SIZEWELL C STAGE 3
PRE-APPLICATION CONSULTATION
Representations from
Leiston-cum-Sizewell Town Council
SUMMARY
The impact on local residents, the
specific impact on the town centre and the wider impacts from the additional
traffic remain the primary concerns of Leiston-cum-Sizewell Town Council and
their residents. Almost 90% of the
construction will take place in this parish.
The current Stage 3 consultation has
better detail than Stage 2 in many areas and has allowed Councillors and
residents to get a better feel for the sheer size of the project and form
better impressions on just what the impacts might be. This has heightened
concerns in some areas, particularly around the size of the platform, and these
are detailed below.
Whilst welcoming many of the socio-economic
benefits that a major infrastructure will bring the main issues detailed below
concentrate on the undoubted disruption and inconvenience the town and
surrounding area will experience throughout the lengthy construction phase and
also raises topics where mitigation and compensatory measures could be included
in EDF Energy’s future plans.
Councillors would like to thank EDF Energy
for the better timing of this consultation, the wide distribution of
documentation and the willingness to meet and discuss issues with groups and
parishes when requested.
1.0
INTRODUCTION
1.1 These
representations are made on behalf of Leiston-cum-Sizewell Town Council.
1.2
They represent the views of
the elected members of Leiston-cum-Sizewell Town Council. This response was
formally endorsed by the Town Council at its meeting on 19 March 2019. Their
views took into account various representations and
submissions made to them by residents over the course of the consultation.
1.3
This response is structured
as follows:
·
Section 2 - Addresses the
overall principle of Sizewell C.
·
Section 3 - Provides some
local context to the area and sets out the principal concerns of Leiston-cum-Sizewell
Town Council.
·
Section 4 - Highlights the
key negative impacts to beach access, natural and heritage assets.
·
Section 5 - Identifies key
socio-economic impacts of Sizewell C to the Leiston-cum-Sizewell.
·
Section 6 - Presents
mitigation measures to help alleviate negative impacts and secure positive
impacts not covered in in Section 4 and 5
·
Section 7 - Identifies
transport impacts and required mitigation measures.
·
Section 8 - Provides a
response to the different options presented in the Stage 3 consultation
material.
·
Section 9 – Identifies the
considerable challenges of the first stages of construction
·
Section 10 - Lists
additional evidence required to support the Sizewell C proposals and work that
needs to be done with other stakeholders.
·
Section 11 and 12 –
Consultation and Conclusion
Appendix A – for purpose of clarity this provides a list of and
rationale for all requested improvements to community infrastructure and
amenity.
Appendix B –covers the mitigation and compensation required specifically
for Leiston Town Centre.
2.0 NATIONAL ENERGY STATEMENT
2.1 It
is the understanding of Leiston-cum-Sizewell Town Council that, under the
Government’s National Policy Statement for Nuclear Power Generation (EN-6) and
the recent consultation for revision of this policy (for post 2025), Sizewell
remains a nominated site for a reactor. The finalised strategic site criteria in
the new consultation remains the same however when relating to the size of the
site nominated. It also still gives the nominator an element of flexibility on
the size once detailed plans are drawn up. The extant EN6 gives leeway on
flooding issues and Habitat Regulations via a mechanism called Imperative Reasons of Overriding Public Interest
(IROPI). This was to meet the Government’s objective to maintain or enhance
levels of energy security that they felt held a certain urgency back in
2011. A lot has changed since then and the upsurge of wind power in particular has
lessened the urgency and, in our opinion, the need for potential adverse effects on the integrity of the
European Sites which cannot be effectively avoided or mitigated to achieve the
Governments aim in this document. Importantly, Sizewell is the only site
nominated in an Area of Outstanding Natural Beauty.
2.2 It is the flexibility of site size that has caused the most concern
though as, the plans for two reactors on the site (for economy of scale) has
pushed the EN6 site boundaries out too far and has raised serious concerns
about how the site will now impinge on the local environment and, more
importantly, resident’s amenity in the future.
2.3 It is acknowledged that Government is the key driver in how many
of the 8 sites from EN6 are actually needed. They will be influenced of course
by the timescales for delivery, and this will feature heavily in the selection
process.
