Framework Core Strategy (Proposed Submission) (September 2010) Policy D14 Natural Environment

148 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Appraisal Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts on Priority Habitats and Species including European Protected Species Guiding Question - Will it result in harm to internationally or nationally important or protected species? A number of international and nationally protected species are located within the surrounding area of the HPC development site, A full account of these species is provided within the Terrestrial Ecology and Ornithology Chapter of the Environmental Statement Volume 2, Chapter 20 . The principal potential ecological issues for internationally/nationally important species include: • Disturbance to priority fish species due to piling noise associated with jetty construction (piling) and interruption of migratory passage due to thermal plume. • Potential displacement of over-wintering and passage bird populations due to construction noise, and disturbance to breeding bird populations. • Potential of the construction of the temporary jetty to affect rafting shellduck. • Impingement/entrainment of priority fish species in the cooling water intakes. A key issue identified by the AoS Site Report for Hinkley Point is the potential for visual and noise disturbance to important bird populations. The environmental studies undertaken identify that the waterfowl species most likely to be affected by disturbance resulting from construction on or near to the shore include wintering shelduck, wintering curlew and passage ringed plover. However, mitigation has been put forward and consequently these impacts are not considered to be significant. They would be further minimised by good practice measures to reduce visual and noise disturbance. For example, lighting on the temporary jetty will be left on continuously throughout the night, however positioned so that light spill into the intertidal is limited. This will allow bird species using the intertidal and inshore waters to habituate to the development area rather than being regularly displaced from roosting areas. Potential impacts on priority fish have been identified in the Marine Ecology Chapter of the Environmental Statement Volume 2, Chapter 19 . The principal potential impacts identified include disturbance from piling activities, impacts from the thermal plume and impingement and entrainment of fish in the cooling water intakes. Mitigation has been put forward in the form of soft start piling, the sensitive location of the cooling water outfalls and the inclusion of a Fish Recovery and Return (FRR) system. Further details are provided within the chapter. The most significant issues surrounding off-site associated development on this sustainability objective include those from the extension and upgrades to Combwich Wharf and the construction of the laydown facility and the construction of the Cannington bypass. Measures have been identified to avoid and reduce potentially significant effects on passage and wintering SPA bird species, and to maintain and enhance the conservation value of the area in the medium and long-term in line with planning policy concerning biodiversity conservation. The Environmental Statement concludes that the upgrade to the wharf at Combwich will not result in a significant effect on birds forming the qualifying interest of adjacent statutory designated sites. Appropriate design measures will be employed to protect other species, such as otter and water vole at Combwich. For the Cannington Bypass a range of protected species are present within or make use of the site. Design measures are proposed enable these species to continue to utilise the site (such as through protecting commuting routes), or alternative provisions established elsewhere.

Sustainability Statement | October 2011 149

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Guiding Question - Will it affect other statutory or non-statutory wildlife sites? The Environmental Statement identifies various other direct and indirect impacts on habitats. Specific issues on wildlife sites include: • The intertidal area near to the fore shore is part of the Bridgwater Bay SSSI. The SSSI will be affected by the proposals through direct habitat loss. • EDF Energy has been managing a relatively extensive area of land around the existing power station complex through an Integrated Land Management Plan, which promotes wildlife at the site. The result has been the establishment of a range of habitat types, including flower-rich grassland, woodland, scrub and reed bed. The area has been designated as a County Wildlife Site. The Built Development will result in the Loss of approximately 60% of the Hinkley County Wildlife Site (CWS). However over 40% of the total area of CWS has been avoided through development design. This allows the retention of the most extensive areas of species-rich semi-natural grassland, the still water-bodies of most ecological merit and much of the local scrub. • Whilst the remainder of the site is not a wildlife site, the proposals will lead to the loss of hedgerows, considered as ecologically important under The Hedgerow Regulations 1997; Sixty hedgerows within and adjacent to the Development Site will be lost as a result of construction. Thirty Seven of the hedgerows are considered ecologically important under The Regulations, and are a priority habitat under the UK BAP. The loss of these hedgerows is in direct conflict with the objective to avoid adverse impacts on priority habitats and species; however to minimise the effect of this loss, a range of measures, including retention, replanting in the long-term and management will be undertaken. Proposals for enhancement during construction include: • creation of a wildflower grassland and woodland mosaic within the site south of the construction area, wildflower seeding on soil storage bunds and scrub creation along the western boundary; • creation of wildflower grassland off-site; and • habitat management of all retained and created habitats and monitoring of habitats and species. In the long-term, restoration of the construction area will result in the creation of 94ha of semi-natural habitat, including woodland, species-rich grassland, hedgerows and wetlands. A full account of impacts on statutory and non statutory sites as a result of construction work for off-site associated development is available within the Environmental Statement. In general the siting of off-site associated development has tried to minimise impacts on ecological receptors, which is in accordance with this objective. Summary The performance of the proposals against these objectives is a complex issue to consider in this appraisal, simply because the S M L proposals will lead to the losses and impacts of a varied number of habitats and species, some of which can be mitigated more easily than others. The Environmental Statement concludes that there will be a number of adverse effects on habitats and species; however it is thought that these will be less significant following the extensive package of measures to avoid and minimise these impacts within the scheme design and the biodiversity enhancement proposed. Notable examples include 
0? adopting careful construction practices to minimise disturbance to European protected birds, and the creation of a greater amount of habitat at HPC in the long-term from the existing situation.

150 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To avoid impacts on valuable ecological networks and ecosystem functionality Planning Policy Statement 9 (PPS9) Regional Planning Guidance for the West Somerset District Local Plan Whilst policy within the Biodiversity and Geological South West (RPG 10) (2001). Policy (2006) (‘saved’ policies) Overarching NPS for Energy is Conservation (2005). EN 1: Landscape and Biodiversity. Policy NC/3: Sites of Local Nature primarily focussed on protection, “Networks of natural habitats provide a Local authorities and other agencies in Conservation or Geological the IPC are also encouraged to valuable resource. They can link sites of their plans, policies and proposals, Importance. secure potential enhancement measures by the use of planning biodiversity importance and provide should, amongst other things: Planning permission will not be granted routes or stepping stones for the conditions or obligations. • promote the restoration and for development which has a significant migration, dispersal and genetic “Development proposals provide expansion of depleted and adverse effect on local nature exchange of species in the wider many opportunities for building-in vulnerable biodiversity resources in conservation/geological interests or environment. Local authorities should aim beneficial biodiversity or geological order to reverse fragmentation and integrity of landscape features, unless the to maintain networks by avoiding or features as part of good design. create continuous viable habitats; importance of the development outweighs repairing the fragmentation and isolation When considering proposals, the IPC and the value of the substantive interests of natural habitats through policies in should maximise such opportunities in • present. Where development is permitted plans” (para 12). indicate that the protection and, which would damage the nature and around developments…” (para Consultation Paper on a New Planning where possible, enhancement of the conservation value of the site, such 5.3.15). Policy Statement – Planning for a landscape and biodiversity should damage will be kept to a minimum. Natural and Healthy Environment be planned into new development. Policy NC/5: Wildlife Habitats. (2010) Draft Revised RSS for the South Habitats and other features of the In its final form, it is intended that this West Incorporating the Secretary of landscape identified as priorities in the PPS will replace PPS9. The draft PPS State’s Proposed Changes for Public West Somerset Biodiversity Action Plan, contains policies to maintain and Consultation (July 2008). or otherwise of major importance for enhance, restore or add to biodiversity ENV4: Nature Conservation wildlife, will be protected and their and geodiversity through the planning The distinctive habitats and species of management and enhancement system. It includes policies to promote the South West will be maintained and encouraged by not permitting damaging opportunities for the incorporation of enhanced in line with national targets development. beneficial biodiversity and geological and the South West Regional features within the design of Biodiversity Action Plan. Policy TW/1: Trees and Woodland development, and to maintain networks of Protection RE8: Woodlands and Forests. natural habitats by avoiding their Development proposals that would Local authorities and other bodies will fragmentation and isolation. adversely affect woodlands, groups of support the implementation of the trees or individual trees of significant RWFF, ensuring the environmental, landscape, wildlife or amenity value will social and economic value and

Sustainability Statement | October 2011 151

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives character of the region’s trees, woods only be permitted where conditions can and forests are protected and be attached to planning permissions to enhanced in a sustainable way. protect trees and, where appropriate, to Woodland areas, including ancient and require replacement and/or additional tree semi-natural woodland should be planting. maintained at least at 2005 levels and Policy TW/2: Hedgerows. expanded where possible to provide a buffer to core areas of woodland. Development or land management Ancient or veteran trees should be proposals will be required to show that an protected against loss. Where allowance has been made for the woodland is unavoidably lost through retention and protection of existing development it should be replaced with hedgerows and hedgerow trees unless appropriate new woodland on at least they are not considered to be of value to the same scale. the area's landscape, character or wildlife. Somerset & Exmoor National Park Sedgemoor District Local Plan (2004) Joint Structure Plan Review 1991- (‘saved’ policies) 2011 (2000) (‘saved’ policies) Policy CNE9: Interest on Other Sites. Policy 1 (Nature Conservation) The nature conservation value of land States that the biodiversity of Somerset outside nationally designated sites will be and the Exmoor National Park should a material consideration. Development be maintained and enhanced. which would damage: Wild Somerset - The Somerset Biodiversity Strategy 2008-2018 (the • the nature conservation interest of a Somerset Biodiversity Strategy) County Wildlife Site, County (Ref. 15.x) Geological Site, Local Nature Reserve The Somerset Biodiversity Strategy is or non-statutory Nature Reserve, or intended to represent a long term • blueprint for successful biodiversity natural features such as watercourses, hedgerows, trees, copses and ponds conservation in Somerset. which provide wildlife corridors, links Somerset Local BAP (LBAP) and or stepping stones from one habitat to Sedgemoor LBAP another, will not be permitted unless The Somerset LBAP has been the need for the development in that produced in conjunction with the location is unavoidable and of Somerset Biodiversity Strategy and overriding importance. identifies targets and actions for the Developers are encouraged to make

152 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives following biodiversity receptors across positive provision for wildlife through Somerset appropriate habitat creation/restoration South West Sustainability Checklist and subsequent management. objectives. Policy CNE12: Trees, Hedgerows and • Develop integrated sustainable land Woodlands. management practices – that In considering proposals for development, safeguard and enhance the region’s the Council will seek to protect important biodiversity whilst also bringing trees and hedgerows. Planning benefits to society, the economy permission may be refused where these and environment. would not be retained, or acceptably replaced. The Council will also encourage • To ensure that the ecological value the planting and proper management of of the site is conserved and new trees and shrubs enhanced maintaining biodiversity and protecting existing natural Sedgemoor District Council Local habitats. Development Framework Core Strategy (Proposed Submission) (September 2010) Policy D4 Renewable and Low Carbon Energy Generation Policy D14 Natural Environment Appraisal Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts on Priority Habitats and Species including European Protected Species Guiding Question - Will it affect the structure and function/ecosystem processes that are essential to restoring, securing and/or maintaining favourable condition of a feature or a site? As identified under the sustainability objective ‘to avoid adverse impacts on the integrity of wildlife sites of international and national importance’, It is recognised that warming of Intertidal Habitats as a result of the thermal plume from new plant - resulting in changes to benthic communities is the ecological effect that has the greatest potential to effect the coherency of the ecological structure and function of a European protected site. This potential impact has been considered by EDF Energy, and measures to reduce this include utilising the most efficient combination of intake and outfall positions for cooling water infrastructure in order to prevent the recirculation of warmed sea water affecting the Severn SAC, SPA and Ramsar Site. The locations of intake and outfall have been selected based on the combination which has the least likely environmental effect. The assessment of impacts from this is ongoing. Guiding Question - Will it result in the release of harmful substances for example oil, fuel and other pollution into water bodies which could affect aquatic ecosystems? The construction and operation of HPC and all other off-site associated developments will be undertaken in a manner consistent with best practices. Surface water

Sustainability Statement | October 2011 153

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives drainage systems will be fully compliant with all applicable legislation, regulations and guidance which in cases, includes gaining Environmental Permits to discharge into surface water bodies. To gain such permits, water must be discharged at a specific flow rate and chemical quality that ensures that existing conditions are not adversely affected. In general construction activities will be undertaken in a way to limit discharges into water bodies, with appropriate pollution prevention measures in place and an Incident Management Plan to ensure that if accidental contamination does occur, appropriate controls and measures are taken. The EIA considers potential impacts arising from contaminating water bodies during construction, either through sediment laden run-off or contaminated run-off. In general, the EIA identifies that there will be minor adverse effects or negligible effects arising expected to occur. Mitigation put forward includes the adoption of best practices, following relevant Environment Agency Pollution Prevention Guidance (PPGs). There are also extensive measures taken in the form of sediment traps and the application of Water Management Zones, which ensure that discharges are of an appropriate quality at the HPC development site. Guiding Question - Will it result in the accidental migration of radionuclides which could harm aquatic or terrestrial ecosystems? The proposals are designed such to ensure that accidental migration of radionuclide’s are limited in accordance with relevant nuclear licensing covered by the Radioactive Substances Act (1993) and also addressed within the draft Environmental Permitting Regulations (2010). The design of the facility is such that the release of radionuclides into the aquatic or terrestrial environment is undertaken by applying the appropriate control measures. This has been assessed as part of the Radioactive Substances Regulations (RSR), which EDF Energy has made an application for in July 2011. This considers impacts on human and non-human health. The radiological assessment within the EIA, Chapter 21, Volume 2 considers radiological risk during construction and operation. Results of surface water, sea water and soil showed very low levels or no levels of elevated radiation. The low activity levels present do not pose a threat to human or non-human health. Guiding Question - Will it result in changes to stream hydrology and morphology that could affect aquatic or terrestrial ecosystems? Modifications to surface watercourses will occur at the HPC development site as a result of the construction. The principal issue is the culverting of Holford Stream, which supplies water to the Wick Moor (Bridgwater Bay SSSI). The culverting, and the associated works associated with Water Management Zones at either end of the culvert are anticipated to provide a more stable supply of water to the SSSI year round. This is expected to have a betterment to the SSSI. Certain Off-site associated development may also have the potential to impact upon stream hydrology and morphology, based on the proximity of new development to surface water features. Impacts on streams have been carefully considered and where necessary such features have been retained in the design of the off-site associated development. Other noteworthy areas include Combwich laydown facility, which will impact on a number of surface water features through the introduction of culverts. The Hydrology and Drainage and Water Quality chapters of the Environmental Statement set out various measures to ensure likelihood of effects are minimised, including best practice in terms of design and a Sediment Management Plans. The scope of the plan is likely to include silt fencing, sediment trapping, run off attenuation, maintenance and monitoring measures. These will considerably reduce the likelihood of environmental change. Summary The development proposals will create new landscape features, which in certain instances will alter existing ecological networks. S M L EDF Energy is exploring ways of minimising impacts on ecosystem connectivity through the adoption of mitigation, and also by ensuring biodiversity gain in accordance with PPS9. Proposals exist to ensure that ecological networks are maintained during construction. Once operational, the developments will be designed to enhance connectivity wherever possible. An example of this is that the Cannington bypass may have a minor 0

positive benefit for habitats which recreate connectivity. In general the objective to avoid adverse impacts on valuable ecological networks and ecosystems functionality is supported by the proposals.

154 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

4.6 Climate Change

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Minimise Greenhouse Gas Emissions Climate Change Act (2008) Regional Planning Guidance for the West Somerset District Local Plan Policies for Climate Change are now at The Climate Change Act introduces South West (RPG 10) (2001) Policy 2006 (‘saved’ policies) the centre of most planning policy targets for carbon reduction up to 2050. RE 6: Energy Generation and Use Policy BD/9 documents. The Overarching NPS for Energy and the revised Nuclear NPS do By 2050, the UK pledges an 80% Local authorities, energy suppliers and Development will only be permitted where not include any policies directly relating reduction in carbon emissions relative other agencies should support and it is demonstrated that the conservation of to minimising greenhouse gas to the 1990 baseline. The Act also encourage the region to meet the energy and water has been considered in emissions; however the implementation establishes mandatory carbon budgets national targets for: the design, layout, siting and drainage of which set the UK on a trajectory for of the policy document delivers this goal. • A 12.5% reduction in greenhouse the proposal and that all practicable achieving these targets. With regard to specific design criteria for gas emissions below 1990 levels by measures to conserve water are included minimising greenhouse gas emissions, Low Carbon Transition Plan (2009) 2008-2012, and a 20% reduction as part of the scheme. the IPC is guided towards The UK Government’s Low Carbon (from 1990 levels) in carbon dioxide West Somerset Local Development considerations for CHP; paragraph 4.6.8 Transition Plan, published on 15 July emissions by 2010. Framework Core Strategy identifies that “ substantial additional 2009, says that “…in order to Sustainability Appraisal Objectives • A minimum of 11-15% of electricity positive weight should be given by the decarbonise our electricity supply, production to be from renewable Reduce greenhouse gas emissions IPC to applications incorporating CHP ”. electricity will need to come from a mix energy sources by 2010. Increase energy efficiency and the including renewable sources, nuclear Planning policies at the regional and amount of energy generated from power and fossil fuels with carbon • Encourage and promote the greater local levels interpret guidance within renewable sources. capture and storage use of renewable energy sources, PPS 1 and its supplement; Development Sedgemoor District Local Plan (2004) and Climate Change, and PPS 22, including community-based projects, such as CHP and (‘saved’ policies) Renewable energy; which places broad Overarching National Policy Community Heating and their Policy BE1. Sustainable and Quality requirements for development planning. Statement for Energy Infrastructure integration into more energy Development This includes targets for renewable (EN-1), (July 2011) energy and decentralised energy. efficient new build or redevelopment Applicants for planning permission for all The Overarching NPS identifies that for proposals. development will be required to submit There are also a number of much the UK to meet its energy and climate justification as to how the proposal has broader policies identified within regional change objectives; there is an urgent considered a wide range and local planning policies which aim to need for new electricity generation deliver the goals of this objective. plant, including new nuclear power.

Sustainability Statement | October 2011 155

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives

Supplement to PPS 1: Planning and • Have full regard to the of design criteria, including sustainable Climate Change (2005). recommendations and detailed development issues. The detailed design The Climate Change supplement to background information contained in criteria are set out at Appendix 9.1 PPS 1 promotes and encourages the report “Renewable energy together with more specific design renewable and low carbon energy assessments and targets for the applications and are summarised under development. South West” (GOSW APRIL 2001). the three headings below: Planning Policy Statement 22: Development Plans should: • Energy and movement. Planning for Renewable Energy • Specify the criteria against which • Accessibility and linkages. (2004) proposals for renewable energy • Energy strategy. This sets out further detail about how projects will be assessed, balancing such policies should be framed and the the benefits of developing more • Applicants will be required to issues which should be considered. sustainable forms of energy demonstrate they have addressed This national policy framework expects generation against the these issues. The extent will depend new development to be planned to environmental impacts, in particular on the scale and the complexity of the make good use of opportunities for on national and international proposal. decentralised and renewable or low designated sites. Policy PCS6 Energy Efficient carbon energy, including micro • Development generation. Promote energy conservation measures through policies guiding Development will only be permitted where the design, layout and construction it is demonstrated that energy efficiency techniques of new development has been taken into account in the proposals. design, layout, siting and construction of Draft Revised RSS for the South the proposal, and the use of landscaping West Incorporating the Secretary of and that all measures which are State’s Proposed Changes for Public practicable are included as part of the Consultation (July 2008). RE5: scheme. Renewable Energy and New Policy PCS5: Renewable Energy Development Proposals for the development of the Local planning authorities should set sources of renewable energy schemes, targets in their DPD’s for the energy to including wind power, will be permitted be used in new development to come provided that all the following criteria are from decentralised and met. Developments must: • Be sited and designed so as to minimise their impact on the landscape, utilising landscape features. 156 Sustainability Statement | October 2011 • NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives

renewable or low-carbon energy • Not have an unacceptable impact on sources where it is feasible and viable, the character or setting of a settlement and the development thresholds to which such targets would apply. In the • Not lead to an unacceptable level of interim, before targets are set in DPD’s, nuisance by reason of noise, safety, at least 10% of the energy to be used shadow flicker, electro-magnetic in new development of more than ten interference, or reflected light. dwellings or 1000m 2 of non-residential Particular attention will be given to the floor space should come from impact on dwellings and other decentralised and renewable or low- regularly occupied premises. carbon sources, unless, having regard • Not unacceptably affect the character to the type of development involved or setting of a Listed Building, and its design, this is not feasible or Conservation Area or a scheduled viable. ancient monument. Policy SD2 Climate Change • Not unacceptably affect a site The region’s contribution to climate designated for its ecological or change will be reduced by reducing archaeological value either during or greenhouse gas emissions at least in after construction. line with the current national targets. Sedgemoor District Council Local SW Councils: South West Climate Development Framework Core Action Plan, 2008 - 2010, Key Strategy (Proposed Submission) Objectives (September 2010) Provide support and coordination of Policy D3 Sustainable Construction activity to achieve low and zero carbon and Reducing Carbon Emissions in new development by 2016 (housing) New Development and 2018/19 (non domestic sector). The Council will encourage the use of Support local authorities, especially sustainable construction techniques that, those with SSCT’s, to deliver amongst other things, reduce CO 2 decentralised energy networks in new emissions. Applications for all major major urban extensions and large development proposals will be required developments.

