Agenda item 6 CAB 23/19 Appendix A Joint response of Suffolk Coastal District Council and Suffolk County Council to EDF Energy’s Stage 3 Public Consultation The following appendix is the draft response subject to agreement of the report by Suffolk County Council Cabinet and Suffolk Coastal District Council Cabinet. March 2019 77 Agenda item 6 CAB 23/19 Appendix A 78 Agenda item 6 CAB 23/19 Appendix A CONTENTS GLOSSARY OF ACRONYMS (6.) EXECUTIVE SUMMARY (8.) OVERVIEW (14.) Overall Representation (14.) Planning Policy Context (14.) IMPACTS ON THE ENVIRONMENT (16.) Natural environment (16.) o Policy context (16.) o Overview of Stage 3 coverage of the natural environment (17.) o Local principles and the mitigation hierarchy (19.) o Cumulative impacts with SPR and NGV proposals (21.) o Landscape and Ecology Management Plan (21.) o Marine ecology & water quality (22.) o Associated development natural environment impacts (22.) Historic environment (24.) Environmental Health and Protection (25.) o Air Quality (25.) o Environmental Protection (27.) o Construction - Hours of working (28.) o Construction - Noise and vibration (28.) o Construction - Contaminated land and soils (29.) o Construction - Lighting (30.) o Construction - Water quality (30.) o Site operation - Noise and vibration (30.) o Radioactive Discharges (30.) o Other Ancillary Environmental Protection Matters (31.) o Decommissioning (31.) Coastal impacts (32.) Inland Flood and Water Management (32.) Construction materials and their spoil and soil management implications (35.) SOCIO-ECONOMIC STRATEGY (38.) Tourism (42.) Skills, Employment and Education (44.) Supply Chain (48.) Gravity Model and sensitivity testing (49.) o Transport implications of the gravity model and sensitivity testing (50.) Accommodation Strategy (52.) o Caravan site at the LEEIE (55.) Impacts on public services (59.) o Access to public services and community facilities (59.) o Schools and childcare (59.) o Social services and safeguarding (60.) o Healthcare facilities (62.) o Emergency / blue light services (64.) 79 Agenda item 6 CAB 23/19 Appendix A Emergency planning (66.) o Assessment of Impact on REPPIR Off Site Emergency Plan (66.) Community impacts (67.) o Sports and recreation (67.) o Community cohesion and integration (68.) o Community Fund (69.) o Community Safety Management Plan (CSMP) and Worker Code of Conduct (69.) o Impacts on the Leiston Recycling Centre (70.) TRANSPORT STRATEGY (71.) Transport strategy overview (71.) Transport strategy for the construction workforce (71.) Transport strategy for moving materials and freight (74.) o Material quantities (78.) o Abnormal Indivisible Loads (AIL) (78.) o Light Goods Vehicles (79.) Comments on the differences in the proposals for the rail-led and road-led strategies (80.) o Rail improvements (81.) o Road improvements (81.) Phasing (82.) Transport air quality, noise, vibration (83.) Maintenance (84.) Monitoring and mitigation (85.) TRAFFIC MODELLING (86.) Traffic Modelling approach (86.) Traffic modelling of impacts on the A12 (88.) Traffic modelling related to junction improvements (90.) MAIN DEVELOPMENT SITE (93.) Illustrative construction programme (93.) General flood and water comments (93.) The power station platform (96.) o Power station design – overview (96.) o Main reactor buildings (96.) o Turbine halls and Operational Service Centre (OSC) (96.) o Dry Fuel Storage (97.) o Forebays (97.) o Pylons (97.) o Drainage and ecology (99.) o Historic Environment (99.) Sizewell B Relocated Facilities (100.) Developments on Goose Hill (102.) SSSI Crossing (104.) Northern Mound (105.) Sea Defences and coastal processes (106.) o Monitoring and mitigation (108.) o Impact Assessments (109.) o Impact of climate change and sea level rise on erosion and flood risk assessment (109.) o Impact on Coralline Crag (109.) o External influences from coastal management actions by others (109.) 80 Agenda item 6 CAB 23/19 Appendix A o Coastal processes - Decommissioning (110.) o Impact on access (110.) o Cooling water infrastructure (111.) o Combined construction outfall (CCO) and Fish recovery return (FRR) (111.) Beach landing facility (112.) Helipad (114.) Land east of Eastlands Industrial Estate (LEEIE) (115.) Temporary construction area (117.) o General AONB and ecological impacts (117.) o Spoil management strategy (118.) o Borrow pits (119.) o Stockpiling (120.) o Temporary construction areas – historic environment comments (122.) o Other construction site area features (123.) o Upper Abbey Farmhouse (124.) o Restoration of the construction laydown area (125.) Accommodation campus (125.) RAIL (130.) Green Rail Route (132.) LEVEL CROSSINGS (135.) SIZEWELL LINK ROAD (140.) Additional Suffolk County Council comments regarding the Sizewell Link Road (145.) Additional Suffolk Coastal District Council comments regarding the Sizewell Link Road (147.) THEBERTON BYPASS (149.) TWO-VILLAGES BYPASS (153.) NORTHERN PARK AND RIDE (159.) SOUTHERN PARK AND RIDE (162.) Associated Mitigation for the Southern Park and Ride (165.) FREIGHT MANAGEMENT FACILITIES (167.) YOXFORD ROUNDABOUT (170.) HIGHWAYS IMPROVEMENTS, CYCLING, AND RIGHTS OF WAY (173.) Highway Improvements (173.) Public Rights of Way (PROW) (176.) o Construction phase - impact on access (178.) o Operational - impact on access (180.) o Traffic Issues – Impact on access (180.) o Proposed bypasses (181.) Cycling (182.) IN-COMBINATION EFFECTS (184.) NEXT STEPS (186.) 