2.4 Even bearing in mind the strategic nature of these decisions it
is understood that Sizewell C will be considered on its own merits by an
independent Planning Inspectorate who will pass on their recommendation to the
Secretary of State to make the final decision on the site’s suitability. Not
it’s necessity.
2.5 This does not mean therefore that Sizewell C will automatically
be granted a Development Consent order.
2.6 There is also still the fundamental concern of locating so much
of the country’s power supply in one area. This is exacerbated by National Grid
currently allocating enormous capacity on the same line to various other major
infrastructure projects from the wind sector. Loss of transmission on this one line could
lead to major grid instability.
2.7 With this in mind, Leiston-cum-Sizewell Town Council still have
serious ecological and practical concerns for siting two more reactors in an
AONB (and SSSI) and would insist that the issues set out in these
representations are fully addressed and mitigated for should the Secretary of
State subsequently consider this site to be suitable. It is assumed that the ONR will be providing
a clear statement on whether they are content that the site is large enough to
support two reactors and the ancillary equipment along with waste storage. We
commented in Stage 2 that the illustrative maps did not appear to leave much
leeway for any additional buildings that may have become necessary and this has
been proved pertinent as the size of the site has now increased. Sizewell B is
having to relocate facilities and there are unsightly and unwanted pylons now
being proposed on the site too due to the restricted footprint. Members are
seriously concerned that the new land take, predicted in our Stage 2 response, will
have a huge detrimental effect on the surrounding designated areas, especially
the coastal path. In our opinion this site is too small for the proposed
project. Members would
therefore like assurance from ONR and EDF Energy that this has been considered
and from the Planning Inspectorate, in due course, that this extra incursion and
impact on the surrounding designated sites is acceptable.
2.8 There is
also concern about a possible displaced flood risk from the strengthening and easterly
movement of the sea defenses plus the unknown impact of the Beach Landing
Facility and its access road on coastal processes.
3.0 LOCATION
OF LEISTON AND SIZEWELL
3.1 Leiston
is a small market town that is adjoined by the hamlet of Sizewell, with a
collective population of around 6,000.
It is located on the coast between Lowestoft and Felixstowe. Leiston is served by a variety of shops,
public houses, cafes, and restaurants.
It also has its own recognised football club in the Football League, a leisure centre, a
Film Theatre and is home to the world renowned Long Shop Museum. It also adjoins the internationally famous
RSBP Minsmere bird reserve and is home to Leiston Abbey.
3.2 The
proximity to the coast and its position in the centre of the AONB means that
residents and visitors to Leiston and Sizewell enjoy excellent access to the
amenities offered by having the coastline on their doorstep and country walks
all around the parish. This includes good access to the beach for recreation
including walking, dog walking, and swimming. The Park Run along the frontage
of the Power Stations to Minsmere is also very popular and a big benefit to
resident’s health and wellbeing.
3.3 Leiston
has an established Neighbourhood Plan, with vision, and this document should be
used by EDF Energy to assess the efficacy of supporting the town and entering
into partnership with the town to work on the bigger projects with them as its
major employer and neighbour for many years to come.
3.4 The
impacts on current amenities, the loss of valuable recreation space at Sizewell
and the impacts from the additional traffic associated with the proposed
development of Sizewell C, are a major concern for the residents of Leiston and
Sizewell.
3.5 These
impacts are of particular concern for Leiston and Sizewell during the construction
period – especially the first two years.
3.6 It
should be noted that there are other very large construction projects planned
to take place in the same very small area which will not only interlap but possibly interfere with the initial stages of
SZC construction. These will have a cumulative effect on the parish and
surrounding area and must be factored in. They will include Scottish Power
Renewable wind farm projects, Interconnectors from Europe, the continued
dismantling of Sizewell A and the possible relocation of facilities on Sizewell
B.
4.0 PUBLIC
RIGHTS OF WAY, LOSS OF ACCESS TO BEACH AND IMPACT ON NATURAL AND HERITAGE SITES
4.1 Leiston-cum-Sizewell Town Council is
particularly concerned about the potential loss of public rights of way and any
restriction of access, including access to the beach from the Kenton Hills and
Goose Hills Walks and along the beach itself (part of the England Coast Path –
a new National Trail). The closure of Bridleway 19 is a significant loss of
amenity which is only partly mitigated by the alternative route. This must be
re-opened as soon as construction allows.