Sustainability Statement | October 2011 157

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Embed long-term carbon management to provide a statement demonstrating how and resource efficiency in business sustainable construction principles have planning and investment and economic been incorporated, this should address development. demolition, construction and long-term Investigate and promote the carbon management. Including how the proposal ‘sink’ capacity of the region’s minimises net greenhouse gas emissions peatlands. Maintain and enhance of the proposed development. regional peat resources, through Policy D4 Renewable and Low Carbon projects such as re-wetting, reducing Energy Generation stocking densities and frequency of National Sustainability Indicators used burns and restoring vegetation, to within Somerset AA: maximise the carbon storage potential. NI 185 – CO 2 reduction from LA Somerset & Exmoor National Park operations. Joint Structure Plan Review 1991- NI 186 – Per capita CO emissions in the 2001 (2000) (‘saved’ policies) 2 LA area. No relevant objectives or policies. Checklist South West Objective: To ensure that new developments are appropriately adapted to the impacts of present and future climate change and to minimise their own impact on greenhouse gases, flooding, heat gain, water resources and water quality. Appraisal Hinkley Point Strategic Sustainability Objective: To Minimise Greenhouse Gas Emissions Guiding Question - Will it take account of future effects and risks of climate change for example sea level rise? The design of HPC takes account of the future climatic changes. Most significantly, future changes in sea level have been considered by ensuring that the HPC, including all access to the station, has been designed to withstand sea level rises in accordance with the upper projections from the UK Climate Impacts Programme (UK CIP) 09 projections up to 2100. This is further explored in the flood risk section of this sustainability framework; however more detailed information is provided within the HPC Flood Risk Assessment, which supports the DCO application. Guiding Question - Will future changes in weather patterns be considered? The ability of the Hinkley Point C (HPC) project to assist in mitigating climate change is linked closely with its ability to adapt to future changes in climate. Failure to do so

158 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives may prevent continued power generation. In addition to establishing a legal framework for mitigating emissions, the Climate Change Act (2008) has introduced a new power for the Secretary of State to direct ‘reporting authorities’, which includes EDF Energy (and all energy providers with assets over 10 TWh), requiring them to account for how they are adapting to future changes in climate under provisions within the Act. They must demonstrate how new development will be resilient to climate change. The design of the HPC permanent development site and off-site associated development will address future changes in weather. The degree to which this is achieved is influenced by its longevity. The UK is predicted to experience warmer wetter winters, and hotter and drier summers as a result of a Changing Climate. Where possible building design takes into account the effects of climate change. HPC will have an operational life of 60 years, however because of the requirements for disposal of spent fuel and decommissioning of associated facilities, several buildings may be in place well beyond this - far longer than a typical modern building. Therefore the design requires that impacts from a changing climate must be appropriately factored into design of the main site in particular. Off-site associated development, in use for a relatively short period of time (less than 10 years), is of lower significance. Notwithstanding this, the design of this development will take into account recognised principles of climate change adaptation and be in accordance with local planning policies. This will include adopting appropriate drainage strategies to manage increased rainfall. The design of the HPC permanent development site makes specific considerations to changing weather patterns arising from climate change. This includes proposals for the height of the land platform, the adaptability of the sea wall and specific considerations to building and drainage system design. A further account of these is provided within the Hinkley Point C Design and Access Statement . Guiding Question - Will it result in increased vehicular emissions (particularly carbon dioxide)?

A construction project of any scale will require movement of people and materials, therefore increased vehicular emissions are anticipated. Similarly, CO2 emissions will increase as a result of the project’s construction phase, of which transport related CO 2 will form a part. Notwithstanding this, EDF Energy has explored a series of opportunities within its Freight Management Strategy, which aims to reduce impacts on transport environment, and which may have direct benefits in reducing carbon emissions associated with vehicular transport. EDF Energy has undertaken considerable work to reduce impacts from construction related transport. This will have direct and indirect benefits on making relative reductions on emissions. Key proposals include: • The delivery of four park and ride facilities located in strategic areas to intercept workers and shuttle them to and from the site using buses. The principle of park and rides – which will result in consolidated staff travel (up to 40 workers per bus) – will reduce emissions associated with private car travel. EDF Energy intends that the very large majority of those accessing the site will make use of these facilities, or make use of other sustainable forms of travel as opposed to private care journeys. • Delivery of freight management/logistics facilities at Junction 23 and Junction 24, to manage transport of materials to the Development Site, reducing congestion and emissions, particularly in Bridgwater. This will be delivered in accordance with an electronic Delivery Management System (DMS) and the identification of routes which make use of the strategic road network where possible. • Consolidating Light Good Vehicles (LGV’s) and small commercial vehicles in the postal/courier management centres at Junction 23 and Junction 24, further reducing trips. • The EDF Energy Accommodation Strategy has also been designed to minimise travel to work distances.

Sustainability Statement | October 2011 159

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Guiding Question - Will it result in increased emissions from asset construction, maintenance and demolition, waste recycling and disposal or other activities? Increased emissions from these activities are inevitable. It is important to note however, that these activities are necessary to facilitate the completion of the power station, on time and within budget, which as explored, is essential. The proposals for the generation of nuclear power are supported at the national level through the Low Carbon Transition Plan and the Overarching National Policy Statement for Energy Infrastructure (Overarching NPS). Nuclear power is a low carbon technology and the proposals at Hinkley Point would be for two EPR type reactors, generating 1,630MW of low carbon electricity per reactor. This will provide 6% of the UK’s electricity demand from a low carbon source, thus playing a significant role toward the UK’s Low Carbon Transition Plan, assisting the UK meet its low carbon budgets and demonstrating consistency with the sustainability objective: to mitigate climate change. EDF Energy has undertaken a Life Cycle Assessment of the Carbon Footprint of HPC , which assesses the greenhouse gases (GHGs) embedded within all stages of the life cycle of the Hinkley Point C (HPC) Project. This is expressed in gCO 2e/kWh. The assessment identifies that the carbon footprint associated with HPC is very low, approximately 4.8 gCO2e/kWh, which is significantly lower than coal or gas. The construction phase is identified to lead to one the largest contributing factor of emissions. These represent approximately 35% of the entire footprint of HPC. Whilst this will result in an increase in GHG associated with construction, this will be offset very rapidly once HPC is operational. Furthermore, the GHGs embedded in construction are very difficult to avoid. The materials, which constitute the most significant share of the emissions associated with construction, are necessary fundamental to the safe construction and operation of the power station, with which EDF Energy has very limited ability to control. For example, steel and concrete represents 36% and 18% respectively of the emissions arising during construction. These elements are fixed through the Generic Design Assessment (GDA) and there is no flexibility to utilise materials with lower embodied carbon. Notwithstanding this, where flexibility exists, EDF Energy will attempt to manage emissions as far as possible. Various initiatives, such as modular solutions for construction of the accommodation buildings will achieve efficiency of and minimisation of waste in construction, as well as in demolition. This provides fast erection time and delivers a high quality product as the modular units can be fitted out offsite in a controlled environment, with a likely reduction in construction waste. Furthermore, the modular structural form will be easily dismantled. Also, all Tier 1 contractors will be required to set out a strategies for how CO 2 will be managed in their work packages. In general, whilst an increase in emissions is expected to occur from activities such as asset construction, demolition, waste recycling and disposal, the increase will be far offset by the generation of low carbon energy. Further to this, each one of these activities will be geared towards emissions reduction where possible and practical. Guiding Question - Will it include CHP to assist in minimising greenhouse gas emissions?* The Overarching NPS identifies that CHP must be considered alongside any proposals for new energy generating proposals. EDF Energy has commissioned a study to identify the feasibility of incorporating CHP into the power generation process. The study has tested three scenarios for making use of heat, these included options for connecting Bridgwater and Cannington to a hot water system, and also providing a hot water distribution system for a potentially new development. The conclusions of this study demonstrate that the delivery of all options is impractical given the short lifespan of the buildings. Primarily, it is not economically viable, even if the distribution of this heat was incentivised by Government schemes; the opportunity for CHP would be incapable of delivering energy at a price which will be competitive with gas. Furthermore, the utilisation of CHP would reduce the quantity of low carbon electricity generated, which is the primary purpose of this development.

160 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Guiding Question - Will the development incorporate energy efficiency and renewable/low carbon energy in accordance with local planning policies?* It is proposed that the buildings at the HPC permanent development site will be powered by electricity produced from the generation process, once HPC has been commissioned and is operational. This will effectively mean that the power delivered to of all site buildings will be low carbon, apart from periods of maintenance outages, where back up grid supplied electricity will be used. Furthermore, the proposal to locate a new EPR reactor in the south west of England, which currently holds a greater demand of electricity than is generated, means that energy efficiency is promoted. This would be achieved through reducing long-distance power flows through the grid and hence reduce the energy dissipated as transmission losses. This is recognised by the National Grid in its Seven Year Statement (Ref. 74): “Clearly, if a new power station were to be located in the north, and this were to displace the operation of southern generation, then the north to south power flows would increase, transmission losses would increase and some of the output of the new station would, in effect, be 'lost' to the system. However, if the new power station were to be located in the south and this displaced northern generation, the converse would be true; north to south power flows would decrease, system losses would decrease and the relative net effect would be as if a larger station had been installed”. (Page 18, Ch7). According to National Grid's modelling, a summary of which is presented within that Statement, a MW of electricity generation in Zone 17 (SW England, where HPC is located) is worth 111% of its value in meeting demand, whereas by comparison the same MW generated in Zone 7 (NE England) is worth 96%, and in Scotland lower still- less than 90%. Subsequently, locating HPC in Somerset as opposed to a northern region allows the system to meet approximately (15% of 3260 MW), 489MW of additional demand, for exactly the same station output. This is a significant benefit in sustainability terms, which reinforces the need for HPC. In addition, all off-site associated development has been designed with the intent to achieve energy efficiency as part of the design brief. The general approach has been to follow a Lean/Clean/Green energy hierarchy as generally considered best practice. Each off-site associated development site must take account of Building Regulations. Buildings will be designed with a range of measures to achieve this standard. Certain buildings will also be subject to BREEAM, and will be designed to limit carbon emissions, requiring that ASHP systems are installed. For temporary accommodation sites, such as Bridgwater A and Bridgwater C, the objective to meet BREEAM Very Good standards ensures that renewable/low carbon measures will be pursued, and will be designed to meet Part L2a of the Building Regulations 2010. This is achieved through passive design measures such as improved performance of the building fabric, and optimising the use of natural light. Active design measures include lighting control presence detection, and a building management system. The use of additional renewable technology to improve the CO 2 emission has been addressed to meet with Building Regulations and local planning policies. For other associated developments such as the Park and Ride sites, energy efficient measures will be implicated where possible, such as efficient car park lighting where appropriate. Summary Given the proposals will provide a significant contribution to the Government’s objectives to augment the low carbon power S M L sector, on balance, the objectives for minimising greenhouse gases are strongly supported by the proposals. Over the short-term during construction emissions are expected to increase as a result of construction activities, however EDF Energy is adopting a series of measures to reduce emissions during this phase of development. It is expected that equal or even greater emphasis will 

 be placed on emissions reductions during decommissioning activities, although at present there is a large degree of uncertainty over how this will be managed. When considering the substantial generation of nuclear power expected over the medium term, the proposals far exceed this sustainability objective.

Sustainability Statement | October 2011 161

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

4.7 Communities: Population, Employment and Viability

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Create Employment Opportunities

PPS 4 – Planning for Sustainable Regional Planning Guidance for the West Somerset District Local Plan Economic development throughout Economic Growth (2010) South West (RPG 10) (2001) Policy (2006) (‘saved’ policies) the levels of policy will be delivered This sets out key planning policies for EC1: Economic Development No relevant objectives or policies. by flexible policies which promote business and economic prosperity. economic development in both urban Local authorities, the SWRDA, local West Somerset Core Strategy and rural areas, and establishes economic partnerships and other Sustainability Appraisal Objectives The Nuclear NPS does not include positive planning for sustainable agencies should support the sustainable direct guidance for economic Improve sustainable economic activity economic growth. development of the regional economy development; however the within West Somerset enabling by: Overarching NPS does acknowledge The guidance includes policies to both regeneration of key areas. that the IPC should “ consider any guide plan formulation (directed at • Positively promoting and encouraging Sedgemoor District Local Plan (2004) relevant positive provisions the regional and local planning authorities) new economic activity in the areas (‘saved’ policies) developer has made or is proposing and development control policies where it can bring the greatest Objective to make to mitigate impacts (for against which individual planning economic and social benefits and example through planning applications and appeals will be judged. make the greatest contribution to To foster and promote the economic well- obligations) and any legacy benefits Regions and local authorities should reducing regional disparities in being of the District, through application of that may arise as well as any options plan to achieve sustainable economic prosperity. positive and flexible policies designed to for phasing development in relation growth through flexible and proactive support the establishment and expansion • Accommodating continued economic to the socio-economic impacts” policies in supporting the start up and of a range of competitive businesses and development in sustainable locations (Paragraph 5.12.8) growth of businesses, attracting inward enterprises which also contribute towards in the more prosperous north and investment and increasing employment, achieving local need, sustainability and east of the region and seeking to particularly in deprived areas. quality objectives. develop beneficial economic linkages between these areas and areas to Policy E6: New and Existing the west whose economies have Employment Sites performed less well. In the countryside beyond settlement • boundaries the establishment of new Ensuring that the region’s unique employment sites and the extension of environmental and cultural assets are established sites will only be permitted maintained, enhanced where a countryside location is

162 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives

• and utilised to attract and develop essential and no suitable alternative is business activity. available within or adjoining a local settlement. • Developing the skills and abilities of The Sedgemoor Local Plan has two the region’s people by improving proposals for development within access to training, education and Bridgewater Saved, including Proposal E1 employment opportunities. - Land at Somerset Bridge, Bridgwater and Draft Revised RSS for the South West Proposal E2 - Land at former Wellworthys Incorporating the Secretary of State’s playing field, Salmon Parade, Bridgwater. Proposed Changes for Public Sedgemoor District Council Local Consultation (July 2008) Development Framework Core Strategy Sub regional policies within the revised (Proposed Submission) (September draft RSS aim to support the economy 2010) by enhancing educational achievement Vision 1: A Spatial Vision for and skills, and by providing for a range Sedgemoor of premises and land (including strategically important sites) to meet the “By 2026 Sedgemoor will have a thriving, changing needs of sectors, in a way that diverse and resilient economy underpinned complements and helps to implement by an ambitious and skilled local labour the South West Regional Economic force.” Strategy. Strategic Objective SO6 Somerset & Exmoor National Park “To ensure the economic wellbeing of our Joint Structure Plan Review 1991- communities, by developing an economic 2001 (2000) (‘saved’ policies) blueprint to shape the restructuring of our Policy 19 Employment and economy and transform the workforce.” Community Provision In Rural Areas Policy D11: Economic Prosperity In rural areas provision should be made Advises that, in general, employment for development which creates or proposals will be supported where they enhances local employment. contribute to a series of objectives.

Sustainability Statement | October 2011 163

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives The Sustainable Community Strategy Sedgemoor Economic Strategy to 2026: for Somerset 2008-2026 (2009) • To provide economic leadership for the • This document sets out the Somerset businesses and communities of Strategic Partnership’s long-term Sedgemoor in Somerset, ensuring vision for Somerset in 2026. The Sedgemoor effectively influences document seeks to broaden and County, regional and national policies strengthen the local economy and investment programmes. through increasing the overall • To maximise investment attractiveness employment rate, increasing the and dynamism of the economy, through average earning of employees in the business infrastructure, enterprise and area and increasing the new skills, increasing Sedgemoor’s business registration rate. contribution to the Somerset and South West economy. • To realise the potential of Bridgwater as a regionally significant economic growth centre, benefiting businesses and communities in the wider district. • To support the economic renewal of Sedgemoor’s coastal and rural towns and dispersed communities. • To ensure that all of Sedgemoor’s communities benefit from increased economic prosperity.

164 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Appraisal Hinkley Point Strategic Sustainability Objective: To Create Employment Opportunities The Government has identified within the AoS Site Report for Hinkley Point, that strategic effect on population, employment and viability are likely to be minor, although uncertainty remained as the project may lead to a shortage of local construction workers to meet the needs of other industries. The Government also identified that positive cumulative effects may arise for the region with consideration to a second nuclear power station and Severn Barrage in the south-west, contributing to the regional economy and employment. Guiding Question - Will it create both temporary and permanent jobs in areas of need? 20,000-25,000 individual jobs are expected to be provided during the construction programme, with 5,000 predicted to be filled by Somerset residents. The workforce will peak at 5,600 workers in 2016. Approximately 900 full-time staff will be required for HPC’s operation, virtually all of whom will live in Sedgemoor, West Somerset or Taunton Deane Districts. A four-year apprenticeship programme will be offered by EDF Energy, sourcing approximately [200-300] of the trained technicians required for the operation of HPC. Employment opportunities may also be associated with some of the indirect benefits of the project on supply chain. The Socio-Economic Assessment identified the following benefits of the project on the local economy: • The project will generate indirect economic benefit to create demands for goods and services from local firms creating additional employment. This is estimated to generate £100 million per annum for the regional economy during each year of construction. • Additional economic benefit is anticipated to be £40 million per annum during operation. • These indirect economic benefits will also create employment opportunities, both permanent and temporary. Guiding Question - Will it enhance skills? HPC will require a diverse range of skills throughout its lifecycle; ranging from specialist engineers through to local labour and support services. The project will create opportunities for skills development, which will be assisted by EDF Energy’s commitments in this area. EDF Energy has a comprehensive Construction Workforce Development Strategy which includes jobs brokerage, outreach work, physical investment in West Somerset and Sedgemoor (Bridgwater College and West Somerset Community College), support for Apprenticeships and Enterprise Project. EDF has also committed substantial funding towards this, comprising a £3 million investment in the Energy Skills centre at Bridgwater College; £1.5 million investment in creating a new Construction Skills Centre at Bridgwater College; and £1.6 million with West Somerset Community College for various projects, including re-aligning facilities at Minehead so that they are better able to offer training to match the needs of the project. Summary The objectives under Communities: Population, Employment and Viability reverberate within proposals. There is a particularly S M L strong relationship between the development proposals and Governmental objectives to create employment opportunities. This is largely due to the number of jobs that will be provided during construction and operation of the facility, with 20,000-25,000 jobs created during the construction period and significant investment in up skilling in the local area. EDF Energy’s investments in



youth skills and training, and liaison with local businesses to promote involvement of local contractors present a viable case for support regarding Community sustainability and improvement.

