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Civic Office Sedgemoor District Council Bridgwater House, Mendip District Council Cannards Grave Road Taunton Deane Borough King Square, Bridgwater, Shepton Mallett, Somerset, Council South Somerset District Somerset TA6 3AR BA4 5BT The Deane House Council Belvedere Road West Somerset Council The Council Offices Taunton, Somerset Tel: 08454082540 Tel: 01749 648999 West Somerset House Brympton Way, Yeovil, TA1 1HE Killick Way, Williton DX: 80619 Bridgwater Somerset, BA20 2HT www.mendip.gov.uk Taunton, TA4 4QA Tel: 01823 356356 www.sedgemoor.gov.uk Tel: 01935 462462 Somerset County Council Tel: 01643 703704 www.tauntondeane.gov.uk County Hall, Taunton, DX: 117701 Williton www.southsomerset.gov.uk Somerset, TA1 4DY www.westsomersetonline.gov.uk Tel: 08453459166 www.somerset.gov.uk Date: Monday, 04 October 2010 Richard Mayson Director of Planning and External Affairs EDF Energy The Qube 90 Whitfield Street London W1T 4EZ Dear Richard Re: Somerset Councils [Somerset County Council (SCC); Mendip District Council (MDC); Sedgemoor District Council (SDC); South Somerset District Council (SSDC); Taunton Deane Borough Council (TDBC); and West Somerset Council (WSC)] and Somerset Nuclear Energy Group (SNEG) Joint Response to Hinkley Point C Proposed Nuclear Development Stage 2 Consultation. We write regarding the Hinkley Point C Proposed Nuclear Development Stage 2 Consultation Proposals. The Councils recognise that significant potential economic benefit to Somerset may arise from the development, and in this respect we should like to find the best way for the proposed development to proceed. However, this must be viewed in the context of the long term impacts of constructing, operating and de-commissioning such a facility over a 160 year period. As such, we have drafted our response to highlight both our concerns with the proposals and potential opportunities for further consideration by EDF, which we have a duty to do as stipulated by the IPC. The Councils acknowledge that there has been a considerable body of work produced by EDF to articulate the issues associated with the highly complex and geographically dispersed proposals. However, the Councils also consider that: • There are substantive and material omissions in both the scope and quality of technical information supplied; • The approach to assessing impacts and mitigation is wholly inadequate; and • There are serious objections to the associated development proposals. Due to these significant deficiencies and concerns with the Stage 2 consultation work the Councils consider that there is a need for further public consultation on amended or new proposals. Any further consultation should clearly set out in more Page 1 of 5 detail the justification for the proposals supported by the necessary strategies, assessments and other documentation (in the form of draft application documents) which address the issues set out in the Council‟s full consultation responses. We believe that this approach would accord with the guidance of the IPC that states “the overriding intention of the legislation is to ensure that detailed matters are consulted upon and solutions or mitigation negotiated with the local community, landowners, statutory consultees and local authorities before submission of the application for development consent to the IPC” - paragraph 8 - IPC's guidance note 1 (Revision 1) on Pre-Application Stages – March 2010. SCC, SDC and WSC are most directly impacted by the proposals and have prepared separate detailed technical responses to the Stage 2 Consultations to outline their concerns. A summary of the key technical issues raised in the council review process is stated below and is endorsed by each of the Somerset Councils and by the Somerset Nuclear Energy Group (SNEG). 1. Accommodation Strategy: The Councils consider that the proposed accommodation strategy is not fit for purpose. There is limited evidence to support the proposed concentration of temporary worker accommodation at a single site in Bridgwater or on the main site or to rule out an alternative accommodation strategy. Over concentration of workers at single sites in Bridgwater and on the main site has potential to result in poor integration of the temporary workforce into key settlements. There is also limited articulation in the Stage 2 documents of the policy basis for the location of accommodation sites or how the proposals would comply with local policy or contribute to long term regeneration. The Councils require EDF to provide an overarching accommodation strategy with details of alternative accommodation proposals including permanent housing. 2. Transport Strategy: The Councils consider that inadequate information has been supplied to support the proposed transport strategy or to rule out the need (or otherwise) for a Bridgwater Bypass. We have significant concerns relating to the potential for as much as 20% of quarried material to be transported by road. Superficially, EDF‟s proposals to reduce material transport by road (e.g. through use of an aggregates jetty and freight handling facilities) appear reasonable. However, there is insufficient detail regarding this 20% provision for the councils to properly understand its impact. In addition, insufficient reference has been made to other sustainable transport options for the movement of workers to site, to and from park and ride sites and accommodation centres (e.g. rail, coach, cycling and walking). Only limited highway mitigation is proposed and this is considered to be insufficient based on the extent of the proposals and their impact upon the highway network and ongoing maintenance requirements. We are concerned that conclusions have been drawn in the transport documentation based on incomplete and unfinished work, and that these unsupported conclusions on impact are potentially misleading. Considerable additional work is required including cumulative effects assessment and in our view it is unlikely that this will be achievable by winter 2010. Specific areas for further consideration include the impact of HGVs (currently included within total vehicle number data); highway safety and resilience (flooding/climate change/emergency planning); supply chain implications and training trips; and a full NATA assessment of any by-pass proposals to mitigate these impacts. 3. Mitigation and compensation: The Councils consider that the approach to mitigation of tangible impacts and the limited community fund to deal with more Page 2 of 5 intangible development impacts is not acceptable. The lack of any reference to the joint Vision for the project developed between EDF and SCC, SDC and WSC is disappointing. We consider the proposed one off £1M community fund to be wholly disproportionate to the likely intangible impacts upon Somerset citizens over the project‟s lifetime and the extent of effect when related to national/international community fund exemplars. 4. Procurement and skills: The Councils consider that the Stage 2 proposals lack detailed construction and operational workforce development strategies and lack a local workforce delivery mechanism (e.g. to deliver the assumed 40% local labour). The baseline assessment does not include mapping of existing service provisions. No detail has been supplied in relation to training facilities; supply chain land and premises needs and their associated transport impacts. Further detail is requested in relation to the proposed apprenticeship hub (WSC); and construction skills centre (SDC) operation. The lack of detail regarding the potential construction worker family make up means that the potential impact on teaching/education provision is unclear. This leaves us unable to comment on the appropriateness of the proposed £1.047M contribution towards education. 5. Environmental protection: The Councils are concerned that the approach to environmental assessment is not robust. Of particular concern is that the conclusions of significance assessment do not appear to reflect the level of effect identified within the assessment text. There is a lack of rigour in certain assessments (e.g. noise/vibration and air quality) where out of date or inappropriate methods, such as averaging of receptors, have been applied. Baseline data is incomplete, and while it is acknowledged that due to time constraints some baseline datasets will not be available until the final submission (e.g. ecology/archaeology), we do not consider that it is appropriate to draw conclusions relating to the effect of the proposals, since these may be misleading. Within the documentation a number of construction effects are defined as temporary such as noise/air quality/traffic. Given the 10 year period of the works its potential effects, although not permanent, are not considered to be temporary in nature either. Furthermore, we consider that the assessment of the effects focussing on individual projects leads to an inaccurate assessment of the overall significance of effects as it does not take into account the cumulative or in-combination effects that may arise. Cumulative effects are not independently assessed. Finally, although some potential mitigation is outlined within the environmental assessment documents, there is a lack of commitment to actual delivery of mitigation. 6. Socio-economic: The Councils consider the Stage 2 proposals to be focussed too heavily on peak workforce impacts rather than the longer term socio-economic effects, i.e. the proposals consider the „boom‟ rather than „bust‟ period. The long term economic development and job creation issues
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