81 Agenda item 6 CAB 23/19 Appendix A 82 Agenda item 6 CAB 23/19 Appendix A GLOSSARY OF ACRONYMS AIL Abnormal Indivisible Load AONB Suffolk Coast and Heaths Area of Outstanding Natural Beauty AQMA Air Quality Management Area AW Anglian Water BEIS Department of Business, Energy and Industrial Strategy BGS British Geological Survey BLF Beach Landing Facility CCA Civil Contingencies Act 2004 CCG Clinical Commissioning Group CEMP Construction Environment Management Plan CHP Combined Heat and Power CLEA Guidance on soil concentrations CSMP Community Safety Management Plan DCO Development Consent Order DECC Department of Energy and Climate Change DMO Suffolk Coast Destination Management Organisation DMRB Design Manual for Roads and Bridges EA Environment Agency EcIA Economic Impact Assessment EIA Environmental Impact Assessment FEH Flood Estimation Handbook FRA Flood Risk Assessment GVA Gross Value Added HB Home Based worker HCDF Hard Coastal Defence Feature HER Historic Environment Record HGV Heavy Goods Vehicle HIA Health Impact Assessment HLC Historic Landscape Characteristics HMO House in Multiple Occupation HRA Habitat Regulation Assessment LEEIE Land east of Eastlands Industrial Estate LEMP Landscape and Ecology Management Plan LGV Light Goods Vehicle 83 Agenda item 6 CAB 23/19 Appendix A LIDAR Light Detection and Ranging LLFA Lead Local Flood Authority LTP Local Transport Plan LVIA Landscape and Visual Impact Assessment MHW Mean High Water Mt Million tonnes MUGA Multi Use Games Area NALEP New Anglia Local Enterprise Partnership NEET Not in Education, Employment or Training NHB Non Home-Based worker NPPF National Planning Policy Framework NPS National Policy Statement NSIP Nationally Significant Infrastructure Project OSC Operational Service Centre PEIR Preliminary Environmental Information Report PINS Planning Inspectorate PM10 Particulate matter PROW Public Right of Way PRS Private Rented Sector REPPIR Radiation (Emergency Preparedness and Public Information) Regulations 2019 RSPB Royal Society for the Protection of Birds SMART Specific, Measurable, Attainable, Realistic / Relevant, Timely SSSI Site of Special Scientific Interest STEMC Science, Technology, Engineering, Mathematics and Construction SuDS Sustainable Drainage Systems SWMP Leiston Surface Water Management Plan TCA Temporary Construction Area TCPA Town and Country Planning Act WSI Archaeological Written Scheme of Investigation 84 Agenda item 6 CAB 23/19 Appendix A This response is the JOINT response of the two Councils unless where otherwise identified throughout the text. EXECUTIVE SUMMARY 1. This document is the joint response of Suffolk County Council and Suffolk Coastal District Council (referred to as “the Councils” in this response) to EDF Energy’s Stage 3 public consultation. Unless it is identified otherwise in specific sections, the Councils share the views on matters within this response. The response has been formally agreed in Cabinet Meetings of the Councils, on 11 March 2019 by Suffolk Coastal District Council’s Cabinet, and on 12 March 2019 by Suffolk County Council’s Cabinet. 2. In line with previously determined policy, the Councils continue to support the principle of a new nuclear power station at Sizewell, recognising the significant benefit that such a development would bring to Suffolk. The Councils are disappointed that the Stage 3 proposals have not evolved more considerably since Stage 2, particularly given the time that has been available and that this is a final public consultation. There remain a considerable number of issues to be addressed between Stage 3 and submission of the Development Consent Order (DCO). At this stage there are still some areas where the Councils are not content, cannot come to a clear view or have been unable to update our response since Stage 2. 3. Based on the new information put forward in the Stage 3 Consultation, the Councils are still not able to support all the specific proposals put forward by EDF Energy and the impacts of the proposed development are still not yet fully developed