Sustainability Statement | October 2011 165

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Encourage the Development of Sustainable Communities

UK Government Sustainable Regional Planning Guidance for the West Somerset District Local Plan Policies at all tiers of governance Development Strategy (2005). South West (RPG 10) (2001). Policy (2006) (‘saved’ policies) identify that sustainable communities Sustainable communities will be: EN5: Health, Education, Safety and No relevant objectives/policies. can be delivered through a balanced other Social Infrastructure: approach to social, economic and • Inclusive, facilitating involvement West Somerset Core Strategy environmental objectives for and security. Health, education and other social Sustainability Appraisal Objectives. infrastructure requirements need to be sustainable development, which is To develop and maintain a balanced and • Efficiently and appropriately taken into account fully in development underpinned by the provision of sustainable population structure with facile managed. planning throughout the region. adequate services and access to infrastructure, services, facilities • Development plans and programmes infrastructure. Environmentally sensitive. and residences far all sectors of society. should: • Built and designed to a high • Sedgemoor District Local Plan (2004) standard. Facilitate the reconfiguration and (‘saved’ policies) • modernisation of local health Good quality infrastructure. services, in accordance with Objectives • Economically, socially and sustainable development principles, Ensuring adequate provision is in place for environmentally progressive. informed by partnership working with improvements to existing infrastructure, to meet development requirements without • Health Authorities and others on Appropriate, efficient and accessible Health Improvement and harm to the environment or quality of life in provision of services. Modernisation Plans (HIMPs). the District, thereby promoting sustainable • development. Present equality of opportunities and • Encourage new facilities to be inclusion to all parties. developed or redeveloped wherever To promote the retention and provision of PPS 1 Delivering Sustainable possible on sites that are well served new community facilities and services at Development (2005). by public transport and easily the neighbourhood level within our Towns, Rural Centres and Villages. PPS 1 sets out the Government's accessible on foot or bicycle. Policy PCS7: Community Facilities and overarching planning policies on the • Access for patients, staff and visitors. delivery of sustainable development Services: through the planning system. The • Enable the varied provision of Planning permission for proposals that delivery of sustainable communities is facilities for education and training. would result in the loss of community promoted. • facilities and services will be refused Encourage provision of other facilities unless: required by local communities, wherever possible maximising the • Appropriate alternatives are available potential of existing community locally. buildings. • The proposed use would be of equal or

166 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives • Include policies and proposals for the greater community benefit. provision of appropriate services • Existing use is no longer viable. within rural areas. For example, encouraging mixed use • Where planning permission is granted developments, which incorporate for the change of use of an important health care provision with other uses. facility, conversion works should not • preclude a later reversion to the original Local authorities should take steps to use. ensure that crime prevention Sedgemoor Sustainable Communities considerations are incorporated in Strategy 2009-2026: the design of new development. • The purpose of the Community Strategy is Should consider the impacts of to promote the economic, social and proposed developments on the environmental Wellbeing of Sedgemoor. health of local communities, taking The Strategy sets out key aims for the advice from Health Authorities. district, these include: Draft Revised RSS for the South West • Making a positive contribution. Incorporating the Secretary of State’s Proposed Changes for Public • Living sustainably. Consultation (July 2008). • Ensuring economic well being. Policy SD4: Sustainable Communities • Enjoying and achieving. Growth and development will be planned and managed positively to create and • Staying safe. maintain Sustainable Communities • Being healthy. throughout the region. Sedgemoor District Local Development Framework Core Strategy (Proposed Submission) (September 2010)

Sustainability Statement | October 2011 167

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Checklist South West Objectives Strategic Objective SO4 To ensure development supports a “To create more sustainable communities.” vibrant, diverse and inclusive community Policy D4 Renewable and Low Carbon which integrates with surrounding Energy Generation communities. Policy D19 Health and Social Care To ensure the most sustainable sites are New development that creates a need for used for development and that the additional health care that cannot be met design process, layout structure and through existing facilities will be expected form provide a development that is to meet any identified shortfall. appropriate to the local context, and supports a sustainable community. All major planning applications will be required to provide a Health Impact Assessment. All development proposals where appropriate should promote healthy and active living. Appraisal Hinkley Point Strategic Sustainability Objective: To Encourage the Development of Sustainable Communities Guiding Question - Will it result in in-migration of population? EDF Energy’s assessment of the construction workforce required to build Hinkley Point C, includes an assessment of the recruitment of workers. It identifies those workers already living within 90 minutes of the site (the Construction Daily Commuting Zone (CDCZ) who are classified as “Home Based Workers”, and those who will move into the area (defined as a 60 minute travel time of the site who are described as “Non-Home Based” workers. The relative proportions of each will vary throughout the project depending on the overall volume of demand and the specific skills required at any given point in the construction process. For the peak of construction in late 2016 and early 2017, it is anticipated that approximately 34% of the workforce will be homes based (1,900) and 66% non-home based (3,700). EDF Energy has used these estimates to plan, in partnership with public service providers and others how to avoid, or where necessary mitigate impacts, and potential investments which could help meet construction workers’ needs but also provide longer term benefits to local residents. This includes: • a campus based accommodation strategy so that demand for local accommodation doesn’t exceed identified supply; • design and management arrangements for the campuses to minimise impacts and aid their integration into their local areas; • an Accommodation Management Strategy which directs workers to areas with available accommodation, and ensures good behaviour through a worker code of conduct,

168 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives • A housing fund to allow “pre-mitigation” of any impacts on the local housing market but also a long-term benefit for the area; • Investment in public services including policing and emergency services, education, and leisure; • A “Community Fund” to help mitigate the intangible and qualitative impacts on those particular communities most affected by the development. Guiding Question - Will it result in out-migration of population? The three districts (West Somerset, Sedgemoor and Taunton Deane) already see considerable population churn, with several thousand people moving into and out of the area every year. There is no evidence to suggest that the construction phase of the development will have any impact on out-migration. One of the factors identified for the “out migration”, particularly of younger age groups, is the lack of well paid and skilled employment. The development of HPC will provide a round 900 well paid and skilled jobs for a period of around 60 years. This may help retain existing population. Further details are available within the Economic Statement . Guiding Question - Will it affect the population dynamics of nearby communities? The age structure of the local population varies between the districts. It is particularly high and ageing in West Somerset compared to national averages but more “balanced” in the other districts. The Socio-Economic Assessment include workforce benchmark demographics which suggests a relatively even split of working age “men” will form the majority of the construction workforce. At peak construction 450 to 500 non-home based workers may be in households with dependents. EDF Energy has, on the basis of these assessments, planned mitigation measures to address the likely needs and impacts of this workforce. In the longer term the permanent workforce is unlikely to change local population structures significantly although if HPC were not built the population structure may age even more rapidly as the de-commissioning of HPB would reduce employment opportunities for working age residents in the area. Guiding Question – Will it provide a balance between housing and employment opportunities to reduce out-commuting?* The entire permanent workforce at HPC is likely to live within the districts of Sedgemoor, West Somerset and Taunton Deane. This is likely to contribute to local labour market self containment as these workers will not have to out commute to larger population centres such as Bristol, as many current residents do for higher skilled and paid jobs. Summary These proposals clearly promote and encourage development of a sustainable community, facilitating significant direct and S M L tangential benefits.

0?

Sustainability Statement | October 2011 169

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts in Property and Land Values and Avoid Planning Blight No specific policy driver. Regional Planning Guidance for the No direct policy driver exists at the local Planning policy aims to reduce impacts South West (RPG 10) (2001) level; however policies from West Somerset from blight at all levels. The Nuclear Policies within the RPG are designed to and Sedgemoor District Councils are NPS does not address planning blight Improve the quality of the urban geared towards promoting land values and specifically, although does identify that environment, including the setting and avoiding planning blight, by ensuring the SSA and the promotion of the sites surroundings of cities and towns, the appropriate siting of new development. takes into consideration planning blight. quality of new development and the Sedgemoor District Council Core “The Government does not consider it is public realm, and reduced noise pollution Strategy Sustainability Appraisal appropriate to include more than ten and blight. Objectives sites in this NPS at this stage when the To ensure new development is high quality, need is balanced against the potential locally distinctive involving sustainable harm to Natura 2000 sites and other construction practices, and is respectful of factors like planning blight”. Paragraph the historic environment. 2.5.5 Nuclear NPS. West Somerset Core Strategy Sustainability Appraisal Objectives Enhance the form and design of the built environment. Appraisal Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts in Property and Land Values and Avoid Planning Blight Guiding Question - Will it result in a decrease in property and land values as a result of a change in perceptions or blight? The impact of the project on property values and planning blight has been considered by EDF Energy and is subject to ongoing analysis. The surrounding communities of Hinkley Point have a long-standing relationship with nuclear power stations. The impact of planning blight from constructing HPC – given the presence of HPA and HPB – is expected to be reduced. Notwithstanding, there will be impacts from construction which will be disruptive to local communities, particularly on hamlets neighbouring the proposed HPC development site. The most significant impacts are expected during construction, whereas once operational impacts may be reduced. Off-site associated development is potentially more likely to give rise to impacts. Various proposals have been put forward to mitigate this. EDF Energy has been consulting on neighbourhood support schemes, and is developing a noise insulation scheme and a property price support scheme for qualifying residents. The measures put forward represent best practices, and demonstrate EDF Energy’s commitments and responsibilities to neighbouring communities. Summary EDF Energy is enacting a comprehensive neighbourhood support scheme, which it has consulted on as part of the S M L

170 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives development proposals. The scheme will protect resident’s properties, helping to mitigate concerns for residents on land values. The impacts of planning blight and reduction in land values is being managed by EDF Energy. The construction works  0 0? will inevitably cause the most disruption. Once operational, the impacts are reduced, particularly given the baseline conditions which take account of the existing A and B stations.

Sustainability Statement | October 2011 171

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

4.8 Communities: Supporting Infrastructure

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts on the Function and Efficiency of the Strategic Transport Infrastructure PPG 13: Transport Regional Planning Guidance for the West Somerset District Local Plan (2006) Paragraph 5.13.4 of the Overarching NPS Originally published in March South West (RPG 10) (2001). Policy (‘saved’ policies) highlights how demand management 2001 (revised January 2011), TRAN 1: Reducing the Need to Travel Policy T/3: Transport Requirements of measures should be considered before new the objectives of this national Local authorities, developers and other New Development transport infrastructure: guidance are to integrate agencies should work towards reducing New roads and improvement schemes • Where mitigation is needed, possible planning and transport at all the need to travel by private motor should be designed to minimise demand management measures must be levels to help reduce the need vehicle through the appropriate location environmental impact. As far as the Local considered and implemented, before to travel, the length of journeys of new development. Development plans Planning Authority’s powers permit, considering requirements for the and make it safer and easier and LTPs should, amongst other things: planning permission will only be granted provision of new inland transport for people to access jobs via • Propose major development in where the proposal: infrastructure to deal with remaining non-car modes of travel. transport impacts (Paragraph 5.13.8). keeping with the roles of individual • Is of a design which both minimises

PUAs and larger towns on sites where environmental impact and risk of there will be a good choice of travel by accidents. sustainable transport, or where choice can be provided as part of the • Has no adverse effects on the character development, whilst regarding of sensitive or distinctive landscapes, regional accessibility standards. townscapes and areas of acknowledged historic or wildlife interest. Policy TRAN 6: Movement of Goods Local authorities, the business • Includes indigenous landscaping community, transport operators and other schemes to integrate into the agencies should work together to achieve surrounding area. more • Makes appropriate provision for pedestrians, cyclists the mobility impaired and facilitates access to public transport.

172 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives

sustainable patterns of distribution. In • Minimises the impact on the particular they should aim to: environment through mitigation and • Locate major freight generating compensation measures where development close to regional rail and necessary. road networks. Policy T/13: Bus facilities and infrastructure. • Support investment in rail gauge enhancements. The Local Planning Authority will support • the retention and enhancement of facilities In liaison with the Strategic Rail and infrastructure which support bus Authority, encourage the development services, including a new transport of rail freight terminals and transfer interchange facility on land adjacent to facilities in locations close to PUAs Minehead Railway Station. and at key locations where there is Both Sedgemoor and West Somerset good access to the regional rail District Council have objectives for network and the inter-urban road transport with their local Plans. The network, including terminals at objectives broadly translate as follows: Swindon, Avonmouth, Exeter, Plymouth and other centres and, • To reduce the need to travel and subject to feasibility, to meet the distances travelled. needs of Cornwall. • Maximum accessibility by sustainable • Reduce the impact of large vehicles modes of travel. on the environment through traffic • To reduce environmental damage and management measures and freight promote environmental improvement by quality partnerships, whilst traffic management. maintaining adequate access for delivery of goods. • Easy movement for pedestrians, cyclists and the mobility impaired; particularly within our Towns and larger settlements. • Reduced risk of accidents and improved road safety. • •

Sustainability Statement | October 2011 173

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Somerset & Exmoor National Park West Somerset Core Strategy Joint Structure Plan Review 1991-2001 Sustainability Appraisal Objectives.

(2000) (‘saved’ policies) Reduce the need to travel and facilitate Policy 39: Transport And Development modal shift (particularly reducing the impact Proposals for development should be of traffic during the peak Summer months). considered having regard to: Sedgemoor District Local Development Framework Core Strategy (Proposed • The management of demand for Submission) (September 2010) transport. Policy D9 Sustainable Transport and • Achieving a shift in transport modes to Movement alternatives to the private car and lorry Development proposals that reduce wherever possible. congestion, encourage an improved and • The need for improvements to integrated transport network and allow for a transport infrastructure. wide choice of modes of transport as a Policy 45: Bus means of access to jobs, homes, services and facilities will be encouraged and Facilities for buses should be improved. supported. Proposals will, amongst other This should include measures to give things, be compatible with the existing priority to buses and to introduce park transport infrastructure or, if not, provision and ride systems where these are the shall be made for improvements to most sustainable option. infrastructure to enable development to Policy 49 Transport Requirements Of proceed. New Development Policy D10 Managing the Transport Proposals for development should be Impacts of Development compatible with the existing transport Development proposals that will have a infrastructure, or, if not, provision should significant transport impact should meet a be made for improvements to series of objectives to mitigate transport infrastructure to enable development to impacts. proceed. Future Transport Plan for Somerset This document sets out the transport objectives for Somerset.

174 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Appraisal Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts on the Function and Efficiency of the Strategic Transport Infrastructure EDF Energy has completed a number of transport studies to determine the impacts of the existing road infrastructure on the project, as the construction phase will require significant movement of people and materials. Detailed studies are presented within the Transportation Chapter ( Chapter 10, Volume 2 and Chapter 8, volumes 3 – 11 ) of the Environmental Statement. Further information is also provided within the Freight Management Strategy. Guiding Question - Will it create changes to services and service capacity in population centres? EDF Energy is promoting a transport strategy which aims to transport the workforce by private bus to the HPC Construction Site, thus limiting impacts on existing capacities in Bridgwater and Cannington. Out of work hours, workers will be encouraged to use public transport. EDF Energy has worked with Somerset County Council to develop measures to ensure impacts on existing services are limited. Guiding Question - Will it result in the direct loss of strategic road/rail/air/port infrastructure? The development will not result in the loss of strategic transport infrastructure which would be used by others. Guiding Question - Will it result in increased congestion/pressure on key transport infrastructure? Information on transport infrastructure has been appraised within the Environmental Statement, with various measures considered to reduce the impact, including: • The construction of a new bypass around Cannington. • The refurbishment and extension of Combwich Wharf to maximise water-borne transport of AILs. • Provision of a temporary jetty at HPC for bulky aggregate delivery. • Shift patterns for construction workers so that they can be moved to and from the site outside peak traffic hours. • Strategic locations for construction worker accommodation, taking account of transport impacts. • Park and ride facilities and parking restraint measures. • Freight Management/Logistics facilities. • Minor road improvements, identifying haul routes which minimise congestion in Bridgwater, through development of a Freight Management Strategy. • Postal/courier delivery centres and proposals for a Delivery Management System.

Sustainability Statement | October 2011 175

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives In addition to the construction and operation of the main site, proposals for off-site associated development also demonstrate conformity to these objectives, as well as a number of local planning objectives for transport. Policy objectives set out by Sedgemoor and West Somerset District Councils include: • To reduce the need to travel and distances travelled. • Maximum accessibility by sustainable modes of travel. • Traffic management to reduce environmental damage and promote environmental improvement. • Easy movement for pedestrians, cyclists and the mobility impaired; particularly within Towns and larger settlements. • Reduced risk of accidents and improved road safety. The proposed location and design of off-site associated development – particularly the accommodation campuses– have been progressed in a way which minimises impacts on transport, promoting sustainable forms of transport. Key transport principles include: • Inclusion of cycle parking, and promoting car sharing and other travel planning initiatives. • Utilising buses for mass transit to and from the site (up to 40 people per journey). Summary The proposals will conform to the objectives, particularly during the operation phase of HPC, with the future use of the S M L Cannington bypass and various other highway improvements. The largest impact on transport infrastructure will arise during the construction phase, however EDF Energy have considered a range of comprehensive measures to manage transport 
0? impacts during this period.

176 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Avoid Disruption to Basic Services and Infrastructure Regional Planning Guidance for the West Somerset District Local South West (RPG 10) (2001) Development Framework Core Strategy Options Paper (January 2010) Policy EN5: Health, Education, Safety and other Social No relevant objectives/policies. Infrastructure West Somerset Core Strategy Health, education and other social Sustainability Appraisal Objectives. infrastructure requirements need to be Ensure equitable access to viable fully accounted in development facilities and services for all sectors of the planning throughout the region. community including those in rural areas. South West Sustainability Checklist Sedgemoor District Local Plan (2004) To ensure people can reach facilities (‘saved’ policies) they require using an appropriate mode Policy PCS7 of transport, encouraging walking and Loss of Community Facilities and public transport use and reducing the Services use of private cars for shorter journeys. Planning permission for proposals that RSS for the South West would result in the loss of community Incorporating the Secretary of facilities and services will be refused State’s Proposed Changes for Public unless: Consultation (July 2008). • Appropriate alternatives are available Development Policy D: locally. Infrastructure The planning and delivery of • The proposed use would be of equal development should ensure efficient or greater community benefit. and effective use of existing • Existing use is no longer viable. infrastructure and should provide for Where planning permission is granted for the delivery of new or improved the change of use of an important facility, transport, education, health, culture, conversion works

Sustainability Statement | October 2011 177

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives

sport and recreation and green • should not preclude a later reversion infrastructure in tandem with to the original use. development. • Provision of a medical centre on Main Somerset & Exmoor National Park Site to cater for increased workforce. Joint Structure Plan Review 1991- 2001 (2000) (‘saved’ policies) ) • Providing support to GP surgeries to Policy STR1: Sustainable cater for longer term increase in Development population arising from the operation of the facility. Development in Somerset and the Exmoor National Park should develop a • Opportunities to extend existing pattern of land use and transport which community provision as part of legacy. minimises the length of journeys and Sedgemoor District Local the need to travel and maximises the Development Framework Core potential for the use of public transport. Strategy (Proposed Submission) (September 2010) Policy D19 Health and Social Care Appraisal Hinkley Point Strategic Sustainability Objective: To Avoid Disruption to Basic Services and Infrastructure Guiding Question - Will it result in loss or disruption to basic services and infrastructure (for example electricity, gas)? Basic services include water, power and sewerage. The implication of development of HPC, although placing demands on existing infrastructure, particularly water, is not predicted to cause significant disruption to such services and infrastructure. The most significant volume of water required for the operation of the facility is for cooling. The power station will make use of seawater for this purpose, making no additional demand on potable water. However, the operation of the facility will require a significant amount of potable water, and evaluations identify that the existing water main to the site is inadequate to meet predicted requirements. Significant volumes of water are required to generate steam to drive the turbines. EDF Energy has explored the opportunity for desalination to meet this demand; however this is not being progressed as the potential water source for this purpose in the Bristol Channel has a high level of suspended solids, requiring filtration and disposal of significant quantities of solid material. The proposal pursued will draw water from Wessex Water supplies. Regarding sewerage, the existing Hinkley Point Power station complex utilises its own sewage treatment plant, which is not made available for use by others. Evaluation of the plant serving HPB has identified that it is not sufficient for HPC. Utilisation of new plant will not place increased stress on existing infrastructure, therefore broadly accords with the objective to avoid disruption to basic services and infrastructure.

178 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives HPC will be largely self sufficient regarding its energy source. As with HPA and HPB, there will be no gas supply to the power station complex, and so the site is solely reliant on electricity to meet power requirements. The electricity will be generated on site, with the exception of electricity required during construction and commissioning, which will be taken from an existing 275 kV substation. A new 400 kV substation will be constructed which HPC will utilise. The construction and operation of off-site associated development will place varying demands on basic services. Evaluations have been undertaken or the basic services, particularly in Bridgwater. Based on the scale of the proposals for off-site associated development, the impacts on basic services is not significant. Guiding Question – Will it impact emergency services and community infrastructure? EDF Energy has undertaken extensive work with emergency services and local authorities in respect of community safety. Outline Contingency Response Arrangements have been developed, and overview of which can be seen appended to the Community Safety Management Plan. Police: the potential for nuclear demonstrations during construction is a central concern; however EDF Energy’s security arrangements with local police services are significant. More broadly, consideration has been given to anti-social behaviour and increased incidence of crime. Given the strict enforcement of the worker code of conduct, mitigation measures are in place to ensure the workforce do not contribute to a significant change in the presently low crime levels. Fire Services: the potential for impact on fire services may arise from two sources; through potential incidents onsite during the construction process, and from any increase in services due to the temporary increase in population caused by the construction workforce. It is not possible to quantify these as they are not based on any specific incidents; however it is likely the impact will be negligible. Healthcare: EDF Energy proposes various measures to minimise the impact of the construction workforce on the healthcare capacity of area. Increased demand for local healthcare will arise from non-home based workers where workers (or their families) register for services with a local GP, and/or are referred by the GP for other specialist services. Increased pressure may also occur where they require ambulance services. Plans involve an onsite clinic contracted with external provider Dura Diamond, to create a situation where construction workers do not have to register with a local GP. This will minimise the impact on local healthcare. However, still realising that the effects of the construction workforce on HPC will be felt – for example in the case of an ambulance needing to be called out – EDF Energy propose to financially support local healthcare services and thus overall impact is expected to be negligible. This is discussed in further detail in the HIA. Guiding Question - Will it place significant pressure on local/regional waste management facilities (non-nuclear waste)? This is assessed under the materials and waste section of the Sustainability Framework. A comprehensive Waste Management Implementation Strategy has been developed which takes account of local waste management provision. EDF Energy maintains an objective within that strategy, to reduce impacts on this key service. To achieve this, it is proposing various initiatives, including making use of a number of facilities (addressing the proximity principle), and selling directly to market, rather than overburdening existing waste transfer facilities and recycling facilities. Summary The proposals for HPC are being pursued in a manner which reduces pressure on existing services as far as possible. EDF S M L Energy has undertaken extensive consultation with key service providers, and has developed plans and actions to reduce impacts. This is supplemented with various requirements and obligations put forward for the DCO and payments made via 0 0 0 Section 106 obligations.

