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Kelsale Cum Carlton Parish Council's Detailed Response to Sizewell C Stage 3 Pre-Application Consultation

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Kelsale Cum Carlton Parish Council's Detailed Response to Sizewell C Stage 3 Pre-Application Consultation Kelsale cum Carlton Parish Council’s Detailed Response to Sizewell C Stage 3 Pre-Application Consultation “Had I the heavens’ embroidered cloths Enwrought with golden and silver light, The Blue and the dim and the dark cloths Of night and light and the half light, I would spread the cloths under your feet; But I being poor, have only my dreams; I have spread my dreams under your feet; Tread softly because you tread on my dreams” WB Yeats (1830-1894) Page 1 of 187 Version: Final Kelsale cum Carlton Parish Council’s Detailed Response to Sizewell C Stage 3 Pre-Application Consultation Introduction About Kelsale cum Carlton Kelsale cum Carlton [KcC] is one of the largest (by area) Parishes in the Suffolk Coastal area and comprises a combined Parish of two village entities (Kelsale and Carlton), three historic Greens (Curlew, North and East) and is bisected by the A12, with the bulk of residents living to the east of it. The Parish also has the northern tail of the historic A12 route, providing many Saxmundham residents and businesses direct access to and from the A12 at Dorley’s Corner, a small community directly alongside the A12. The KcC Parish comprises nearly 500 households, 32 listed buildings (Graded 1*, 2* & 2), a small light industrial estate, a number of places of worship, a listed Village Hall, a Social Club, Public House, several large farms, a number of smaller farms and agricultural businesses dependent on tourism, all located in a substantial agricultural land area surrounding the village centres. It is home to; the Fromus Nature Reserve (to the west of the A12), three roadside nature reserves (at Tiggins Lane, Fordley Road and Carlton Green - west of the A12), a private nature reserve (Rydall Mount, Tiggins Lane), several flora species of ‘national interest’, a wide range of domestic and migratory birds, a migratory Red Deer population and a multiplicity of Great Crested Newt colonies. KcC also has two County Wildlife Citations with a third sitting on its boundary. The Parish has a considerable historic inheritance including; several medieval moated areas, an Ancient Woodland, a richness of archaeological interest and of course the contentious view held by some that, East Green may have been; the site of, adjacent to or on the road toward Sitomagus, all of which have yet to be substantiated. More recently, in 2018 Kelsale Village became the latest Conservation Area to be designated in the Suffolk Coastal area, in recognition of both its built environment with buildings from ‘Nationally Important’ architects and its special setting in an open and unspoilt agricultural landscape. KcC also benefits from a non-designated heritage asset in the form of the historic Carlton Parkland that sits astride the old A12 and adjacent to Clayhills Road at its northern margin. KcC’s neighbouring parishes comprise; Theberton to the east, Middleton and Yoxford to the north, Saxmundham to the south, Rendham to the west, along with other close neighbours; Knodishall, Leiston and Sternfield across predominantly agricultural fields. In general terms the network of roads and lanes servicing KcC residents and businesses (excepting the A12 and Main Road) are less than 4 metres wide, with many effectively operating as single carriageway lanes. Those where two way ‘mixed traffic’ is possible (along part or all of their length) are very limited and largely have either complicating factors (i.e. Kelsale Primary School, weak or weight limited bridges, etc.) or facilitative features (i.e. passing spaces). It should be noted that the network of lanes comprising the greater KcC area are regularly used by; horseriders, runners, walkers, dog walkers, cyclists, game shoots and agricultural vehicle – small and large, they are often hedged to both sides (some sunk), are largely unpaved, have soft verges and deep run-off gulleys and are often subject to field run-off in west weather. KcC is centrally placed in an area identified as having ‘severe’ water issues. As a consequence KcCPC is concerned that the additional water required to construct Sizewell C may irrevocably damage the local aquifers, water abstraction sites and local supply continuity. About Kelsale cum Carlton Parish Council’s Response Kelsale cum Carlton Parish Council [KcCPC] has taken the opportunity to review the proposals contained within the four volumes of the Stage 3 Pre-Application Consultation produced by EDF Energy. Volume 1 – Development Proposals (418 pages) Volume 2a – Preliminary Environmental Information (374 pages) Volume 2b – Preliminary Environmental Information (314 pages) Volume 3 – Preliminary Environmental Information Figures (167 pages) Page 2 of 187 Version: Final Kelsale cum Carlton Parish Council’s Detailed Response to Sizewell C Stage 3 Pre-Application Consultation KcCPC has tried to frame responses to all of the elements of the proposal where they have either a direct impact on the residents of the Parish, or indirect and/or unforeseen consequences of a specific proposal that may impact the Parish detrimentally or beneficially. Within the limited time available, KcCPC has tried to solicit the views of as many of residents as possible through a Public Meeting, a door-to-door delivered quantitative and qualitative questionnaire alongside face-to-face dialogue. Where KcCPC (and/or the Parishes’ residents) are not adequately equipped with; expertise, knowledge, tools, adequate time or an understanding of a specific topic, KcCPC defer to the expressed views of fellow Parish Councils, Town Councils, expert bodies and/or impacted residents and businesses. Where a paragraph is ‘noted’, KcCPC have reviewed the content and concluded it does not require comment. Readers should note that - KcCPC reserve the right to alter its position in regard to the views expressed in this response, if as a consequence of; ongoing work, the emergence of material elsewhere or other matters of significance howsoever arising, inform KcCPC’s position at the time or writing, more fully. In order to ease navigation of a complex response to EDF Energy’s documents, numbering remains the same, with PEI paragraphs prefixed by ‘PEI’. Text in black is that of EDF or in a limited number of cases, a third party, whilst Kelsale cum Carlton Parish Council’s [KcCPC] responses are made in blue. Kelsale cum Carlton Parish Council has undertaken this response and all of its consultation with residents on the basis that government policy has given approval for EDF Energy to consult on the construction of Sizewell C with a view to EDF Energy making an application for a Development Consent Order. Consequently, comments largely relate to the ‘how’ delivery will be made and not the underpinning rationale for Sizewell C or Nuclear Power. CONTENTS KcCPC’s response to EDF Energy’s Stage 3 Volume 1 – Section 1 Introduction 4-7 – Section 2 Project Overview 8-15 – Section 3 Planning Context 16-19 – Section 4 Socio-economics 20-39 – Section 5 Transport Strategy 40-67 – Section 6 Traffic Modelling 68-94 – Section 7 Main Development Site 95-114 – Section 8 Rail 115-120 – Section 9 Level Crossings 121-128 – Section 10 Sizewell Link Road 129-150 – Section 11 Theberton Bypass 151-156 – Section 12 Two Village Bypass 157-161 – Section 13 Northern Park and Ride 162-165 – Section 14 Southern Park and Ride 166-170 – Section 15 Freight Management Facilities 171-176 – Section 16 Yoxford Roundabout 177-179 – Section 17 Highway Improvements, Cycling & PRoW 180-187 Page 3 of 187 Version: Final Kelsale cum Carlton Parish Council’s Detailed Response to Sizewell C Stage 3 Pre-Application Consultation 1. Introduction (Volume 1, Pages 2 to 11) 1.1 Introduction 1.1.1 KcCPC note the Joint Venture between EDF Energy and China General Nuclear Power Corporation through NNB Generation Company (SZC) Limited (Reg. No. 09284825), incorporated in London on 28th October 2014. KcCPC also note that further shareholder investment is being sought to finance and construct Sizewell C, with unnamed UK Pension Funds currently in discussions. It is noted that NNB Generation Company (SZC) Limited is referred to as EDF Energy throughout the consultation documentation. 1.1.2 Noted 1.1.3 KcCPC note the intent not to undertake any further consultation prior to deciding whether to take forward proposals in the form of an application for a Development Consent Order. KcCPC regret that this appears to be the intention of EDF Energy, as it believes that some of the proposals coming forward in this Stage 3 Consultation, are radically different to those in the preceding Stages (1 and 2) and are in some instances either in part or fully; unsubstantiated, incomplete, ill defined, unproven or unsound. Consequently, KcCPC believes it likely that some proposals directly impacting Parish residents may only be seen in substantive form at the point an application for a Development Consent Order is made to the Planning Inspectorate, leaving Representations to the Planning Inspectorate as the only forum for raising concerns. 1.1.4 KcCPC note the restatement of the EDF Energy vision (from Stage 2). However, in light of proposals coming forward in Stage 3 (and noting the respect shown for the marine environment), KcCPC wonder under what definition of “sustainability” the development, operation and decommissioning of Sizewell C is being undertaken under. Can it possibly be: "A process of change in which the exploitation of resources, the direction of investments, the orientation of technological development and institutional change are all in harmony and enhance both current and
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