4.2 Access to the public beach is a fundamental
right of residents and visitors alike, this is going to be severely restricted
with the proposal for Sizewell C.
4.3 Although EDF Energy are suggesting that
public access will still be permitted along the length of beach in front of the
proposed Sizewell C site during most of the construction period, it will be a
loss of the current amenity and views enjoyed at present which must be
carefully considered and mitigated for. With the new easterly land take for the
defences it is likely that this will mean walking along the foreshore for many
years to come and then only when it is not closed off completely.
4.4 During the construction of Sizewell B a
high chain-link fence with barbed wire on the top was used along the length of
the restricted beach area. For Sizewell
B this demarcated public footpath measured approximately 4m wide.
4.5 The fencing arrangement used during the
construction of Sizewell B was poorly planned, and ultimately considered
unsuccessful by local residents. The
plans for Sizewell C at Stage 2 looked as though the
issue had been addressed where, after the initial phase (when the access was
planned to be along the foreshore), there appeared to be unimpeded views to the
east for walkers using a reasonably sized recreational corridor.
4.6 At Stage 2 Leiston Town Council asked that
“Leiston-cum-Sizewell Town Council would
wish to discuss any proposed designs for beach restrictions with EDF Energy
before they are presented at the next stage”. No discussions have taken place and, with the easterly extension of the site boundary,
it is unclear whether there will now be any recreational corridor at all.
Figure 7.22 in the Consultation document infers the recreational corridor is
wider at Stage 3 (than in Fig 7.20 in Stage 2 papers) and is clearly wrong and
misleading. With the new defences the recreational corridor will probably have
to ultimately be on the crest of them after construction is complete, rather
than seaward, as the small protective dune above the shingle beach will no
longer be there to shelter the smaller recreational corridor and this, now
being narrowed, will be further eroded by coastal surges and the elements. This
will be a major loss of amenity for our residents and visitors.
4.7 During the initial phase most definitely,
but probably throughout the whole construction, a sturdy maintained walkway must be laid on the shingle for less
able or steady residents as to walk along shingle is not easy.
4.8 It is noted that the existing track along
the beach front is being used by the Civil Nuclear Constabulary. There is concern that EDF Energy will seek to
use this existing track to access the rear of the site proposed for Sizewell
C. Leiston-cum-Sizewell Town Council are
keen to ensure that this existing track is not used by any vehicles to access
the beach, other than security vehicles.
This must be formally agreed in writing by EDF Energy as part of any
future development of the site and LTC
propose and request that this is covered in a statement of common ground
between LTC and EDF Energy
4.9 Leiston-cum-Sizewell Town Council also
remains concerned about the impacts on the surrounding environment, including
the Ramsar site of European importance, and the SSSI site of regional
importance. The impact on other local
heritage assets, such as Leiston Abbey, also still need to continue to be fully
considered. The Town Council would fully
support any representations made by our neighbours in the RSPB and those made
by Natural England and the Environment Agency in this regard. Their expertise and understanding of the
impacts must be addressed by EDF Energy. EDF Energy has a huge responsibility
to protect our landscape if they are to be granted permission on this site.
5.0 SOCIO-ECONOMIC
IMPACTS
5.1 Leiston-cum-Sizewell Town
Council has identified the following socio-economic impacts as a result of the
Sizewell C proposals:
·
Increased
pressure on emergency services and increased traffic on access routes and in
the town.
·
Potential
negative impacts to some local employers but positive impacts overall in terms
of local employment opportunities.
·
Potential
positive impacts to local education, skills and vocational training
opportunities.
·
Potential
negative impact to the local economy following the peak of construction.
·
Increased
visitor numbers to the town centre during the day and evening.
·
Distortions
to the local housing market.
·
Negative
impact on tourism.
5.2 Where
negative impacts are identified these should be mitigated for but equally
important is that the positive impacts to the local economy are both secured
and maximised.