Sustainability Statement | October 2011 179

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

4.9 Human Health and Well-being

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Avoid Impacts on Physical Health Regional Planning Guidance for West Somerset Core Strategy the South West (RPG 10) (2001). Sustainability Appraisal Objectives. Policy EN5: Health, Education, To improve the health and well being of Safety and other Social the population and improve access to Infrastructure health services for all. Health, education and other social Sedgemoor District Local Development infrastructure requirements need to Framework Core Strategy (Proposed be taken into account fully in Submission) (September 2010) development planning throughout Policy D19 Health and Social Care the region. Development plans and programmes should: All major planning applications will be • required to provide a Health Impact Have regard to the impacts of Assessment that identifies the potential proposed developments on the health effects of the project and how health of local communities, mitigation measures, if necessary, have taking advice from Health been included in the development Authorities. proposal. Appraisal Hinkley Point Strategic Sustainability Objective: To Avoid Impacts on Physical Health Guiding Question - Will it adversely affect the health of local communities through accidental radioactive discharges or exposure to radiation? It is a fundamental principle of UK nuclear safety regulation that “all reasonably practicable steps must be taken to prevent and mitigate nuclear and radiation accidents” (HSE 2006a, 2006b). In keeping with such principles, the proposed facility design is derived from the latest generations of reactors built in France (N4 Reactors) and Germany (KONVOI Reactors) and combines the safety experience and knowledge acquired from operating reactors, and is to incorporate the lessons learned following Fukushima. The proposed safety options also benefit from the results of research and development to prevent accidental radioactive discharge. The radiological assessment performed as part of the Health Impact Assessment indicates that once operational, the proposed facility will not generate radiological emissions of a level to result in any deterministic health effects, or of a level to result in any likely low level radiation health effects.

180 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Guiding Question - Will the storage of radioactive waste result in adverse physical and mental health effects for local communities? The implication of storage of radioactive waste on community’s physical and mental health has been scoped out of the HIA, however has previously been assessed. With regards to physical health, a dose assessment has been provided within the HIA which identifies a very low risk to physical health. The radiological assessment section of the Health Impact concludes that the potential dose to a member of the public arising from all current and past operations in the area would be within the region of ‘tolerable risk’ advocated by the HSE (1992) for a new nuclear power station, as a single source, and is significantly lower than the upper limit on tolerability per year when considering all man-made sources (with the exception of medical exposures) taken together. Guiding Question - Will it adversely affect the health of the workforce? Information from the Health and Safety Executive demonstrates that the construction industry in general, presents one of the most hazardous working environments within the UK. However, this does not relate to major infrastructure projects such as HPC, which employ significant risk prevention and occupational health promotion initiatives to facilitate a safe, healthy, and cost effective workforce with minimal downtime or impact to surrounding health care services. In this instance, EDF Energy has commissioned Dura Diamond to provide bespoke occupational and health promotion services that draws on their experience on major projects such as the construction of the London Olympic Park and Euro tunnel. The service provision will significantly remove and reduce occupational health risk, yet also includes health promotion and care services that will benefit both home and non-home-based workers over and above what they receive on general construction projects. This service is further supported by local health care support to plan for and address any residual impacts on local services, and where possible coordinate occupational and public health promotion initiatives to greater effect. Summary EDF Energy is developing an HIA which identifies the health impacts from a number of pathways. A key consideration has been S M L the impacts from radiological material on human health. This process is being managed through a process of regulatory justification.


When considering wider health impacts, It is acknowledged that a key mechanism for managing health will be via a Health Action 0 Plan, which has been developed through liaison with local health authorities. The Nuclear NPS states that given the potential for positive employment opportunities as a result of the development of new nuclear power stations the IPC should give significant weight to the effect of employment on human health and well being. Appraisal Hinkley Point Strategic Sustainability Objective: To Avoid Impacts on Mental Health Guiding Question - Will the storage of radioactive waste result in adverse physical and mental health effects for local communities? The implication of storage of radioactive waste on communities’ physical and mental health has been evaluated within the HIA. In terms of mental health, it is the case that local community health concern and perceived risks can increase stress and anxiety that may lead to changes in physical and mental health. This is addressed below under perceived risk.

Sustainability Statement | October 2011 181

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Guiding Question - Will exposure to noise and vibration as a result of plant activities lead to physical and mental health impacts on nearby communities? The construction and operation of the proposed development, as with all development will comply with environmental standards set to protect the environment and community health. It is appreciated however, that construction will be disruptive to local communities, and although significant mitigation and a community impact fund will be provided, ongoing and meaningful community engagement will be necessary to respond to and address the more intangible aspects important to mental health and well-being. Guiding Question - Will the perceptions of adverse risk as a result of activities lead to adverse impacts on mental health for nearby communities? It is the case that local community health concern and perceived risks can increase stress and anxiety that may lead to changes in physical and mental health. The only way of addressing such perceived health concerns is through the factual assessment and dissemination of information. The Health Impact Assessment has been voluntarily commissioned to investigate potential health issues, to aid in separating perceived from actual risks, and in addition to developing recommendations to further manage community disruption and risk, is to develop community support initiatives and recommendations to address local concerns and anxiety. Summary The links between mental health and the proposals for HPC is a complex issue which is being evaluated within the HIA. In general, S M L it is considered that mental well-being is most closely linked with perceived risk, and community uncertainties regarding the effectiveness of proposed mitigation and support. EDF Energy proposes to manage this through the dissemination of information through the Health Action Plan. In general, the objective to avoid impacts on mental health is supported by the proposals, and may 0

? be exceeded over the medium to longer term as awareness is raised within local communities.

182 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Avoid the Loss of Access and Recreational Opportunities, their Quality and User Convenience Planning Policy Guidance 17: Regional Planning Guidance for the West Somerset District Local Plan (2006) (‘saved’ Planning for open space, South West (RPG 10) (2001). Policy policies) sport and recreation (2002) TCS2: Culture, Leisure and Sport Policy T/9: Existing Footpaths. Open spaces, sports and Local authorities and other agencies in Any development affecting an existing footpath will recreational facilities have a vital their plans, policies and proposals be required to incorporate the footpath into its design. role to play in promoting healthy should: Care should be taken to ensure that the footpath is living and preventing illness, • Identify and protect recreational attractive to users and safe. and in the social development of open spaces and playing fields. West Somerset Core Strategy Sustainability children of all ages through play, Appraisal Objectives. sporting activities and Draft Revised RSS for the South interaction with others. West Incorporating the Secretary of Ensure provision is made to incorporate green State’s Proposed Changes for infrastructure into spatial planning.

Public Consultation (July 2008) Sedgemoor District Local Plan (2004) (‘saved’

Development Policy D: policies) Infrastructure Policy: RLT1 Protection of Recreational Open The planning and delivery of Space. development should ensure efficient Development which would result in the loss of and effective use of existing recreational open space will not be permitted unless: infrastructure and should provide for the delivery of new or improved • The existing sports and recreation facilities can transport, education, health, culture, best be retained and enhanced through the sport and recreation and green redevelopment of a small part of the site; or infrastructure in step with development. • A replacement facility of equivalent sports and/or recreation benefit is made available; or

Sustainability Statement | October 2011 183

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives

• The proposed development provides sports and/or recreation facilities of greater benefit than the long-term recreational value of the open space that would be lost. Policy: RLT3 Outdoor Sports facilities and New Residential Areas All new housing developments will normally be expected to contribute towards the provision of outdoor sites for sport at a rate of 40 square metres per dwelling. In determining the nature of the provision required, account will be taken of the type of dwellings proposed and the quantity and quality of existing outdoor sports provision in the area. Policy H2 Residential Development Criteria for Towns Within the development boundaries of Bridgwater and Burnham-on-Sea and Highbridge, residential development will be permitted, provided it meets the following criteria: • It would not involve the loss of land of recreational and/or amenity value, or of townscape importance. Sedgemoor District Local Development Framework Core Strategy (Proposed Submission) (September 2010) Policy D21 Community and Cultural Facilities • New development that creates a need for additional provision that cannot be met through existing facilities will be expected to meet any identified shortfall. Appraisal Hinkley Point Strategic Sustainability Objective: To Avoid the Loss of Access and Recreational Opportunities, their Quality and User Convenience

184 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Guiding Question - Will it result in the loss of recreational and amenity land or loss of access? Recreation has been evaluated within the Amenity and Recreation Chapter 25, Volumes 2 and Chapter 17, Volumes 3 – 11 of the Environmental Statement . During construction of the Hinkley Point C (HPC) project, a site security boundary will in place to enclose the construction site for the safety and security of the public. This will cut across a number of public rights of way for the duration of the construction phase and for many also the operational phase. Temporary closure is also expected of the West Somerset Coast Path that runs along the coastline. It is proposed that several lengths of temporary footpath would be provided around the boundary of the construction work area to reduce impacts on PROW’s. This would include a diversion for the West Somerset Coast Path. Furthermore, EDF Energy will ensure that a number of measures are adopted to ensure that access to remaining facilities during operation is improved. This includes proposals for: • Improved access through clearance, surfacing, and signposting along a number of routes. • Upgrading of routes. • Opportunities for rationalisation of the footpath network to ensure access is improved. The construction of the main development site will not directly impact upon any existing sports and recreation facilities, open access land or areas of public open space. Where public space will be lost such as the Bridgwater Rugby Football Club pitch, adequate compensation will be provided. A number of PROW’s will be impacted from the construction of off-site associated development. In general mitigation will be applied consistent to that proposed on Main Site. Guiding Question - Will it adversely affect the ability of an individual to enjoy and pursue a healthy lifestyle? The proposals will not impact upon the ability for an individual to enjoy a healthy lifestyle. The Environmental Statement identifies that there will be a negligible impact on disturbance to existing recreation, and the establishment of an EMMP would help to minimise construction related impacts such as the generation of dust and noise, increased traffic and visual impacts that may have an impact. The Health Impact Assessment (HIA) broadly catalogues the implications of loss of leisure, in amongst other factors such as physical security and employment in identifying implication son well-being. Accordingly, recommendations have been put forward through the Health Action Plan (HAP) to minimise any change in well-being. Furthermore, a series of proposals exist to promote health and recreation. EDF Energy is proposing to deliver high quality accommodation campuses which include a range of recreational facilities for the workforce, including sports facilities and cycle storage. A wider range of measures will be delivered via community benefits, which may further support the community to pursue a healthy lifestyle. Summary In general the development proposals achieve this objective. EDF Energy has explored impacts on recreation and amenity within S M L the EIA. These impacts are temporary in nature, and in many cases put forward they enhance access and user convenience. There will be disruption to a number of PRoWs during construction activities, however in general these impacts are temporary in nature and not considered to prevent the objective from being achieved. Benefits from the Community Fund will contribute to 0
0? overall improvement of the area.

Sustainability Statement | October 2011 185

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

4.10 Historic Environment (Cultural Heritage in the AoS)

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts on the Internationally and Nationally Important Features of Historic Environment

PPS 5 Planning for a Historic Regional Planning Guidance for the West Somerset District Local Plan Environment (2010) South West (RPG 10) (2001) Policy (2006) (‘saved’ policies) PPS5 sets out planning policies on the EN 3: The Historic Environment No relevant objectives/policies. conservation of the historic Local authorities and other agencies in West Somerset District Local environment. It states that planning their plans, policies and proposals Development Framework Core has a central role to play in conserving should: Strategy Options Paper (January 2010) our heritage assets and utilising the • Indicate that new development Conserve and enhance the character of historic environment in creating should preserve or enhance historic historic settlements, buildings and sustainable places. The policies buildings and conservation areas landscapes. contained within PPS5 will enable the and important archaeological Government’s vision for the historic Sedgemoor District Local Plan (2004) features and their settings, having environment to be implemented (‘saved’ policies) regard to the advice in PPG15 and through the planning system. Policy HE11: Archaeological Sites of PPG16. National Importance PPS5 introduces the concept of a • “heritage asset”, which is defined as Indicate that policies and There will be a presumption in favour of those parts of the historic environment programmes should work towards preservation in situ of nationally important that have significance because of their rescuing buildings and monuments archaeological sites, whether scheduled historic, archaeological, architectural at risk. or not. Planning permission will not be or artistic interest (page 5). Heritage • Encourage the restoration and granted for development that would assets include designated heritage appropriate re-use of buildings of damage or destroy these sites or their assets (World Heritage Sites, historic and architectural value and settings unless the importance of the Scheduled Monuments, Listed take a particularly active role in proposed development outweighs the Buildings, Protected Wreck Sites, bringing about their restoration national significance of the remains. In Registered Parks and Gardens, where this would help bring about that event, mitigation strategies should be Registered Battlefields and urban regeneration. in place for the protection and recording Conservation Areas) and assets of the site. • Take account of the landscape identified by the local planning authority during the process of context and setting of buildings and settlements; of building

186 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives decision-making or through the plan- • materials; and of the patterns of Policy HE13: Management and making process (including local listing) fields, hedgerows and walls that Interpretation of Archaeological Sites (page 13). distinguish one area from another. Where development is proposed in the

Somerset & Exmoor National Park vicinity of important archaeological sites, Joint Structure Plan Review 1991- consideration should be given to the 2011 (2000) (‘saved’ policies) promotion of schemes for their management, interpretation and public Policy 12: Nationally Important access. Archaeological Remains Sedgemoor District Local “There should be a presumption in Development Framework Core favour of the physical preservation in Strategy (Proposed Submission) situ of nationally important (September 2010) archaeological remains. The setting and amenity value of the Policy D17 Historic Environment archaeological remains should be All development proposals should protected”. contribute to enhancing and maintaining the historic environment, ensuring a continued role in distinguishing the District’s unique sense of identity and place. Where development resulting in the loss of an historic asset is exceptionally permitted, the Council will require the recording of features of interest that would be destroyed in the course of any proposed work. Appraisal Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts on the Internationally and Nationally Important Features of Historic Environment Guiding Question - Will it adversely affect historic sites of international/national importance and their setting? Detailed assessment work, including desk-based and field surveys, has been undertaken for the project as part of the EIA. These ascertained that there are no Scheduled Monuments, Listed Buildings, Conservation Areas, Registered Parks and Gardens within the site boundary of the HPC development site. There are however a range of nationally important assets around the site, which have potential adverse impacts on their setting. The closest is the Wick Barrow Scheduled Ancient Monument (SM). The setting of the monument will be affected by the proposals, particularly during construction, which is predicted to be of major adverse significance, however with the adoption of a Monument Management Plan and enhancements to its immediate setting, this will be a minor adverse impact. Impacts are also predicted

Sustainability Statement | October 2011 187

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives to occur during operation, prior to the application of mitigation. The Monument Management Plan has been prepared to aid the long-term conservation of the site and setting of the monument. Further details are available within Volume 2, Chapter 23 Historic Environment. The Wick Barrow SAM is currently overgrown; part of the Monument Management Plan will enable scrub clearance and long term benefits. This will be coupled with an outreach programme, enabling increased understanding of the Mound. The proposals at the HPC development site also have the potential to impact upon Fairfield House and Gardens, which is a grade II* listed building located to the west of the HPC development site, landscaping and screen planting would be applied to reduce impacts. Less able to be mitigated however are impacts on nationally designated assets located in the Quantocks, including the earthwork remains of an Iron Age hill fort and a Bronze Age bowl barrow on Dowsborough Hill. With regard to off-site associated development, the principal area lies with Cannington bypass. There are no designated heritage assets (Scheduled Monuments, Listed Buildings, Conservation Areas, Registered Parks and Gardens, Registered Battlefields, Important Hedgerows or Ancient Woodlands within the site boundary, however some of these important features are located nearby to the sites. The route of the Cannington bypass will impact upon three archaeology sites have been identified within the site boundary through geophysical surveys. Construction would result in the removal of buried archaeology. The route also crosses Brymore ‘ride’, which is a tree lined avenue associated with Brymore school, a grade II listed building. Whilst the ride is not listed, the route has the potential to impact the setting, particularly during construction. Summary A comprehensive assessment of the historic environment impacts has been undertaken within the EIA. EDF Energy has S M L identified mitigation where possible to reduce impacts. Bearing in mind that the appraisal objective focuses most closely on international and nationally significant features, the most significant cultural heritage impacts at the HPC development site would be on Pixies Mound, which is a Scheduled Monument containing buried archaeological remains. The development of HPC is likely to impact on the setting of this nationally significant feature. Given the location of existing HPA and HPB, however, this impact is predicted to be minor. Furthermore, this monument will be preserved in-situ in accordance with relevant planning  0 0? policies and a Monument Management Plan enacted. For offsite associated development, the impacts are broad however will generally result in the setting of the historic assets being affected. Where impacts are identified mitigation has been put forward and consulted upon.

188 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts on the Setting and Quality of Built Heritage, Archaeology and Historic Landscapes Regional Planning Guidance for the West Somerset District Local South West (RPG 10) (2001). Policy EN Development Framework Core 3: The Historic Environment Strategy Options Paper (January Local authorities and other agencies in 2010) their plans, policies and proposals should: Conserve and enhance the character of afford the highest level of protection to historic settlements, buildings and historic and archaeological areas, sites landscapes (Paragraph 5.2.2) and monuments of international, national West Somerset Core Strategy and regional importance; Sustainability Appraisal Objectives Draft Revised RSS for the South West Protect the fabric and setting of Incorporating the Secretary of State’s designated and undesignated Proposed Changes for Public archaeological sites, monuments, Consultation (July 2008) structures and buildings, recorded Policy ENV1: Protecting and Historic Parks and gardens, maritime Enhancing the Region’s Natural and and coastal heritage, listed buildings Historic Environment and conservation areas. States that, where development and Sedgemoor District Local Plan changes in land use are planned which (2004) (‘saved’ policies) would affect the natural and historic Policy HE5: Retention of Listed environment, local authorities will first Buildings seek to avoid loss of or damage to the The repair and conservation of assets, then mitigate any unavoidable Buildings of Architectural or Historic damage, and compensate for loss or Interest will be encouraged damage through offsetting actions. Policy HE9: Other Archaeological Policy ENV5: Historic Environment Sites and Areas States that the historic environment of the Where development proposals will South West will be preserved and affect Areas of High Archaeological enhanced

Sustainability Statement | October 2011 189

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Somerset & Exmoor National Park Potential and elsewhere where there is Joint Structure Plan Review 1991-2011 reason to believe that there may be (2000) (‘saved’ policies) archaeological remains, an assessment Policy 9: The Built Historic of the nature, character and importance Environment of the site will be sought prior to the determination of any planning The setting, local distinctiveness and application variety of buildings and structures of architectural or historic interest should be Policy HE12: Other Archaeological maintained and where possible Sites and Areas enhanced. The character or appearance Planning permission will not be granted of Conservation Areas should be for development which would damage preserved or enhanced. or destroy locally important Policy 11: Areas of High archaeological remains, unless the Archaeological Potential importance of the development outweighs the local significance of the “Development proposals should take remains. Where physical preservation account of identified Areas of High in situ is not possible, mitigation Archaeological Potential or, elsewhere strategies will be required for the where there is reason to believe that protection and/or recording of the site important remains exist, so that appropriate assessment and necessary Sedgemoor District Council Local protection can be afforded to any Development Framework Core archaeological remains identified”. Strategy (Proposed Submission) (September 2010) Policy 13: Locally Important Archaeological Remains Policy D17: Historic Environment “Development proposals which affect All development proposals should locally important archaeological remains contribute to enhancing and should take account of the relative maintaining the historic environment, importance of the remains. If the ensuring a continued role in preservation in situ of the archaeological distinguishing the District’s unique remains cannot be justified, arrangements sense of identity and place. should be sought to record those parts of the site that would be destroyed or altered”.

190 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Appraisal Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts on the Setting and Quality of Built Heritage, Archaeology and Historic Landscapes Guiding Question - Will it adversely affect buried archaeology? As a prerequisite to the construction works on a number of sites, topsoil stripping will take place and the creation of temporary work areas and areas to be used for the storage of spoil. Buried archaeology exists at the HPC development site as well as a number of the off-site associated developments. In certain instances, archaeological watching briefs will be established with objectives to monitor continuously all excavation and removal of soil that may contain archaeological deposits for the duration of the proposed works; and to identify and record any archaeological features, deposits, artefacts or other material uncovered by the proposed works. In most cases, preservation by record is proposed as mitigation In partnership with Somerset County Museum, EDF Energy intents to exhibit many of the significant archaeological remains within the PIC. Guiding Question - Will it adversely affect landscapes of historic importance? Historic landscape characterisation has no statutory basis; however local planning authorities are required to "take account of the historical dimensions of the landscape as a whole". An assessment on the historic environment has been undertaken as part of the EIA process ( Chapter 17 , Volume 3 – 11 ), which includes assessing impacts on the historic landscape and the selling of designated heritage assets. Summary The development proposals will impact upon buried archaeology. EDF Energy will undertake preservation by record on any S M L heritage assets that will be lost due to the development. Impacts on the setting of historic assets have also been considered within the Environmental Statement. The worst effects will occur during the construction period and are therefore temporary in nature. During the short-term there is a negative relationship with this objective. During operation the impacts are reduced, for example there will be no negative effects on buried archaeology.

