Further advice to Alde and Ore Association members:
EDF have launched a further short consultation on adjustments they are proposing to make to their proposals to reduce road traffic and make more use of rail and sea transport. Responses have to be submitted by 18th December.
Full details can be downloaded from https://edf.thirdlight.com/pf.tlx?jUNjtYxjt2VdAX.
The Alde and Ore Association’s remit limits its own consideration to the impact on the coast and members may want to take a view on the proposals to seek to reduce traffic on the roads as it affects their lives.
The proposals involve extending the proposed Beach Landing Facility and have added a temporary beach landing facility, for which four options are given. The consultation also involves changes to the Hard Core Defence Feature which will defend the two SZC plants from the sea and flooding. There are also new plans for a temporary storm water outfall on the beach. These plans have consequences for the earlier proposals envisaged for shoreline protection by shingle recycling.
The problem with all these proposals is that they involve new ideas on which the consultation document admits there is further work to be done to assess whether or not the impact on coastal processes and sediment movements will have significant effects, but it never the less goes on to suggest they do not think what they find will be significant.
The Association’s Trustees conclude that, just as with the original proposals, these amended proposals are hard to comment on because the data and assessments of their likely impact are still missing. For example the design of the Hard Core Defence Feature was incomplete in the last consultation so assessment of its impact on coastal processes was not possible. This lack of transparency about what is planned, when the impact could be detrimental to our coast was and remains unacceptable, however welcome the attempt to reduce the number of road vehicle movements might be.
Details
Hard Core Defence Feature– now includes sheet piled walls with the effect that the HCDF will be 3.8 m higher and probably extended about 8 metres further seaward- the word ‘probably’ is used as the diagrams are not complete and East Coast Council experts have done their best to assess what the changes mean from of what is proposed. Diagrams of the HCDF are also hard to follow as little is given to set the amended construction in context, such as High Water Mark. But it seems clear that it will be a much more intrusive structure than in the earlier proposal.
The Permanent Beach Landing facility would be extended by 30 metres and would be used for major exceptional deliveries.
The Temporary Beach Landing facility would be used for delivery of bulk materials during the summer months. There are four options for the Temporary Facility which are yet to be assessed for EDF to arrive at a final choice: these have varying degrees of fixed and floating platforms and differing relationships with the shoreline. While the fourth option, which is currently largely a floating construction, seems least likely to affect sediment flows, it has not yet been decided whether that might in fact have a more fixed construction, in which case it might not be preferable.
Temporary Storm Water Outfall This is a new addition but the actual placing on the beach is uncertain, as are the considerations as to its impact on the beach profile and possible problems for walkers.
The consultation document accepts that the new proposals would mean that the need to take remedial action to deal with erosion and long shore drift would be needed earlier than under the previous plan, probably by 2050. It can be inferred that the earlier date of the structure starting to protrude from the coastline could mean earlier and more build-up of sediment north of Sizewell. The plans remain silent on what happens to the south: EDF maintain that given the coastal processes within the Greater Sizewell Bay will stay with that area, there will not be any implications to the south. This assertion remains strange given the long evolution of the dynamic Suffolk coast, even from Dunwich to Shingle Street, and the fact that the ness of Thorpeness itself had moved south in recent years.
East Coast Council are in discussion with EDF about a future monitoring and mitigation plan. While it is not in the EDF plans and is being pushed for by ESC, indeed the Association supported this proposal in its last consultation response, the fact that EDF are talking about it is a positive development. The existence of such a plan, if Sizewell is allowed to be built, will be vital to ensure changes to the coast caused by the existence of SZC, as opposed to natural coastal evolution, are addressed and mitigation put in place. The need for a legally binding, well governed structure which will be properly funded was stated in many comments to earlier consultations, including by the AOA, but the Plan will be needed to be activated earlier now under the revised proposals. That therefore remains an important point to stress.
Action
Trustees will be sending in a response to the consultation covering the above points.
But members are encouraged to send in their own comments. The details as to where and how comments can be submitted are given at the end of this email. At the very least these might say that while recognising the effort to reduce transport by road, the proposals in this latest consultation are not clearly defined or fully assessed. They add to greater uncertainty about the impact on the coast already commented on in the earlier consultation. A consultation on which is not possible to form a view but only to express concerns is not a real consultation. The concerns remain. There is nothing in any of the proposals to date which give any confidence that there has been any proper consideration of the potential damage to this dynamic coastline arising from the disturbance that will be caused by the construction of Sizewell C and which could have substantial adverse consequences for the shoreline of the settlements and Orfordness to the south of the Sizewell area.
It may be easier to email or send comments by Freepost. Do also copy your responses to your East Coast Council Councillor and to Suffolk County Council.
From the Alde and Ore Association Trustees
8 Dec 2020
Any responses to the consultation are to be submitted to the Applicant by the latest of 18 December 2020 via one of the methods below
:•complete a response form online (www.sizewellc.co.uk);
•email comments to info@sizewellc.co.uk;
•post comments to FREEPOST SZC CONSULTATION (no stamp or further address required); and
•if you are shielding and unable to use the above methods, call Freephone 0800 197 6102 (09:00 – 17:00 Monday to Friday) to arrange for your response to be collected.