Emergency Services
5.3 Further
development at Sizewell will require appropriate consideration with the
emergency services. Additional risks
associated with the construction and operation should be identified ahead of
the project to enable adequate planning, resourcing, training, site
familiarisation and equipment provisions for the emergency services. Any extra resources must be specifically
bought in and must remain earmarked for the development. There should be absolutely no dilution
whatsoever of current resources before, during, and after construction. With
the big increase in risk from extra traffic, heavy industry, hazardous
materials and increased personnel in the parish a strategy must be looked at to
protect the on-call firefighters in Leiston in particular. An increase in call
outs will test the good will of the firefighters’ employers so this needs to be
addressed separately. Fears have also been raised, highlighted during the
construction of SZB, that retained firefighters may be lost due to them
changing employment and joining the construction site. EDF Energy is asked to
be aware of this problem and to work with local employers on recruiting and
retention of firefighters during the project. EDF Energy are also requested to
look at how they would support the improvement of poor response times of our
Ambulance Service to postcode area IP16 for their own peace of mind as well as
to re-assure residents they wouldn’t get even worse service due to increased
traffic. It is requested that serious
consideration be given to formally requesting that the joint Leiston
Fire/Police Station also house a small ambulance station. Leiston Town
Council are aware that discussions are taking place between EDF Energy and
Suffolk Constabulary and are in full support of any measures Suffolk propose to
augment the Constabulary’s provision to be able to effectively police the
project, Leiston and the knock on effects in the wider area.
Local Job Market
5.4 Previous
experience with Sizewell power stations has proved that the new jobs associated
with the Sizewell C proposal will have an impact on the local job market. It is expected that EDF Energy will seek to
employ a significant proportion of local people. Fair and equal opportunities need to be
applied to recruitment for the Leiston-cum-Sizewell communities. Although it is noted that Sizewell C will
have a potential effect on some local employers, Leiston-cum-Sizewell Town
Council expects the local area to benefit from the employment opportunities
that will be provided. It is expected and hoped that a Major Projects Agreement
will be made with a Union to regularise the
workforce.
Education, Skills
and Vocational Training Opportunities
5.5 Leiston-cum-Sizewell
Town Council also wants to see EDF Energy continue to make positive
contributions towards education in the area through their liaison with our
local academies. EDF Energy would be
turning Sizewell into a highly specialised and
technical area for several decades to come, therefore it would be only
appropriate that they should look to pass some of these skills and knowledge
into the local area. Leiston Town
Council welcomes their current work with Alde Valley Academy and ask that they
also support ancillary skills and vocational training which are just as
important to support the estate. EDF Energy are requested to look at
establishing a training and skills centre in Leiston, either on their own, or
with other energy companies including the NDA. This would complement the project and
remain as an important legacy in this area once the station is established.
This could be achieved in Partnership with the Leiston Together Board and
Suffolk New College on the Coast.
Managing the
Impact Post Peak Construction
5.6 It is
hoped and expected that a strategy is discussed and implemented in good time to
manage the slump in employment after various phases of the construction
programme. Leiston suffered from this during the previous builds and ways must
be found to manage it this time.
Increased Number
of Visitors to the Town Centre During the Day and Evenings
5.7 It must be
remembered that the non-home-based-workers will also have the freedom to travel
when they are not at work. They will
likely use their own vehicles or walk into surrounding areas for personal or
leisure use. Previous developments at
Sizewell have resulted in serious ‘anti-social’ behaviour in the town, which
must not be allowed to happen again. The implementation of the proposed
contractual drug and alcohol policy should alleviate most of the worst problems
and would allow workers to enjoy the town and also help businesses in the
process. This must be rigorous and consistent. A continuous shuttle bus service into Leiston and to the off site sports facility would
benefit the workers and help manage the car parking situation. It is hoped that
changing attitudes and better management will make the construction less
challenging for the night time economy than was the case previously. An active “Construction Consultative Committee”
between EDF Energy, the Town Council and relevant bodies should be set up early
on to inform and communicate any issues that come to light.