 0 0 More broadly, EDF Energy is undertaking a series of steps to enhance access to the historic environment. The PIC will contain a heritage display (designed in conjunction with Somerset Museum) describing the history of the site from pre-historic times until the present day and presenting archaeological artefacts from the site excavations as well as information on retained heritage assets such as the Green Lane track way and Wick Barrow (Pixies Mound). Heritage trails and interpretation boards throughout the restored landscape will also be provided.

Sustainability Statement | October 2011 191

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

4.11 Landscape

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts on the Nationally Important Landscape PPS 1: Delivering Sustainable Regional Planning Guidance for the West Somerset Local Plan (2006) Development (2005) outlines the South West (RPG 10) (2001). Policy (‘saved’ policies) Government policies on delivering EN 1: Landscape and Biodiversity Policy LC/3: Landscape Character sustainable development through the Local authorities and other agencies, Where development is permitted outside planning system. PPS1 states: in their plans, policies and proposals, development limits, particular attention “planning authorities should seek to should, amongst other things, provide will be given to the protection of the enhance as well as protect …. the historic for the strong protection and scenic quality and distinctive local environment and landscape and enhancement of the region’s character of the landscape. townscape character” internationally and nationally Development, which does not respect PPS 7: Sustainable Development in important landscape areas and nature the character of the local landscape will Rural Areas (2004) conservation sites. not be permitted. PPS 7 sets out Government policy on the Draft Revised RSS for the South Sedgemoor District Local Plan (2004) conservation of the natural beauty of the West Incorporating the Secretary of (‘saved’ policies) State’s Proposed Changes for landscape and countryside. It states that, Policy CNE2 Landscape Character nationally designated areas have been Public Consultation (July 2008) Development which adversely affects confirmed by the Government as having Policy ENV3 Protected local landscape character or scenic the highest status of protection in relation Landscapes quality will not be permitted. In to landscape and scenic beauty ...Particular care will be taken to particular: (Paragraph 21). ensure that no development is Consultation Paper on a New Planning permitted outside the • Siting and landscaping should take account of visibility from publicly Policy Statement: Planning for a National Park or Areas of Outstanding accessible vantage points. Natural and Healthy Environment Natural Beauty which would damage (March 2010) their natural beauty, character and • The form, bulk and design of In its final form, the PPS will replace special qualities or otherwise buildings should have proper regard paragraphs 21 to 23 in PPS7 which relate prejudice the achievement of National to their context in respect of both the to landscape protection. Park or Area of Area of Outstanding immediate setting and the defining With specific reference to landscape Natural Beauty purposes. characteristics of the wider local protection, proposed Policy NE8.5 area. maintains the approach set out in Paragraph 21 of PPS7. In addition,

192 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives proposed Policy NE8.5 advises that, in Somerset & Exmoor National Park • In determining planning applications consideration of applications for major Joint Structure Plan Review 1991- the important characteristics of development proposals should include an 2011 (2000) (‘saved’ policies) landscape character areas described assessment of:, amongst other things, Policy 5 Landscape Character in the Sedgemoor Landscape any detrimental effect on the environment, The distinctive character of the Assessment and Countryside Design the landscape and recreational countryside of Somerset and the Summary and/or AONB Landscape opportunities, and the extent to which that Exmoor National Park should be Assessments will be a material could be moderated. safeguarded. Particular regard should consideration. be had to the distinctive features of Sedgemoor District Council Local the countryside in landscape, cultural Development Framework Core heritage and nature conservation Strategy (Proposed Submission) terms in the provision for (September 2010) development. Policy D14 Natural Environment, Bridgwater Bay to Bideford Bay Landscape Shoreline Management Plan 1998 Proposals should ensure that they Maintain the landscape character of enhance the landscape quality wherever the area and observe heritage possible or that there is no significant coast/Area of Outstanding Natural adverse impact on local landscape Beauty/National Park Objectives. character, scenic quality and distinctive Strategy for the Severn Estuary landscape features. (2001) and Quantock Hills AONB Management Plan Appraisal Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts on the Nationally Important Landscapes Several national landscape designations have been identified within the landscape and visual assessment within the Environmental Statement ( Chapter 22, Volume 2 and Chapter 15, volumes 3 – 10 ). This primarily includes Exmoor National Park, Quantock and Mendip Hills Areas of Outstanding Natural Beauty (AONB). The Government has identified three guide questions which relate to adverse impacts on important landscapes. These include: • Will it adversely affect landscapes within or immediately adjacent to a National Park? • Will it adversely affect landscapes in or immediately adjacent to an AONB or National Scenic Area?

Sustainability Statement | October 2011 193

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives

• Will it adversely affect Heritage Coast or Preferred Conservation Zones? A number of assessment studies have been undertaken to determine the influence of HPC and its off-site associated development on sensitive view points, these have been taken from both on land and the coastline in the case of the main site. Impacts are categorised as both landscape and visual. Guiding Question - Will it adversely affect landscapes within or immediately adjacent to a National Park? Exmoor National Park is located 20 km away from the HPC development site, however, due to the designation of the park, has been included as a potential viewpoint for the landscape and visual assessment. Due to the distance from the HPC development site, HPC will be difficult to see. Further to this, since the existing two stations HPA and HPB are located at the site, the introduction of a HPC is expected to have very limited impacts. With regards to off-site associated development there are not expected to be impacts on this designation due to their distance from the National Park and their relatively smaller size. Williton is the closest site at 3km, but impacts on possible views are not considered to be significant. Furthermore, Cannington bypass, although a visible feature in the landscape is not considered to impact on this given the distance. Guiding Question - Will it adversely affect landscapes in or immediately adjacent to an AONB or National Scenic Area? There are two Areas of Outstanding Natural Beauty (AONB’s) within the study area of the HPC development site. This includes the Quantock Hills and Mendip Hills AONB’s. The HPC development site is within 4 km of the Quantock Hills AONB, and 18 km of the Mendip Hills AONB. Whilst the development is situated outside of the AONB’s, this is still an important consideration for the landscape and visual assessment. As the HPC development site is located adjacent to the existing HPA and HPB, the impacts of this new landform are reduced compared to a scenario where HPA and HPB are not present. The buildings have been arranged in a hierarchy of scale relative to the site platform levels to minimise the visual impact of the development. The tallest structures would still be visible, but with the lower level clutter screened, these structures would visually integrate the site into the landscape and so lessen the impact of HPC on local landscape character and the setting of the Quantock Hills AONB. The impacts of off-site associated development is typically less significant than the HPC development site, since off –site associated development is smaller and less obtrusive in the landscape. Guiding Question - Will it adversely affect Heritage Coast or Preferred Conservation Zones? Impacts from the HPC have been considered from a number of viewpoints, including the coastline and the sea. Summary The construction of a new nuclear power station is envisaged to have an impact on the surrounding landscape, however given S M L that the site is immediately adjacent to HPA and HPB, , the impacts on the landscape are less significant in that context . Furthermore, due to the distances between the HPC development site and nationally important landscapes, the objective is considered to be met. 0 0 0

194 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Avoid Impacts on Landscape Character, Quality and Tranquillity, Diversity and Distinctiveness Regional Planning Guidance for Policies from West Somerset Local Plan the South West (RPG 10) (2001). and also Sedgemoor ensure that individual Policy EN 1: Landscape and buildings are sympathetic to the Biodiversity landscape. Local authorities and other agencies, West Somerset Local Plan (2006) in their plans, policies and proposals, (‘saved’ policies) should, amongst other things; Policy BD/2 – Design of New • “indicate that the protection and, Development where possible, enhancement of Proposals for new development should the landscape and biodiversity respect the scale and character of their should be planned into new surroundings. Planning applications for development; new buildings will only be permitted where: • have regard to the significant • The siting of the building(s) has regard landscape joint character areas of to its relationship with adjoining the region set out in this RPG buildings and open spaces. (Map 4) and aim to conserve and • The building materials and detailing are enhance local character; and appropriate to the area and • take measures to protect the sympathetic to adjoining buildings. character of the countryside and • The design of the building(s) is in scale the environmental features that and harmony with adjoining buildings contribute towards that character, and the area as a whole. including minimisation of light pollution.” • Walls, fences and outbuildings are Draft Revised RSS for the South appropriate to the area and will respect West Incorporating the Secretary the character predominating in the of State’s Proposed Changes for locality. Public Consultation (July 2008). Policy BD/1: Siting, Layout and Form. Policy ENV2 Landscape Character New development will only be permitted Areas which is sympathetic to the scale and The distinctive qualities and features layout of existing buildings and spaces of the South West’s landscape within a distinct neighbourhood or street or

Sustainability Statement | October 2011 195

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives character areas will be sustained and in the countryside which respects local enhanced by Local Planning land form, field patterns and tree and Authorities undertaking assessments hedgerow cover. of landscape character at a strategic West Somerset Core Strategy level and in partnership with adjoining Sustainability Appraisal Objectives. authorities (where landscape Reduce impacts on tranquillity from noise character areas cross administrative and visual intrusion. boundaries) in order to identify priority areas for the maintenance, Ensure that special and distinctive enhancement and/or restoration of landscapes, and the features within them, that character and provide an are conserved and enhanced. appropriate policy framework in Sedgemoor District Local Plan (2004) LDD’s for each area. (‘saved’ policies) Policy SD3 The Environment and Policy BE8: Local Materials. Natural Resources The Council will seek to ensure that The region’s environment and natural indigenous construction materials are resources will be protected and employed wherever possible and enhanced by: appropriate, particularly where this is a prominent feature of a locality. • Ensuring that development respects landscape and ecological Sedgemoor District Council Local thresholds of settlements. Development Framework Core Strategy (Proposed Submission) (September Somerset and Exmoor National 2010) Park Joint Structure Plan Review 1991-2011 (2000) (‘saved’ policies) Policy D14: Natural Environment Policy 5: Landscape and Character “Proposals should ensure that they “The distinctive character of the enhance the landscape quality wherever possible or that there is no significant countryside of Somerset and the adverse impact on local landscape Exmoor National Park should be character, scenic quality and distinctive safeguarded for its own sake. landscape features as identified in the Particular regard should be had to Sedgemoor Landscape Assessment and landscape, cultural heritage and Countryside Design Summary.” nature conservation terms in the provision for development.”

196 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Appraisal Hinkley Point Strategic Sustainability Objective: To Avoid Impacts on Landscape Character, Quality and Tranquillity, Diversity and Distinctiveness The Overarching NPS details that nuclear power stations are commonly constructed in less populated areas, in accordance with the demographic principle, which requires development to be located outside of urban centres. These landscapes are likely to be valued aesthetically, however the net benefits of a nuclear power station to an area must be considered. The Overarching NPS details, one of the criteria for consideration by the IPC will relate to ‘Principles of Good Design’; this requires that energy infrastructure is as visually attractive as possible, which should be delivered by good architecture and appropriate landscaping. Whilst HPC is an engineering led project, ensuring that practicality and functionality are at the centre of the design rationale the proposals put forward have been subject to a Master Plan design vision undertaken by YRM architects. The design vision ensures that the visual appearance of the buildings is influenced as far as possible by good architectural design. This Vision has set an approach for the general appearance of the buildings on-site, and sets out requirements for landscape planting around the Development Site. For off-site associated development, a particular challenge has been integrating new development into the landscape. Sites located on greenfield land may mean that impacts on surrounding landscapes are typically more significant. EDF Energy has moved a number of sites during consultation onto brownfield land, to reduce impacts. In general, EDF Energy and their designers have undertaken extensive consultation with regard to landscape impacts and potential receptors, and have had a strong influence on the layout and siting of the offsite associated development. Based on the topography of the sites and their proximity to urban settings and road networks, impacts could be considered to be reduced compared to the original proposal. CABE has been consulted on these elements and the designs reflect this accordingly . Landscape proposals have been developed to screen new development from sensitive receptors. A landscape strategy has been developed which builds on the local landscape context to ensure impacts are minimised as far as possible, with long-term benefits attained. The approach to landscape mitigation varies depending on the final condition of the settlement, where possible, landscape mitigation will be designed to serve more than single function, by contributing to ecological connectivity, recreation and amenity, sustainable drainage and climate change adaptation. Guiding Question - Will it adversely affect local landscapes/townscapes of value? For many of the sites, especially In Bridgwater, the local townscape may be enhanced by the introduction of new development on otherwise unused sites. In general local planning policies for landscape relates strongly to the appearance of new development. The off-site accommodation campuses, which will be centrally located in Bridgwater, will adopt a high standard of design and appearance, and be complimented by landscape strategies. It is expected that in general in the long-term the proposals will have a negligible impact on the townscape; however, impacts during construction and removal/restoration (depending on final condition) will detract from townscape value, albeit for a limited time. Landscape screening measures will be substantial, such as at Cannington Bypass, and Junction 23 developments. When established, these measures will mitigate many local landscape/townscape impacts. This also provides additional ecological benefits. Guiding Question - Will it affect the levels of tranquillity in an area? Tranquillity is a measure of how peaceful an area is. This is negatively affected by both changes in a landscape and increases in noise; therefore impacts on tranquillity will be most significant during the construction phase of the project. The most significant issues relate to the Main Site, as this area has the largest land take and longest construction phase, as well as areas such as Combwich Wharf, which are particularly tranquil areas that will be affected, especially during construction, but in the case of Combwich Wharf, also in operation with the receipt of AILs delivered to the Wharf. There will be a significant adverse affect on tranquillity; however this will be temporary in duration.

Sustainability Statement | October 2011 197

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Guiding Question - Will it adversely affect the landscape character or distinctiveness? The HPC development site lies within the national Landscape Character Area 146: Vale of Taunton and Quantock Fringes: a broad sweep of pastoral lowland landscape which contrasts to the steep moorland-topped character of the Bredon and Quantock Hills to the west and the open character of the clay levels to the east. The existing Hinkley Point Complex is a dominant landscape feature. When considering the construction of a new power station, this is not anticipated to change the landscape character or distinctiveness of the area when considered against national landscape classification. Notwithstanding this, visual impacts from power lines will change the appearance certain landscape character areas, however, these will be mitigated as far as possible. Of all off-site associated developments, potentially of greatest significance are the Cannington Bypass and Combwich Wharf developments, which are both proposed on greenfield land. This will adversely affect landscape character and landform. The initial proposals for Junction 24 and Williton Park and Ride sites have been altered to locate them on brownfield land; replacing the Somerfield Site and a lorry park respectively. Impact on landscape character and landform is therefore considered negligible in the long-term. The development has been taken forward in consultation with the Sedgemoor District Council, and is in accordance with the Bridgwater Vision. Guiding Question - Will it result in increased levels of light pollution? Light pollution has been carefully evaluated for the proposals, and a lighting strategy for the main site and offsite associated development has been developed by the designers, with input landscape consultants, security consultants and ecologists. Due to security reasons, many of the sites will require lighting throughout the night. Where possible this will be limited to essential and security lighting. There are a number of design standards which exist to limit light pollution by restricting sky glow and light lost to the sky. These will be followed wherever practical and possible. Issues of position lighting, the types of lighting proposed and the required Lux levels have been evaluated to ensure a lighting strategy can deliver objectives for security, safety whilst taking into account disturbance to people and ecology. Energy efficiency has also been considered. A white light scheme has been proposed at Combwich Wharf to reduce light pollution at night, and associated ecological effects. Summary The landscape strategy for the proposed development will aim to meet all the associated landscape designation policy objectives. S M L There will a number of minor and some major adverse affects from the new power station on sensitive receptors. The construction of the power station and off-site associated development will have adverse impacts on local landscape character and tranquillity, and therefore an adverse impact is expected during construction, however the objective is expected to be delivered over the  0  medium-term. The IPC are guided towards giving greater weight towards impacts on national and international designated landscapes, which is expected would be been met

198 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

4.12 Soils, Geology and Land Use

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Avoid Damage to Geological Resources Planning Policy Statement 9 (PPS9) Draft Revised RSS for the South West Somerset District Local Plan Biodiversity and Geological West Incorporating the Secretary of (2006) (‘saved’ policies) Conservation (2004). State’s Proposed Changes for Public Policy NC/3: Sites of Local Nature The Governments objectives for PPS 9 Consultation (July 2008). Policy Conservation of Geological Importance. ENV1 Protecting and Enhancing the include objectives to conserve, Planning permission will not be granted for Region’s Natural and Historic enhance and restore the diversity of development which has a significant Environment England’s wildlife and geology by: adverse effect on local nature The quality, character, diversity and • Sustaining, and where conservation/geological interests or local distinctiveness of the natural and possible improving, the integrity of landscape features*, unless the historic environment in the South West quality and extent of natural habitat importance of the development outweighs will be protected and enhanced, and and geological and the value of the substantive interests developments which support their geomorphological sites and the present. Where development is permitted positive management will be natural physical processes on which would damage the nature encouraged. Where development and which they depend. conservation value of the site, such changes in land use are planned which damage will be kept to a minimum. Consultation Paper on a New would affect these assets, local West Somerset Core Strategy SA Planning Policy Statement: Planning authorities will first seek to avoid loss of Objectives. for a Natural and Healthy or damage to the assets, then mitigate Environment any unavoidable damage, and Reduce land contamination, and In its final form, it is intended that this compensate for loss or damage through safeguard soil and geological quality and PPS will replace PPS 9 (Biodiversity offsetting actions. Priority will be given quantity. and Geological Conservation). The to preserving and enhancing sites of Sedgemoor District Local Plan (2004) draft PPS contains policies to maintain international or national landscape, (‘saved’ policies) and enhance, restore or add to nature conservation, geological, historic, No relevant objectives/policies. biodiversity and geodiversity through or archaeological importance.

the planning system.

Sustainability Statement | October 2011 199

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Sedgemoor District Council Local Development Framework Core Strategy (Proposed Submission) (September 2010) Policy S3: Proposals will be supported where they contribute to meeting all of the relevant objectives contained within the policy such as minimising the impact on natural resources including soil protection. Appraisal Hinkley Point Strategic Sustainability Objective: To Avoid Damage to Geological Resources Guiding Question - Will it compromise the future extraction/use of geological/mineral reserves? Whilst not a geological reserve, wider impacts on geology have also been assessed within the Environmental Statement. The primary issue will be the construction of the sea wall will obscure exposed foreshore pavement. However other areas located around Hinkley Point also have similar, accessible geology. With this factor considered, the significance of the lost geology is reduced. Furthermore, the physical loss of geological material would occur from construction works, although it is understood that good examples of similar geology can be seen in the area. The project is not expected to impact upon further extraction of materials. Summary HPC and off-site associated development are generally not located in an area which may compromise mineral extraction or S M L sensitive geology that may be damaged. Based on the fact that there will be limited conflicts with this objective, the objective to avoid damage to geological resources will be met.  The management of other sites will generally involve limited and temporary construction work, and are not anticipated to impact 0 0 on geology whatsoever.

200 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Avoid the Use of Greenfield Land and Encourage the Reuse of Brownfield Sites PPS 7 Sustainable Development in Regional Planning Guidance for the Sedgemoor District Local Plan (2004) A number of policy objectives Rural Areas (2004) South West (RPG 10) (2001) Policy (‘saved’ policies) promote the use of brownfield land PPS 7 sets out the Government's SS20: Rural Land Policy STR4: Development Location with the objective to reduce urban planning policies for rural areas, Local authorities and other agencies, Strategy sprawl; this is implemented through the planning system at all levels of including country towns and villages in their plans, policies and proposals The overall policy on development policy. However the Governments and the wider, largely undeveloped should conserve the region’s best and distribution for the period 1991-2011 is to SSA for new nuclear power stations countryside up to the fringes of larger most versatile agricultural land and identify land and sites on the basis of the included a criterion recognising the urban areas. associated soils in accordance with following priorities: HSE siting policy. This requires The PPS aims to promote more the guidance in PPG7 (now • Firstly on brownfield land or sites which nuclear power stations to be located sustainable patterns of development: superseded by PPS 7); land of a poorer quality should be used in offer the opportunity for redevelopment away from urban centres. In • Focusing most development in, or preference to higher quality except or re-use, the development of which recognising this criterion, this may next to, existing towns and villages. where other sustainability criteria would contribute towards regeneration, however conflict with the objectives viability and vitality, and which are within for the protection of greenfield land. • Preventing urban sprawl. suggest otherwise. or close to existing or proposed public Draft Revised RSS for the South • Discouraging the development of transport corridors in this order: West Incorporating the Secretary of ‘greenfield’ land, and, where such State’s Proposed Changes for - Within Bridgwater, Burnham-on-Sea land must be used, ensuring it is not Public Consultation (July 2008) and Highbridge used wastefully. Development Policy H Re-using within Rural Centres and Villages. Land - In the countryside, re-using existing Local authorities will ensure that the buildings, or for development where full potential of previously used land is a countryside location is essential. taken into account in providing for new Secondly on greenfield sites, only if it is development, whilst recognising that demonstrated that sufficient brownfield sites previously developed land may not or re-use opportunities are unavailable. It always be in the most sustainable shall be in this order: locations that development may not • At Bridgwater. necessarily always be the most sustainable land use. For the region • At Burnham-on-Sea/Highbridge. as a whole the aim should be to • At Cheddar. achieve at least 50% of new housing development on previously developed Sedgemoor District Council Local land (including the conversion of Development Framework Core Strategy

Sustainability Statement | October 2011 201

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives existing buildings). (Proposed Submission) (September Somerset & Exmoor National Park 2010) Joint Structure Plan Review 1991- Policy S1: Spatial Strategy for 2011 (2000) (‘saved’ policies) Sedgemoor Policy 7: Agricultural Land To create the most sustainable form of “Subject to the overall aims of the growth for Sedgemoor, Bridgwater will be strategy, provision should not be made the focus for the District’s housing and for permanent development, excluding employment growth. It will accommodate forestry and agricultural, involving the the majority of new development within its best and most versatile agricultural urban area through the provision of a land (Grades 1, 2 and 3a) unless there strategic urban extension, brownfield sites are no alternative sites on lower and at other well related Greenfield quality agricultural land and there is on locations. overriding need for development in that location. Where land in Grades 1, 2 and 3a does need to be developed there is a choice between different grades, development should be diverted towards land of the lowest grade.” Appraisal Hinkley Point Strategic Sustainability Objective: To Avoid the Use of Greenfield Use and Encourage the Reuse of Brownfield Sites A central principle of the project has been to minimise land take wherever practically possible in order to promote the prudent use of land. This is consistent with the UK Government’s Sustainable Development Strategy (2005), and is implemented by a range of land use planning policies. This key sustainability objective is reflected in the design of the development, particularly off-site associated development. The design of the nuclear power station involves consideration of safety and security factors. The layout of the nuclear power station must ensure that operations can be conducted safely in the event of accidental or deliberate challenges and natural and contrived external hazards. The design and layout of the nuclear power station must also enable the ability to monitor and control access to the site and within the site, and to control access to nuclear materials. The amount of land required for the nuclear power station and the configuration of buildings are a product of these essential safety and security requirements and have influenced the masterplan of the site.

202 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Guiding Question - Guide Question: Will it result in the loss of agricultural land? The area of the Development Site is approximately 171ha; this comprises the full site preparation and construction site area. The permanent build site is notably smaller (67.5 hectares in area). Approximately 105ha of land will be restored as part of the landscape restoration strategy. The majority of the HPC development site is used as agricultural land. Half of the agricultural fields within the main site are being used for arable crop production. All of these fields are intensively managed with very limited or no field margins. The remaining 50% of the agricultural fields comprise improved or poor semi-natural grassland. These are used for grazing cattle. In terms of the quality of this land, the soils are classified as Agricultural Land Classification (ALC) Grade 3. Further surveys have determined that the majority of the soils within the site area are classified as ALC sub-Grade 3b, meaning they are of moderate quality. Approximately 73% of the land is classified as being Moderate Quality Agricultural Land with a further 14% being classified as Best and Most Versatile Land. 13% is classed as grade four; Poor Quality. Off-site development has also been assessed. Agricultural land is often impacted. EDF Energy has located a number of sites on brownfield land in Bridgwater and also at Junction 24 and Williton, therefore mitigating the impact on agricultural land. There will however be impacts at the Junction 23 facilities, the Cannington bypass and Cannington park and ride facility, and Combwich laydown facility. The proposals for the laydown facility at Combwich, as well as the facilities at Junction 23 and Cannington park and ride are assumed to be temporary and therefore may be returned to greenfield sites once reinstated. Guide Question: Will it result in the loss of greenfield land? In terms of land use for the HPC development site, a review of historical maps and plans has identified that the Built Development and Southern Construction Areas have been greenfield agricultural land since at least 1886. The proposals will therefore result in the loss of greenfield land. Impacts from off-site associated development are varied. Bridgwater sites will be located on brownfield plots, and therefore deliver the objectives. The proposals for development on a number of these sites will be temporary, and therefore may be returned to greenfield sites once reinstated. This will occur both on the HPC development site (construction area & Southern Construction Campus), and off-site associated development. An example of this is the Southern construction area, which will be required to deliver worker accommodation for up to 510 individuals. EDF Energy proposes to reinstate this land following its use. Guide Question: Will it adversely affect land under land management agreements? A comparatively large area of the HPC Development Site is managed under an Environmental Stewardship Scheme or Countryside Stewardship Arrangement. There is a total of approximately 54.9ha of land within Countryside Stewardship Agreements in the Build Development Area West (BDAW) part of the HPC site. Land in the Build Development Area East BDAE (approximately 13.8ha) is the subject of an entry level Environmental Stewardship Agreement and land within the SCPA (approximately 61.5ha) is the subject of an entry level Environmental Stewardship Agreement. Such schemes also exist for land at Cannington bypass; there is approximately 5-6ha in Countryside Stewardship and a further 5-6ha in entry level Entry Level Environmental Stewardship. Summary Whilst this is a conflict against policy, the Nuclear NPS identifies that existing locations of Power Stations, including Hinkley S M L Point, are acceptable locations to develop new generating stations. When considering principles of layout and opportunities to minimise land take, EDF Energy and its designers have ensured that the impacts on land have been minimised, however the amount of land required for the nuclear power station and the configuration of buildings are a product of essential safety and   0 security requirements and have influenced the masterplan of the site. As the development proposals unavoidably result in land take from greenfield sites, a negative relationship is identified during the short and medium term. When considering the eventual decommissioning over the longer term, much of the development site may be returned to greenfield land, as will a number of off-

Sustainability Statement | October 2011 203

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives site associated developments located on greenfield land. Therefore a positive relationship is considered with this objective over the longer term.

204 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Avoid the Contamination of Soils and Adverse Impacts on Soil Functions

PPS 7: Sustainable Development in Rural South West Climate Change Action Sedgemoor Local Plan (2004) Areas (2004) Plan: (‘saved’ policies) PPS 7 sets out policy for promoting Improve soil husbandry and land Objective: development in rural areas whilst conserving management in sensitive catchments To ensure that the new Plan plays its the character of the countryside and to improve rain infiltration and reduce part in ensuring that our countryside protecting the best and most versatile run-off. and natural environment is effectively agricultural land, defined as Grade 1, 2 and Regional Planning Guidance for managed, including its conservation, 3a of the Agricultural Land Classification the South West (RPG 10) (2001). protection and enhancement. This (ALC). Policy SS20: Rural Land broad objective can be translated into a Consultation Paper on a New Planning Somerset & Exmoor National Park number of supplementary objectives. Policy Statement: Planning for a Natural Joint Structure Plan Review 1991- These are: and Healthy Environment (March 2010) 2011 (2000) (‘saved’ policies) • To safeguard good quality Proposed Policy NE8.9 Policy 7: Agricultural Land agricultural land. “When considering applications involving Sedgemoor District Council Local significant areas of agricultural land, local Development Framework Core planning authorities should take account of Strategy (Proposed Submission) the presence of best and most versatile (September 2010) agricultural land (defined as land in grades 1, Policy S3: 2 and 3a of the ALC) alongside other sustainability considerations. Where Proposals will be supported where they significant development of agricultural land is contribute to meeting all of the relevant unavoidable, local planning authorities objectives contained within the policy should seek to develop areas of poorer such as minimising the impact on quality land (grades 3b, 4 and 5) in natural resources including soil preference to that of a higher quality, except protection. where this would be inconsistent with other sustainability considerations. Little weight should be given to the loss of agricultural land in grades 3b, 4 and 5, except in areas (such as uplands) where particular agricultural practices may

Sustainability Statement | October 2011 205

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives themselves contribute to the quality and character of the environment or the local economy.” Appraisal Hinkley Point Strategic Sustainability Objective: To Avoid the Contamination of Soils and Adverse Impacts on Soil Functions Guiding Question - Will it result in the compaction and erosion of soils? The construction phase of the development will involve the movement and storage of a significant volume of soil. EDF Energy proposes to manage all of the soil required for the construction of HPC on site, eliminating the requirement to transfer and dispose of soil offsite (except for the anticipated small quantity of contaminated material). This is primarily achieved through re-profiling of the site and reinstatement of soil profiles. Furthermore, the contractors will be required to follow a soil management plan, which will include adopting best practices for the handling and storage of soils. This is detailed within the Soil Management Plan, which has been developed for site preparation and development works. A similar management plan has also been developed for the off-site associated developments. Guiding Question - Will it lead to the removal or alteration of soil structure and function? The main construction works will generate a number of possible adverse effects on soil, largely linked to permanent and temporary land-take. This land-take for the main construction works will include changes to soils and land use over the lifetime of the facility. Impacts on soil will include topsoil stripping, which can have an adverse impact on soil structure. The significance of this depends on the soil type. In certain areas at the HPC development site for example, heavy clays are present which may lead to soil compaction, loss of structure and the creation of impermeable conditions. The following has been considered to reduce these impacts: • Correct methods for stripping, segregating and stockpiling soil material, following best practice procedures. • Correct and appropriate soil restoration methods post-construction Guiding Question - Will it lead to the contamination of soils which would affect biodiversity and human health? Assessments have also been undertaken to determine the potential for contamination at the HPC site. Desk based assessments have revealed that the Site has been subject to past uses that may present a low to moderate contamination risk. Firstly, there exists potential contamination from the construction of the existing Hinkley Point Power Station Complex, since the BDAE was used as a contractors fabrication, construction and accommodation areas as well as for disposal/storage of waste spoil and construction and demolition materials. This area will have been remediated during the Enabling Works prior to the HPC construction phase. The Enabling Works have been designed to remove any hotspots of know asbestos contamination and this and any other contamination or construction and demolition wastes discovered during the remediation activities will be removed offsite or re-used on site but only if deemed suitable for use under the agreed land contamination Code of Practice/Materials Management Plan for the site. Secondly, it is possible there could be contamination in the SCPA post construction phase if some of the above contaminated materials from the BDAE are stockpiled and deposited there. Again, this would only happen in agreement with the site’s contaminated land Code of Practice/under the Materials Management Plan, and with the agreement of the Environment Agency – so that certain contaminated materials could be re-used on site it they were deemed to be suitable for re-use in an appropriate location. In general the adoption of good design principles and careful operating practices during construction will limit the potential for contamination to soil.

206 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Summary During construction, a significant volume of soils will be stripped from the site. This is in direct conflict with the objective to avoid S M L the adverse impacts on soil function. Notwithstanding this, a range of proposals exist to protect soil as far as possible through specific management proposals. Over the medium and long-term, proposals for HPC may support this objective.

 0 0?

Sustainability Statement | October 2011 207

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

4.13 Water Quality and Resources

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Avoid Impacts on Surface Water Hydrology and Channel Geomorphology (including coastal geomorphology) Supplement to PPS 25: Development Regional Planning Guidance for the West Somerset District Local Plan Water is a significant sustainability and Coastal Change (2010) South West (RPG 10) (2001) (2006) (‘saved’ policies) issue, and it is apparent from all levels The objectives of the PPS 25 Policy RE 1: Water Resources and Policy CO/1 Proposed Coastal of policy that protection of water quality supplement are to ensure that our Water Quality Development and resources is a key objective. This is consistent between the Water coastal communities continue to prosper To achieve the long-term sustainable Development proposals in any part of the Framework Directive, regional river and adapt to coastal change. This use of water, water resources need to Coastal Zone, including those areas of basin management plans as well as means planning should: be used more efficiently. At the same existing developed coast, will only be considerations for the IPC’s decision time, water resources and water permitted where: • Ensure that policies and decisions in making. treatment infrastructure must be made coastal areas are based on an • The development and its associated available in the right location and at the With regard to coastal change, the understanding of coastal change activities are unlikely to have an right time to support development supplement to PPS 25 has the objective over time. adverse affect, either directly or planned for the period covered by the to ensure that the risk to development • indirectly on: Prevent new development from being regional guidance. The quality of inland which is, exceptionally, necessary in put at risk from coastal change by: and coastal water environments must - heritage features; coastal change areas because it requires a coastal location and provides • Avoiding inappropriate development be conserved and enhanced. Local - landscape character areas; substantial economic and social benefits in areas that are vulnerable to authorities, the Environment Agency, - nature conservation interests, to communities, is managed over its coastal change or any development water companies and other agencies including sub-tidal and marine planned lifetime. Furthermore, the IPC is that adds to the impacts of physical should seek to: habitats, and guided towards consideration of changes to the coast. • Plan their water infrastructure and - residential amenities. cumulative effects with other major • Directing development away from water treatment investment • schemes within the Severn Estuary. programmes in accordance with the The development is unlikely to have areas vulnerable to coastal change. an adverse affect on the character of regional spatial strategy. • Ensure that the risk to development the coast and maintains and where which is, exceptionally, necessary in • Aim to conserve water through possible, enhances, improves or coastal change areas because it demand management and efficient upgrades the environment particularly requires a coastal location and distribution. in derelict and/or despoiled coastal areas. provides substantial economic and • Protect groundwater resources. social benefits to communities, is • The development requires a coastal • Protect and enhance river and managed over its planned lifetime. location. coastal water quality.

208 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives • Ensure that plans are in place to In particular, development plans and West Somerset Core Strategy SA secure the long-term sustainability of other plans and programmes of bodies Objectives coastal areas. and agencies associated with future Maintain and continue to improve the development and water issues, will quality of ground/river/coastal water. need to: Sedgemoor Local Plan (2004) (‘saved’ • Take water related issues into policies) account from an early stage in the No relevant objectives or policies. process of identifying land for

development and re-development and should co-ordinate the timing of new development with the provision of sustainable water supplies, sewage treatment and discharge systems in accordance with advice in PPG12 (Development Plans). • Seek to avoid sites where water supply and/or drainage provision is likely to be unsustainable. • Encourage use of sites where past problems can be solved. • Promote the use of sustainable urban drainage solutions and the production of detailed supplementary planning guidance to facilitate their adoption.

Sustainability Statement | October 2011 209

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Draft Revised RSS for the South West Incorporating the Secretary of State’s Proposed Changes for Public Consultation (July 2008) RE6 Water Resources The region’s network of ground, surface and coastal waters and associated ecosystems will be protected and enhanced, taking account of the Environment Agency’s ‘Regional Water Resources Strategy’, catchment abstraction management strategies, groundwater vulnerability maps, groundwater source protection zone maps and river basin management plans. Surface and groundwater pollution risks must be minimised so that environmental quality standards are achieved and where possible exceeded. Appraisal Hinkley Point Strategic Sustainability Objective: To Avoid Impacts on Surface Water Hydrology and Channel Geomorphology (including coastal geomorphology) Guiding Question - Will it result in the increased sedimentation of watercourses? The movement of heavy plant, stripping and exposure of soil areas, levelling of ground, stockpiling and placement of fill materials, have the potential to generate sediment laden surface water run-off. The release of sediment will be managed, where possible by adopting working practices through an EMMP. This could include: • Adopting watercourse buffer zones and restricting access for plant movement. • The adoption of relevant Environment Agency Guidance. • Employing grit trap/oil interceptor designed and constructed to have a capacity suitable for the proposed facilities. Sediment transport and contaminant mobilisation from construction works.

210 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Guiding Question - Will hydrology and flow regimes be adversely affected by water abstraction? Abstraction will not occur at the site during operation, although dewatering will be required during construction to enable the safe construction of the nuclear island. During this process, it is not expected that it lead to a significant saline intrusion. During operation, whilst abstraction will not occur, measures will be put in place in the form of underground drainage galleries to ensure that rising groundwater does not affect foundations of the structures. Further information is provided within the Groundwater chapter of the Environmental Statement. Guiding Question - Will it result in demand for higher defence standards that will impact on coastal processes? Coastal processes within the Bridgwater bay and Bristol Channel have been widely studied over the past 40 years. A considerable amount is now known about coastal processes and coastal hydrodynamics and geomorphology. The construction components identified to have a potential impact are the construction of the new sea wall, construction drainage across the foreshore and the construction, operation and dismantling of the jetty. In operation, the presence of the sea wall, as well as the cooling water infrastructure have been identified. The impacts on coastal process from this new feature have been evaluated within the Environmental Assessment, which includes impacts from coastal scour. In general HPC is not predicted to have a discernable effect on coastal geomorphology of the inner Bristol Channel.

Guiding Question - Will it adversely affect channel geomorphology? As above, it is not anticipated that HPC will have a discernable effect on coastal geomorphology of the inner Bristol Channel.

Summary The development of HPC will require a significant area of land take and will introduce impermeable surfacing on the site. The S M L proposals for drainage include the discharge of this water into Bridgwater Bay after having been filtered and channelled through 0 0 0 the main cooling water outfall.

Sustainability Statement | October 2011 211

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts on Water Quality, including Coastal and Marine Water Quality, and Assist Achievement of Water Framework Directive Objectives The Water Framework Directive Regional Planning Guidance for the West Somerset Local Plan (2006) (2000/60/E) South West (RPG 10) (2001) (‘saved’ policies) The overall purpose of the Directive is Policy RE 1: Water Resources and No relevant objectives/policies. to establish a framework for the Water Quality West Somerset Core Strategy SA protection of surface fresh water, Draft Revised RSS for the South Objectives. estuaries, coastal water and West Incorporating the Secretary of Maintain and continue to improve the groundwater. The objectives of the State’s Proposed Changes for Public quality of ground/river/coastal water . directive is to enhance the status and Consultation (July 2008). RE6 Water Sedgemoor District Local Plan (2004) prevent further deterioration of aquatic Resources ecosystems and associated wetlands, (‘saved’ policies) Somerset & Exmoor National Park promote the sustainable use of water, No relevant objectives/policies. Joint Structure Plan Review 1991- reduce pollution of water (especially by 2011 (2000) (‘saved’ policies) ‘priority’ and ‘priority hazardous’ substances), and ensure progressive Safeguarding Water Resources reduction of groundwater pollution. Protection will be afforded to all surface, underground and marine water resources from development which could harm their quality or quantity. River Basin Management Plan: South West River Basin District (2009) By 2015, 22 per cent of surface waters (rivers, lakes, estuaries and coastal waters) in this river basin district will improve for at least one element. At least 61 per cent of assessed surface waters will be at good or better biological status by 2015.

212 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Appraisal Hinkley Point Strategic Sustainability Objective: To avoid Adverse Impacts on Water Quality, including Coastal and Marine Water Quality, and Assist Achievement of Water Framework Directive Objectives Guiding Question - Will it cause deterioration in surface water quality as a result of accidental pollution, for example spillages, leaks? Impacts from accidents and spillages have also been considered from construction and operation. The potential risk of accidents and incidents occurring and the avoidance and minimisation of their potential effects on water quality would be managed through the adoption of best practice procedures. For example, fuels will be stored within bunded areas, refuelling will be undertaken in designated areas; plant will be well maintained and regularly serviced. In addition, an incident management plan will be put in place to respond to spillage incidents swiftly and effectively. Pollution prevention/management equipment will be made available in order to minimise the severity of a potential spillage. Guiding Question - Will it cause deterioration in coastal and/or marine water quality as a result of accidental pollution, for example spillages, leaks? As above, the discharge of water into the marine environment will be subject to the relevant licensing and consents. Guiding Question - Will it increase the temperature of the water in water bodies? The outfall the cooling water infrastructure will cause temperature increases. Elevated temperature discharges have the potential to impact upon water quality status in a number of ways. Water temperature and dissolved oxygen concentration have a close relationship for example. Temperature changes also affect the solubility, and in turn the toxicity of water. The WFD sets thresholds for maximum temperature increases. Assessments conclude that the River Parrett and Bridgwater Bay water bodies will not show exceedances beyond the most stringent permitted uplift. Impacts on water quality have been considered from the construction and operation of HPC as well as off-site associated development. In general, impacts will be minimised as far as possible through design and through the adoption of mitigation, S M L however impacts will inevitably occur during construction in particular, meaning that this objective is not met during this period.

  0

Sustainability Statement | October 2011 213

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts on the Supply of Water Resources Consultation on a Planning Regional Planning Guidance for the West Somerset Local Plan (2004) (‘saved’ Policies to reduce water demand are Statement: Planning for a Low South West (RPG 10) (2001). policies) largely held within regional and local Carbon Future in a Changing Policy RE 1: Water Resources and Policy BD/9 policies and enforced through planning Climate (2010) policies for water efficiency and design Water Quality Development will only be permitted where it codes such as BREEAM. However this The draft PPS has been published Draft Revised RSS for the South West is demonstrated that the conservation of has been elevated to the national level for consultation which brings Incorporating the Secretary of State’s energy and water has been considered in in the new draft PPS for Climate together the Planning and Climate Proposed Changes for Public the design, layout, siting and drainage of the Change, which reinforces the Change supplement to PPS 1, with Consultation (July 2008) Policy RE6: proposal and that all practicable measures establishment of water efficiency PPS 22 on Renewable Energy. Water Resources to conserve water are included as part of the measures through encouraging local The draft PPS encourages local scheme. The region’s network of ground, surface authorities to set water use targets in authorities to set water use targets and coastal waters and associated West Somerset District Local new development, particularly in water for new development brought ecosystems will be protected and Development Framework Core Strategy stressed areas. forward, especially in areas with enhanced, taking account of the Options Paper (January 2010) significant vulnerability to impacts Environment Agency's ‘Regional Water No relevant objectives/policies. arising from changes in the Resources Strategy’, catchment West Somerset Core Strategy SA climate. abstraction management strategies, Objectives. groundwater vulnerability maps, groundwater source protection zone maps Improve efficiency of water use. and river basin management plans. Improve adaptation for unavoidable climate Surface and groundwater pollution risks change including consideration of the must be minimised so that environmental location of development. quality standards are achieved and where Sedgemoor District Local Plan (2004) possible exceeded. Local Planning (‘saved’ policies) Authorities, through their LDD’s, must Policy BE1: Sustainable and Quality ensure that rates of planned development Development do not exceed the capacity of existing Applicants for planning permission for all water supply and wastewater treatment development will be required to submit systems and justification as to how the

214 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives do not proceed ahead of essential proposal has considered a wide range of planned improvements to these systems. design criteria, including sustainable Somerset and Exmoor National Park development issues. The detailed design Joint Structure Plan Review 1991-2011 criteria are set out at Appendix 9.1 together (2000) (‘saved’ policies) with more specific design applications and are summarised under the three headings Policy 59: Safeguarding Water below: Resources • “Protection will be afforded to all surface, Natural resources. underground and marine water resources • Bio-diversity and carbon fixing. from development which could harm their • quality or quantity.” Water. • Land. Applicants will be required to demonstrate they have addressed these issues. The extent will depend on the scale and the complexity of the proposal. Sedgemoor District Council Local Development Framework Core Strategy (Proposed Submission) (September 2010) Policy D3 Sustainable Construction and Reducing Carbon Emissions in New Development Applications for all major development proposals will be required to provide a statement demonstrating how sustainable construction principles have been incorporated; this should address demolition, construction and long-term management. This will be expected to show how the proposal maximises its contribution towards minimisation of water consumption. Appraisal Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts on the Supply of Water Resources

Sustainability Statement | October 2011 215

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Guiding Question - Will it adversely affect water supply as a result of abstraction? Dewatering of the excavations for buildings is required to enable safe and efficient construction of foundations and the construction of any section of the building(s) below the baseline water table. Once the sub-water table buildings are in place and the site is operational the baseline groundwater regime will be altered. Guiding Question - Will it increase demand for water? It is expected that the proposals will increase demand for water within the region. HPC will require fresh water for the process of steam generation. Approximately 2,000 M3 per day will be required. EDF Energy has been considering ways to reduce this demand, by utilising desalination. However studies have concluded that this is not practical given the high proportion of suspended solids within the Bristol Channel. As well as conflicting with the requirements of the desalination technology, this would also create higher emissions as a number of vehicle movements would be required to remove the resulting waste material from site. As a consequence, HPC will require a new mains connection to be provided to the facility. Wessex Water, the water authority servicing HPC will make the necessary improvements, which will include pipe work upgrades and additional capacity in a reservoir, 2km to the south of HPC. It is expected that the water supplied to HPC by Wessex Water will originate from a catchment in the Quantocks, and will be gravity fed to the site, eliminating the need for pumping and reducing its carbon footprint. Furthermore, HPC will use relatively less water that HPB for power generation. The HPB site, combined with a small demand from HBA requires approximately 3,000 M 3 per day. HPC will have a reduced requirement on water, with a greater electrical output. HPC will therefore use water more efficiently than the existing sites. Once HPB undergoes decommissioning, the water requirements will be reduced, although an overlap in water use is expected. The construction of the development will also require a substantial quantity of fresh water. This will be used for concrete batching and other key construction activities, as well as that which is required to support the workforce. EDF Energy is exploring a range of measures to reduce water demand. This will include: • The design of facilities to use less water as standard during operation, by introducing best practice water efficiency measures. • Monitoring water use through construction and establishing KPI’s for water use in accordance with industry best practices, with the aim of reducing water use where possible. • The utilisation of rainwater harvesting for certain key buildings at the main site. • Large quantities of water will be required for cooling. It is proposed that cooling water will be abstracted and discharged from the Bristol Channel at an operational rate of between 116 and 134 m3/s depending on tidal state. In other locations an abstraction of this magnitude would often result in associated impacts upon water resources; however given the size of the Bristol Channel, an abstraction of this volume of water is considered to have no adverse impact. Furthermore, The site is not within a water stressed area as identified by the Environment Agency. The Site falls within the Bristol Water region (EA: Identifying Areas of Water Stress, January 2007) which has a relatively lower water stress in comparison to the rest of the UK. Summary It is anticipated that the supply of water for the construction and operation of the facility will lead to an increase in water use for S M L the site. This will be required during construction and operation. At present, the impacts on the supply of water resources will be negative, simply due to the increased requirement for water as a result of the proposals. However it should be noted that this will be partially offset by the fact that HPA is no longer in commission. Furthermore, EDF Energy will adopt a range of   0?

216 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives measures to reduce water demand in construction and where possible in operation. The impact on the surrounding network has not been taken into account at this stage of the assessment, and further information is required to fully assess the performance of the project against this objective. However given the initiatives that EDF Energy will adopt, it is considered that water consumption will be reduced as far as practically possible.

Sustainability Statement | October 2011 217

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts on Groundwater Quality, Distribution and Flow and Assist Achievement of Water Framework Objectives Regional Planning Guidance for the West Somerset Local Plan (2004) (‘saved’ South West (RPG 10) (2001). policies) Policy RE 1: Water Resources and Policy W/3: Groundwater Protection Water Quality Development which would adversely affect Somerset and Exmoor National Park Groundwater Source Protection Areas will not Joint Structure Plan Review 1991-2011 be permitted if the risk to the quality and (2000) (‘saved’ policies) quantity of water in water courses or aquifers Policy 59: Safeguarding Water could result in the inability of a groundwater Resources source to maintain public supply. River Basin Management Plan for South West Somerset District Local Development West (2009): Framework Core Strategy Options Paper (January 2010) The Environment Agency has set a number of objectives up to 2015 to No relevant objectives/policies. improve water quality. It considers a Sedgemoor District Local Plan (2006) number of environmental outcomes (‘saved’ policies) expected to be achieved as a result of No relevant objectives/policies. planned actions in the following areas: • Improve rural land management. • Achieve low impact transport build environments. • Securing sustainable amounts of water. • Restoring wildlife habitats. • Addressing localised pollution sources.

218 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Appraisal Hinkley Point Strategic Sustainability Objective: To Avoid Adverse Impacts on Groundwater Quality, Distribution and Flow and Assist Achievement of Water Framework Objectives Guiding Question - Will it cause deterioration in groundwater quality as a result of accidental pollution, for example spillages, leaks & will it cause deterioration in groundwater quality as a result of the disturbance of contaminated soil? The Environmental Statement identifies impacts on groundwater from construction and operation. The potential operations and activities during the construction phase which may lead to contamination can be summarised as: • The potential mobilisation of existing contaminants from construction activities e.g. groundwater dewatering, soil disturbance during earthworks. • The potential for contamination of the groundwater to occur as a result of accidental release from plant and storage tanks. Pathways fro contamination during operation primarily include: • Spills and leaks from chemical and fuel storage and refuelling areas, waste storage areas (hazardous and conventional) and during transport, delivery, unloading and loading of materials to and from the site. • Discharge and leakage from drainage systems. The Environmental Statement identifies those options for mitigating any impacts that are expected to occur. The majority of potential adverse impacts are negligible in magnitude. Where mitigation is proposed, this follows the preferred hierarchy of mitigation, which is prevention first, then minimisation and only as a last resort, compensation/remediation. Further details on the mitigation options available to protect groundwater are available within the Groundwater chapter of the Environmental Statement. Summary Impacts on groundwater have been considered within the Environmental Statement. In general impacts that are expected to occur S M L during construction, and mitigation will be adopted to reduce this. In general the proposals are in accord with the objectives.

0 0 0

Sustainability Statement | October 2011 219

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

4.14 Flood Risk

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: To Avoid Increased Flood Risk (including coastal flood risk) and Seeks to Reduce Risks where Possible National Policy Statement Regional Planning Guidance for the West Somerset District Local Plan (2006) for Nuclear Power South West (RPG 10) (2001) (‘saved’ policies) Generation (EN-6) Policy RE 2: Flood Risk Policy W/2 Surface water protection The Nuclear NPS states that Flooding causes risk to both property and Development which would adversely affect the nuclear power stations need life and protecting property and people in quantitative and quality aspects of surface, access to cooling water which areas of flood risk is expensive. Local underground or coastal waters will only be means that nuclear power authorities, the Environment Agency, other permitted where acceptable mitigating works are stations in the UK are most agencies and developers should seek to: undertaken as an integral part of that development likely to be developed on Policy W/5 Surface Water Run-off coastal or estuarine sites. • Protect land liable to river and coastal Without appropriate mitigation flooding from new development, by Development which would result in significant measures the potential effects directing development away from river additional surface water run-off and result in of climate change make these and coastal floodplains. contributing to an increase in the risk of flooding within the site and elsewhere, particularly in relation sites at greater risk of flooding • Promote, recognise and adopt the use of to areas liable to flooding will only be permitted than if they were located sustainable drainage systems for where appropriate mitigating measures are taken inland. surface water drainage. as a part of the development. PPS 25 – Development and • Adopt a sequential approach to the Flood Risk (2010) West Somerset District Local Development allocation and development of sites, Framework Core Strategy Options Paper PPS 25 sets out the having regard to their flood risk potential (January 2010) Government’s objectives for in accordance with advice in PPG25 The Options Paper identifies the types of policy that managing flood risk in the (Development and Flood Risk). planning process. The PPS could be included in the Core Strategy, including a Development plans should: identifies the use of the requirement that new developments incorporate sequential test, to ensure that • Identify inland and coastal areas at risk measures to mitigate against flood risk and manage new development makes full from flooding based on the Environment surface water runoff through appropriate use of consideration to the risk of Agency’s indicative Maps and, SUDS (sustainable drainage systems) (p.23). flooding. Where new supplemented where necessary by development is exceptionally historical and modelled flood data and necessary, in such areas, indications as to other areas which could policy aims to make it safe be at risk in future. without increasing flood risk elsewhere and where

220 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives possible, reducing flood risk overall.

• Provide criteria for redevelopment West Somerset District Core Strategy SA proposals in flood plains, in order to Objectives minimise their cumulative adverse Reduce risk of flooding including coastal flooding. impact and secure enhancement of the Sedgemoor District Local Plan Policy (2004) floodwater storage and ecological role of (‘saved’ policies) flood plains. No relevant objectives/policies. Bridgwater Bay to Bideford Bay Shoreline Management Plan 1998 Sedgemoor District Council Core Strategy SA Objectives In terms of coastal flooding and erosion, To address flood risk and ensure key infrastructure, consider and coordinate with those policies towns and villages are safeguarded (or relocated if and objectives of relevance within both the necessary). statutory planning framework and Non statutory management plans of importance Sedgemoor District Council Local Development to the coastal zone. Framework Core Strategy (Proposed Submission) (September 2010) Where feasible, provide sustainable coastal defence schemes to protect shoreline Policy S4: Mitigating the Causes of and development, human life, existing navigable Adapting to the Effects of Climate Change access and the economies of those Development should adapt to the effects of climate shorelines. change by, amongst other things: Draft Revised RSS for the South West “…minimising the risk of flooding and ensuring Incorporating the Secretary of State’s appropriate management of land within areas Proposed Changes for Public vulnerable to flooding…” Consultation (July 2008). Policy D1: Managing Flood Risk Policy F1: Flood Risk All development proposals in Flood Zones 2 and 3 Taking account of climate change and the as defined by the Environment Agency’s Flood Map increasing risk of coastal and river flooding, will only be permitted where the Sequential Test is the priority is to: passed as outlined in PPS25. • Defend existing properties and, where possible, locate new development in places with little or no risk of flooding. • Protect flood plains and land liable to tidal or coastal flooding from

Sustainability Statement | October 2011 221

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives development. • Follow a sequential approach to development in flood risk areas. • Use development to reduce the risk of flooding through location, layout and design. • Relocate existing development from areas of the coast at risk, which cannot be realistically defended. • Identify areas of opportunity for managed realignment to reduce the risk of flooding and create new wildlife areas. Somerset and Exmoor National Park Joint Structure Plan Review 1991-2011 (2000) (‘saved’ policies) Policy 15: Coastal Development “New coastal developments should minimise the risk of flooding, erosion and landslip.” Policy 60: Floodplain Protection “areas vulnerable to flooding should continue to be protected from development which would cause a net loss of flood storage area or interrupt the free flow of water or adversely affect their environmental or ecological value.”

222 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Policy 61: Development in Areas Liable to marine Flooding “provision should only be made for development in areas vulnerable to marine or tidal flooding where the development is needed in that location, no alternative location exists for the development and adequate measures exist or can be readily provided to protect the development”. Appraisal Hinkley Point Strategic Sustainability Objective: To Avoid Increased Flood Risk (including coastal flood risk) and Seeks to Reduce Risks where Possible Guiding Question - Will it result in demand for higher defence standards that will impact on coastal processes? The development proposals brought forward have been subject to detailed Flood Risk Assessment, and the proposals reflect the findings of these assessments and the requirements of PPS25: Development and Flood Risk (2010). The development Site will also need to meet standards imposed by the Nuclear NPS, which requires that new sites are able to withstand the upper projections of the UK Climate Change Impacts Programme (UKCIP 2009), including Tsunami and Storm Surge events. The existing Hinkley Point Power Station complex is protected from coastal flooding by the height of the land platform, which in turn, is protected by defences along the seaward frontage. The risk of flooding from climate change has the potential to threaten the development. To ensure that this does not occur, EDF Energy is proposing to raise the land platform of HPC to 14m AOD, and to construct a new sea wall to protect the land platform from erosion. The land platform has been specified to tolerate the upper projections identified within the UK CIP 2009 for sea level rise. The facility will be designed to be resilient to the effects of climate change. With climate change, erosion potential will increase through increased frequency and severity of storms, and rising sea levels. The sea wall therefore provides a mitigation measure which will maintain the current coastline, in accordance with coastal defence measures for the Shoreline Management Plan (SMP) objectives to protect the local sediment cell (Bideford Bay to Bridgewater Bay). Guiding Question - Will it incorporate SUDS?* Many of the developments will introduce new areas of impermeable surfacing to greenfield sites. At the HPC development site, to ensure that surface water runoff rates are compliant to EA requirements, it is proposed HPC will drain directly into the sea. The attenuation on-site would regulate flows into the downstream system such that the frequency/occurrence of ‘low flow’ events in the Wick Moor SSSI would probably be reduced, thus providing betterment. Three separate drainage systems will be implemented during the construction and operation of HPC development site. Initial (site preparation works) construction drainage system – temporary. Construction phase drainage system – to ensure surface water is treated for quality and attenuated where required on-site, organised into two catchments, to enable discharge at greenfield rates to Holford Stream. There will be an interface between the construction phase drainage system and operational system – a gradual transition. Operational phase drainage system – for the nuclear island and spine road, water will be channelled to the cooling water outfall. The most significant undertaking will be at Holford Stream which will redirected into a culvert of approximately 690m, allowing the infilling of the valley to provide additional

Sustainability Statement | October 2011 223

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives area for the construction site. This will allow the existing river to continue to flow, and will be a permanent feature. Other associated development will adopt SUD’s strategies where appropriate and technically feasible. This includes surface water detention ponds/balancing ponds for the park and ride facilities and facilities at junction 23 and Cannington bypass. These will ensure that surface water is attenuated to Greenfield run-off rates, and also provide amenity and ecological benefits. Further information is available within the Design and Access Statements of each site. Guiding Question – Does it account for climate change?* The main site development will allow for climate change in the modelling up to 2100, based on current estimates within PPS 25. Climate change allowances 2100 – 2140 have been calculated and considered, however are not incorporated. The credible maximum scenario projections for climate change and their likely implications for coastlines have been assessed and incorporated in the design process of the main site. These considerations particularly concern sea level rise, offshore wind speed, extreme wave height, peak rainfall intensity, and peak river flow. The likely extent of these has been assessed using flood risk modelling, in order to determine the appropriateness of development, in compliance with the Flood and Water Management Act 2010 (further details within the Main Site Flood Risk Assessment). Summary The proposals for the HPC project will meet relevant standards for flood risk imposed by PPS 25 and the Nuclear NPS. Measures S M L will be taken during construction and operation of facilities to reduce flood risk.

Furthermore, given that the proposals will assist in minimising greenhouse gases and therefore have a direct benefit on mitigating 0
0 Climate Change, which is considered to promote more extreme flood events, the proposals may be regarded to indirectly assist in moderating flood risk on a larger scale through reducing a major driver of climate change, although this is not directly measurable.

224 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

4.15 Materials and Waste

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Hinkley Point Strategic Sustainability Objective: Sustainable Use of Materials (New Objective) Planning Policy Statement 10 Draft Revised RSS for the South West West Somerset District Local Plan (2006) (PPS 10) Planning for Sustainable Incorporating the Secretary of State’s (‘saved’ policies) Waste Management (2011). Proposed Changes for Public Policy BD/8 – Reuse of materials Consultation (July 2008) Policy RE10: PPS 10 sets out the guidance for Development proposals will only be permitted Supply of Aggregates and Other all those involved in making where maximum possible use within the Minerals Mineral Planning Authorities decisions about the management development site can be made of building should seek to make provision for the of waste and relies on the waste materials, building waste and spare soil supply of aggregates and other minerals hierarchy principle to bring waste generated by site preparation. management in line with the to meet the South West’s contribution to West Somerset District Local Development objectives of sustainable national requirements. Mineral Planning Framework Core Strategy Options Paper development. Authorities and Local Planning Authorities will identify and collaborate in (January 2010) safeguarding mineral resources of No relevant objectives/policies. economic importance from sterilisation by Sedgemoor District Local Plan Policy other forms of development. (2004) (‘saved’ policies) In order to promote the delivery and bulk Policy BE1: Sustainable and Quality transport of minerals by rail and/or water, Development existing railheads, wharfage and other Applicants for planning permission for all handling facilities, will be safeguarded development will be required to submit and opportunities for new ones should be identified, where appropriate. justification as to how the proposal has considered a wide range of design criteria, Policy RE12: Recycled and Secondary including sustainable development issues. The Aggregates detailed design criteria are set out at Appendix Provision will be made for 121 Mt of 9.1 together with more specific design secondary and recycled aggregates to be applications and are summarised under the utilised over the plan period to 2016. three headings below:…

LDD’s will identify new sites and • Development structure. safeguard existing sites, to secure an • appropriate provision of Concept. minerals/aggregates recycling plants in • Open space network. appropriate locations, in accordance with

Sustainability Statement | October 2011 225

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives Policy W2. • Built environment. South West Sustainability Checklist Applicants will be required to demonstrate they To promote the more sustainable use of have addressed these issues. The extent will resources related to both the construction depend on the scale and the complexity of the and the operation of new developments. proposal. Policy BE8: Local Materials The Council will seek to ensure that indigenous construction materials are employed wherever possible and appropriate, particularly where this is a prominent feature of a locality. Sedgemoor District Council Local Development Framework Core Strategy (Proposed Submission) (September 2010) Policy D3 Sustainable Construction Applications for all major development proposals will be required to provide a statement demonstrating how sustainable construction principles have been incorporated; this should address demolition, construction and long-term management. This will be expected to show how the proposal maximises its contribution towards the following objectives:

• Sustainable sourcing of materials and their efficient and appropriate use, including their durability. Appraisal Hinkley Point Sustainability Objective: Sustainable Use of Materials (New Objective) EDF Energy has set about considering a number of sustainability initiatives surrounding materials. The use of materials for the project is significant. Whilst EDF Energy has the intention to maximise the use of sustainable materials, the ability to achieve this is often limited. As an example, certain elements of the HPC site, invariably those that constitute the Nuclear Island, are required to be constructed from a very specific palette of materials, which have been fixed through the stringent safety

226 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance & Objectives requirements associated with the Generic Design Assessment (GDA) process. EDF Energy has no flexibility in modifying these elements to take account of sustainability standards. Even for buildings and structures which fall outside of the GDA, this may impact the types of materials proposed. By way of example, the application of different grades of aggregate for the construction of the power station is limited due to the risk of cross-contamination in the concrete batching plant. This limits the potential to utilise recycled aggregates in certain on-site ancillary buildings. Notwithstanding, EDF Energy intends to incorporate a significant volume of Pulverised Fuel Ash (PFA), a secondary aggregate derived from coal fired power stations as a constituent element of its concrete mix. Furthermore, where flexibility does exist, EDF Energy is committed to sustainable procurement: key examples include: • EDF Energy has adopted a sustainable materials policy, whereby if flexibility exists, contractors will be encouraged to make use of sustainable materials. Major suppliers (Tier 1), will be required to submit to EDF Energy a strategy on show they are maximising the potential for sustainable materials. • As part of the above, EDF Energy expect that 100% of the Tier 1 suppliers will hold an Environmental Management System and at least 90% of timber required for the project will be sourced in accordance with FSC requirements. • Require that contractors take all opportunities to explore the use of standardised, prefabricated and modular buildings and construction elements where appropriate. • Such principles will also be applied to associated development. During the design development, the design team has been briefed to incorporate considerations for sustainable materials and sustainable construction processes. Reference has been made to the Green Guide to Specification, the recovery and reuse of aggregates on sites and maximise us of modular and standardised construction. Summary EDF Energy has considered a number of options for enhancing the sustainability of materials. This has been considered for both S M L the main site and associated development. Commitments in this area will be further developed with appointed contractors, which will include a response to EDF Energy’s sustainable materials policy. The proposals demonstrate a sustainable approach to materials has been taken and will continue to be taken for the project.
0 0

Sustainability Statement | October 2011 227

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance Hinkley Point Strategic Sustainability Objective: To Minimise Waste and Apply Principles of the Waste Hierarchy Waste Strategy for England Regional Planning Guidance for the West Somerset Core Strategy SA (2007) South West (RPG 10) (2001) Objectives The Waste Strategy for England Policy RE5: Management and To reduce waste generation and disposal, sets out the Government’s Transportation of Waste increase recycling and achieve the commitments to implement the In order to achieve sustainable waste sustainable management of waste. waste hierarchy. The main management (the Best Practicable West Somerset District Local elements for the strategy is to: Environmental Options) in the region, Development Framework Core Strategy • Incentivise efforts to reduce, waste planning, disposal and collection Options Paper (January 2010) reuse, recycle then recover authorities, the Environment Agency and No relevant objectives/policies. waste management and water companies energy from waste. Sedgemoor District Local Plan Policy should cooperate to meet a series of • (2004) Reform regulation to drive the objectives. reduction of waste and No relevant objectives/policies. Draft Revised RSS for the South West diversion from Landfill. Incorporating the Secretary of State’s Sedgemoor District Council Local PPS 10 (PPS10): Planning Proposed Changes for Public Development Framework Core Strategy for Sustainable Waste Consultation (July 2008) (Proposed Submission) (September Management (2005) 2010) Policy W4 Controlling, PPS10 forms part of the national Re-using and Recycling Waste Policy D3 Sustainable Construction waste management plan for the in Development Applications for all major development UK. The main aim of the policies is All proposals for larger-scale proposals will be required to provide a to protect human health and the development should include as part of the statement demonstrating how sustainable environment by producing less planning application a report comprising construction principles have been waste and by using it as a an audit of waste materials on site and incorporated; this should address resource wherever possible. proposals for how waste will be managed demolition, construction and long-term PPS10 sets out the key planning over the lifetime of the development. management. This will be expected to show objectives for waste planning how the proposal maximises its contribution Somerset and Exmoor National Park authorities. towards the following objectives: Joint Structure Plan Review 1991-2011 (2000) • Minimising waste and maximising No relevant objectives/policies. recycling.

228 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance The South West Regional Waste Strategy 2004 – 2020 (SWRA) By 2020, 45% of the waste arising in the region is recycled and reused and less than 20% produced in the region is sent to landfill. Appraisal Hinkley Point Sustainability Objective: To Minimise Waste and Apply Principles of the Waste Hierarchy (New Objective) EDF Energy has produced a Waste Management Implementation Strategy to ensure that waste is effectively managed throughout design, construction and operation as sustainably as possible. Proposals for waste management follow the Government’s waste strategy for England 2007, and ensure that a hierarchical approach to waste is adopted. Further information is also provided within the waste section of the Environmental Statement. Various proposals have been developed, which have been subject to consultation with Somerset County Council the Environment Agency and Somerset Waste Partnership. EDF Energy has been exploring opportunities to divert over 90% of engineering, construction and demolition waste arising from the project from landfill. In order to achieve this target, opportunities have been explored to segregate waste on site, reuse materials directly site, including spoil and any demolition crush. For materials which are not able to be directly re-used, EDF Energy aims to utilise local materials recycling facilities (MRFs) and the local market to ensure that residual waste is diverted from landfill. The Waste Management Implementation Strategy includes an analysis on local and regional waste management facilities, and identifies opportunities for disposal based on the proximity principle and Best Available Technology (BAT). Key proposals includes: All soils will be managed in accordance with a Materials Management Plan, which will conform to CL:AIRE Code of Practice: The definition of Waste: Development Industry Code of Practice. Buildings will be subject to pre-demolition audits to identify re-usable and recyclable materials to optimise their recovery during the demolition process. Demolition materials will be subject to WRAP quality protocol to demonstrate that they are fit for purpose before they are reused. EDF Energy is exploring the opportunity for maximum use of standardisation, prefabrication and modularisation (SPaM) techniques in construction. All construction projects will prepare and implement a Site Waste Management Plan (SWMP). The design of accommodation campuses will ensure that waste is effectively segregated for recycling. A significant volume of waste will be generated during the construction process, particularly during the restoration of associated development sites. EDF Energy supports the concept of a re-use strategy, whereby if opportunities exist; EDF will look to directly re-use associated development, or components of this in preference to less sustainable recycling or disposal. This will manifest for example, in the reuse of temporary accommodation units in Bridgwater, which will be adopted if possible and if Market conditions are favourable. This will be assessed at the time of decommissioning.

Sustainability Statement | October 2011 229

NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED

Policy Drivers Observations/Conflicts between Policies National Policy/Guidance Regional Policy/Guidance Local Planning Policy/Guidance Summary Opportunities for sustainable waste management will be developed as the project progresses with contractor teams. At this S M L stage, it is considered that the objective to minimise waste and apply principles of the Waste Hierarchy has been delivered by the project during construction, and will continue to be delivered during operation. Notwithstanding a significant volume of waste will be generated during the construction phase and restoration phases of off-site associated development, and whilst

? the very large majority will be treated in accordance with the waste hierarchy, this will present a sustainability impact.

230 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED

References

1 BERR. Meeting the Energy Challenge - A White Paper on Nuclear Power. HMSO, 2008.

2 DECC. The Low Carbon Transition Plan: National Strategy for Climate Change and Energy. HMSO, 2009.

3 DECC. National Policy Statement for Nuclear Power Generation (EN-6). HMSO, 2011. 4 Planning Act. HMSO, 2008.

5 DECC. Appraisal of Sustainability of the revised draft Nuclear National Policy Statement. HMSO, 2010. 6 DECC. Appraisal of Sustainability Site Report for Hinkley Point. HMSO, October 2010. 7 Justification of Practices Involving Ionising Radiation Regulations (SI 2004/1769). HMSO, 2004. 8 Justification Decision (Generation of Electricity by the EPR Nuclear Reactor) Regulations (SI 2010/2844). HMSO, 2010. 9 DECC. Digest of United Kingdom Energy Statistics (DUKES). HMSO, 2011. 10 Climate Change Act. HMSO, 2008. 11 Committee on Climate Change. Renewable Energy Review. HMSO, 2011. 12 DECC. Overarching National Policy Statement for Energy (EN-1). HMSO, 2010. 13 European Commission. Large Combustion Plant Directive 2001/80/EC. Official Journal of the European Communities, 2001. 14 EDF Energy. EDF Energy Company Wide Sustainability Policy. 2011 15 Defra. Securing the Future: The UK Government Sustainable Development Strategy. HMSO, 2005. 16 Defra. Managing Radioactive Waste Safely: A Framework for Implementing Geological Disposal. HMSO, 2008. 17 Committee on Climate Change. The Fourth Carbon Budget: Reducing Emissions Through the 2020s. HMSO, 2010. 18 Office for Nuclear Regulation. Japanese Earthquake and Tsunami: Implications For The UK Nuclear Industry. Interim report. 2011. 19 CLG. Draft National Planning Policy Framework: Consultation. HMSO, 2011. 20 ODPM. Planning Policy Statement 1 (PPS1): Delivering Sustainable Development. HMSO, 2005. 21 CLG. Planning Policy Statement: Planning and Climate Change - Supplement to Planning Policy Statement 1. HMSO, 2007. 22 CLG. Consultation on a Planning Policy Statement: Planning for a Low Carbon Future in a Changing Climate. HMSO, 2010. 23 CLG. Planning Policy Statement 4: Planning for Sustainable Economic Growth. HMSO, 2009. 24 CLG. Planning Policy Statement 5: Planning for the Historic Environment. HMSO, 2010. 25 CLG. Planning Policy Statement 7: Sustainable Development in Rural Areas. HMSO, 2004

Sustainability Statement | October 2011 231

NOT PROTECTIVELY MARKED

26 CLG. Planning Policy Statement 9: Biodiversity and Geological Conservation. HMSO, 2005 27 CLG. Draft Planning Policy Statement: Planning for a Natural and Healthy Environment. HMSO, 2010. 28 CLG. Planning Policy Statement 10: Planning for Sustainable Waste Management. HMSO, 2011. 29 CLG. Planning Policy Guidance 13: Transport. HMSO, 2011. 30 CLG. Planning Policy Statement 17: Planning for Open Space, Sport and Recreation. HMSO, 2002 31 CLG. Planning Policy Statement 22: Renewable Energy. HMSO, 2004 32 ODPM. Planning Policy Statement 23: Planning and Pollution Control. HMSO, 2004 33 CLG. Planning Policy Statement 25: Development and Flood Risk (Version 2). HMSO, 2010. 34 CLG. Planning Policy Statement 25 Supplement: Development and Coastal Change. HMSO, 2010. 35 Government Office for the South West. Regional Planning Guidance for the South West (RPG 10). HMSO, 2001. 36 Government Office for the South West. The Draft Revised Regional Spatial Strategy for the South West Incorporating the Secretary of States Proposed Changes 2008 - 2026. HMSO, 2008. 37 South West Regional Assembly. Somerset and Exmoor National Park Joint Structure Plan Review 1991-2001 (2000). 38 South West Regional Development Agency. The Regional Economic Strategy for The South West 2006 – 2015, 2006. 39 South West Regional Biodiversity Partnership. South West Biodiversity Implementation Plan. 2004. 40 South West Councils. Climate Change Action Plan for the South West (2008-2010), 2008. 41 Halcrow Group Limited. North Devon and Somerset Coastal Advisory Group (NDASCAG). Shoreline Management Plan Review (SMP2) Hartland Point to Anchor Head, 2011. 42 Defra/Environment Agency. Water for Life and Livelihoods - River Basin Management Plan South West River Basin District. Bristol: EA, December 2009. 43 Future Foundations. South West Sustainability Checklist. 2006. (Online) Available at: http://www.checklistsouthwest.co.uk / 44 Regional South West Assembly. The Regional Waste Strategy for the South West: From Rubbish to Resource (2004-2020). 2004. 45 South West Councils. The Way Ahead: Delivering Sustainable Communities in the South West, 2005. 46 SDC. Sedgemoor Economic Masterplan (2008-2016). 2008. 47 Somerset Strategic Partnership. Somerset Local Area Agreement 2008-2011 (2010). 48 SCC. Somerset Future Transport Plan 2011-2026. 2006. 49 Somerset Strategic Partnership. The Sustainable Community Strategy for Somerset 2008-2026 (2009). 50 Severn Estuary Partnership. Strategy for the Severn Estuary. Cardiff: Severn Estuary Partnership, Department of Earth Science Cardiff University, 2001. 51 Quantock Hills AONB Joint Advisory Committee. Quantock Hills AONB Management Plan 2009-214. Bridgwater, 2009. (Online) Available at:

232 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED

http://www.thequantockhills.co.uk/resources/Management_Plan_2009_1.pdf (Accessed 21 January 2011). 52 Environment Agency. South West River Basin Management Plan. 2009. 53 Environment Agency. Managing Flood Risk on the Severn Estuary: Consultation, Bristol: Environment Agency, 2011. 54 WSC. West Somerset Local Plan (with relevant policies ‘saved’ from 17 April 2009), 2006. 55 WSC. West Somerset District Local Development Framework Core Strategy Options Paper, 2010. 56 SDC. Sedgemoor District Local Plan 1991-2011 (Policies ‘saved’ from 27 September 2007). 2004. 57 SDC. Local Development Framework Core Strategy (Proposed Submission) 2006-26. 2010. 58 SDC and WSC. Consultation Draft Hinkley Point C Project Joint Supplementary Planning Document (SPD). 59 Bridgwater Challenge Partnership. Bridgwater Vision – Delivering a Strategic Framework. 2009. 60 Gillespies. North East Bridgwater Design Principles Document. 2009. 61 SDC. Sustainable Community Strategy for Sedgemoor 2009-2026: Sowing the seeds for a better future. 2009. 62 EDF Energy. Our Sustainability Commitments. 2009. (Online) Available at: http://www.edfenergy.com/sustainability/our-commitments/our-sustainability- commitments / 63 Conservation of Habitats and Species Regulations (SI 2010/490). HMSO, 2010. 64 Protection of Badgers Act. HMSO, 1992 65 Stern, N. Stern Review Report on the Economics of Climate Change. HMSO, 2006 66 DECC. UK Climate Change Sustainable Development Indicator: 2009 Greenhouse Gas Emissions, Final Figures. HMSO, 2009. 67 Parliamentary Office of Science and Technology. POST Note 383, Carbon Footprint of Electricity Generation. 2011 68 HM Government. Climate Resilient Infrastructure: Preparing for a Changing Climate. HMSO, 2011. 69 Defra. Adapting to Climate Change: helping key sectors to adapt to climate change: Statutory Guidance to Reporting Authorities. HMSO, 2009. 70 EDF Energy. Report on Adaptation under the Climate Change Act. 2008. 71 Wilby, R. et al. Keeping nuclear and other sea sites safe from climate change. Proceedings of ICE; Civil Engineering 164, Paper 1100005, August 2011. 72 Wessex Water. Wessex Water’s Report To Defra Under The Climate Change Adaptation Reporting Duty. 2011 73 Environment Agency. Areas of Water Stress: Final Classification. Bristol: Environment Agency 74 National Grid. National Electricity Transmission System - Seven Year Statement (May 2011).

Sustainability Statement | October 2011 233

NOT PROTECTIVELY MARKED

Glossary

Location Proposed Development AA Appropriate Assessment AoS Appraisal of Sustainability AIL Abnormal Indivisible Load ALC Agricultural Land Classification AOD Above Ordnance Datum AONB Area of Outstanding Natural Beauty AQMA Air Quality Management Area ASHP Air Source Heat Pumps BAP Biodiversity Action Plan BAT Best Available Techniques/Best Available Technology BRE Building Research Establishment BREEAM Building Research Establishment Environmental Assessment Method BRI-A Bridgwater A Accommodation Site BRI-C Bridgwater C Accommodation Site BPEO Best Practical Environmental Option CCC Committee on Climate Change CCS Carbon Capture and Storage CCS Considerate Constructors Scheme CEMP Construction Environmental Management Plan CEEQUAL Civil Engineering Environmental Quality Award CEGB Central Electricity Generating Board CESP Community Energy Saving Programme CHP Combined Heat and Power CIBSE Chartered Institution of Building Services Engineers CFMP Catchment Flood Management Plan CL: AIRE Contaminated Land: Applications in Rural Environments COSHH Control of Substances Hazardous to Health CREP Corporate Responsibility and Environmental Panel CWS County Wildlife Site DCO Development Consent Order DECC Department of Energy and Climate Change EA Environment Agency ECoW Ecological Clerk of Works EDF Électricité de France EIA Environmental Impact Assessment EMMP Environmental Management and Monitoring Plan

234 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED

Location Proposed Development EMS Environmental Management System EPD Environment Product Declaration EPR Pressurised Water Reactor EU ETS European Union Emissions Trading Scheme ES Environmental Statement (reporting outcome of EIA) FDP Funded Decommissioning Programme FRA Flood Risk Assessment FSC Forestry Stewardship Council GDA Generic Design Assessment GWP Global Warming Potential Ha Hectares HGV Heavy Goods Vehicle HIA Health Impact Assessment HIMP Health Improvement and Modernisation Plan HPA Health Protection Agency HPA Hinkley Point A HPB Hinkley Point B HPC Hinkley Point C HRA Habitat Regulations Assessment HSE Health and Safety Executive ICRP International Commission on Radiological Protection IPC Infrastructure Planning Commission Km Kilometres KPI Key Performance Indicator kWh Kilo-Watt Hour LA Local Authority LAA Local Area Agreement LBAP Local Biodiversity Action Plan LCA Life Cycle Assessment LCTP Low Carbon Transition Plan LDF Local Development Framework LGV Light Goods Vehicle LIR Local Impact Report LPA Local Planning Authority LTP Local Transport Plan LVIA Landscape and Visual Impact Assessment MW Megawatts

Sustainability Statement | October 2011 235

NOT PROTECTIVELY MARKED

Location Proposed Development Mt Million Tonnes NDA Nuclear Decommissioning Authority NGO Non-Governmental Organisation NNR National Nature Reserve NOx Nitrogen oxides (e.g. NO² Nitrogen Dioxide) NPS National Policy Statement NSIP Nationally Significant Infrastructure Project OCRA Outline Contingency Response Arrangement PFA Pulverised Fuel Ash PIC Public Information Centre PM10 Particulate matter of less than 10 microns average diameter PPC Planning and Pollution Control PPS Planning Policy Statement PPG Planning Policy Guidance/Pollution Prevention Guidance PQQ Pre Qualification Questionnaires PRoW Public Right of Way PWR Pressurised Water Reactor PUA Principal Urban Area Ramsar Site designated under the convention of Wetlands of International Importance (Ramsar Convention 1975) REACH Registration, Evaluation, Authorisation and Restriction of Chemical Substances RES Regional Economic Strategy Ro-Ro Roll-on Roll-off Facility RSS Regional Spatial Strategy SAC Special Area of Conservation SM Scheduled Monument SA/SEA Sustainability Appraisal incorporating Strategic Environmental Assessment SFRA Strategic Flood Risk Assessment SLG Sustainability Leadership Group SMP Shoreline Management Plan

SO 2 Sulphur Dioxide SOCC Statement of Community Consultation SPA Special Protection Area SPaM Standardisation, Prefabrication and Modularisation techniques SPZ Source Protection Zone SSA Strategic Siting Assessment SSSI Site of Special Scientific Interest SuDS Sustainable Drainage Systems

236 Sustainability Statement | October 2011

NOT PROTECTIVELY MARKED

Location Proposed Development SWMP Site Waste Management Plan SWRA South West Regional Assembly TA Transport Assessment UDP Unitary Development Plan UK CIP United Kingdom Climate Impacts Programme UK EPR Pressurised Water Reactor (UK EPR) VOC Volatile Organic Compound WFD Water Framework Directive WRAP Waste and Resources Action Programme WSC West Somerset Council

Sustainability Statement | October 2011 237

NOT PROTECTIVELY MARKED

ANNEX 1 – CO2 CALCULATIONS A1.1 Electricity supplied from the National Grid is derived from a range of sources, including fossil fuels, renewable energy and existing nuclear generation. Once operational, HPC will provide a source of low carbon electricity, which will help to displace more carbon intensive electricity from the National Grid. It is complex to ascertain exactly how much CO 2 will be displaced as a result of the HPC project throughout its operational life; this is because the mix of power generation supporting the grid varies from year to year. The figure of 10 million tonnes of CO 2 per annum as the amount displaced by HPC is based on a simple calculation, which takes account of the amount of electricity generated by HPC and the average carbon intensity of electricity currently provided across the power sector.

A1.2 The electricity generated by HPC per annum, net of consumption by plant on the site, is estimated to be approximately 25 TWh. This assumes that on average both reactor units will run at full capacity for 90% of the year, with the remaining 10% shut down for maintenance and refuelling outages including the periodic ‘statutory’ outage required as a condition of its nuclear site licence. The detailed calculation is that 3260 MWe (installed capacity) * 8760 (hours in a year) *0.90 (load factor) = 25.7 TWh. This is conservatively rounded down to 25 TWh. In practice, EPR reactors are expected to operate for 18 months between statutory outages; hence in a given year, HPC could potentially operate at 100% load factor. If this was the case, the electricity generated in that year would be closer to 28 TWh.

A1.3 The Government makes estimates of the current and future carbon intensity of electricity generation. Its future projections are based on many variables, including its success in implementing its energy policy and renewable energy strategy. More reliable however is the current mix of electricity supplied to the grid. Energy companies are obliged to report this in accordance with the Electricity (Fuel Mix Disclosure) Regulations 2005 (Ref A1.1). In turn, the Government collates this information and publishes it annually. Information for the most recent disclosure period (1st April 2010 to March 1st 2011) is available online (Ref 1.2). During this period the average carbon intensity of electricity generated from gas was 400 gCO 2/kWh, while the average carbon intensity for the actual mix of all sources of electricity, including coal, existing nuclear and renewable energy as well as gas, was 450 gCO 2/kWh.

A1.4 If it is assumed that HPC will displace gas generation only, the HPC project would offset at least 10 million tonnes CO 2 per annum (mt/y). The detailed calculation is (25 TWh * 400gCO 2/ kWh = 10 mt), with the contribution of less than 5gCO 2/ kWh from HPC negligible by comparison. If instead a scenario is assumed whereby HPC offsets the published average mix (450 gCO 2/kWh), then HPC would offset 11.25 mt/y. Finally, if it is assumed that HPC will operate continuously (100% load factor) for a given year, the maximum offset could be in excess of 12.6 mt/y.

edfenergy.com

EDF Energy plc. Registered in England and Wales. Registered No. 2366852. Registered Office: 40 Grosvenor Place, Victoria, London, SW1X 7E