Distortions to the Local
Housing Market
5.8 Accommodation
in the town is a big concern too. The demand for accommodation, some temporary
and some more permanent, especially from better off workers, would distort the
housing market in Leiston which, currently, is the only affordable area in East
Suffolk. This would have a disproportionate effect on our young residents
trying to get onto the housing ladder or rent at an affordable cost
related to the low wages in the area. Members asked that EDF Energy investigate
a scheme to provide financial support to young local families affected by this
to avoid them being priced out of the local housing market. Mention is made of
a housing fund at Stage 3 and this is welcomed but detail is needed on how a system to monitor
and measure the impacts will be assessed and how the fund can be used
constructively and appropriately for Leiston residents.
6.0 COMMUNITY BENEFITS
6.1 This section concentrates on the mitigation
measures required to alleviate the negative impacts, and to secure the positive
impacts, identified under section 4 and 5 of this response. These are set out
more fully at Annex A and B.
6.2 The proposed cycleways and improved footpaths from Sizewell
round to Eastbridge are welcomed. It is still strongly requested that a
permissive path be installed under a 3-span access bridge (Option 3 in Stage 2)
(or adjusted causeway) to allow residents to walk between the Kenton Hills
walks and the beach as soon as possible during the construction phase. The
current causeway option has been selected over the much
preferred bridge option with very little understandable justification.
It precludes any access to the beach except via the long way round to the
sluice for too many years, if ever, and is not supported. The provision of a
path under the “causeway” would be a positive boon for residents and allow
access to the Minsmere beach walks from Kenton Hills avoiding the need to
negotiate the beach works and associated disruption. As the SSSI is being
protected from the laydown area a permissive path just outside the southern protected
boundary of the laydown site would be very feasible, easily established and
much appreciated. It would also allow a circular walk using the new bridleway
for those who would enjoy that. This one addition would have a big community
benefit. Regarding the new cycleways, another crossing south of the Kenton
Hills entrance on Lovers lane, in a safe place, with a footway/cycleway on the
east side of the road up to the Kenton Hills entrance would also be very
beneficial. Currently, if the cycleway around Aldehurst Farm is used it looks
very difficult to cross the road on the Laboratory corner to gain access to
Kenton Hills.
6.3 The new route and cycleway (with crossings) must be in place
before Bridleway 19 is closed.
6.4 To help alleviate the impact of increased usage of the town’s
daytime and evening facilities, to help manage any unforeseen issues arising
from the construction and to increase the amenity available for your workforce,
the following mitigation measures are sought:
·
Funding
of Improved infrastructure in the town centre to alleviate the impact of
increased traffic and parking.
·
Involvement
and help in up-grading and
relocating of the library to allow space for increased online stations. The
Library is part of the Town Centre Regeneration plan.
·
A
representative from the Town Council on the Suffolk Community Foundation Board
overseeing the community fund.
·
A
major role for the Town Council in a responsive and powerful “Construction Consultative
Committee” to ensure issues are dealt with quickly.
6.5 The most significant project which EDF Energy would benefit from
involvement with though would be the regeneration and construction of a new town
centre as proposed in the Town’s Neighbourhood Plan.
EDF Energy would be very welcome to work with the Leiston Community Land Trust
and the Leiston Together Partnership (East Suffolk District Council, LTC, CLT
and SCC) to help achieve a viable, sustainable and attractive development which
would benefit all Sizewell workers now and in the future once Sizewell C
construction is complete. Later in the response there is a recommendation that
the Visitors Centre be moved into the town too, if a suitable location can be
found, as this would add to the tourism provision in the town. EDF Energy is Leiston’s major
employer and neighbour and it would be beneficial for everyone if they became a
partner in the Town’s future. Again, this is covered more fully in Appendix A.
6.6 Further information on the community benefits and improvements
being put forward by Leiston-cum-Sizewell Town Council are set out in Appendix
A and B. These set out the Town
Council’s assessment of immediate and long-term requirements,
and should be used as the basis for any further discussions with EDF
Energy on this particular issue. EDF is encouraged to enter into meaningful
discussions with the Town Council at the earliest appropriate phase of this
project and before the public examination sessions with PINS.
7.0
TRANSPORT
7.1 Leiston-cum-Sizewell Town Council originally
supported EDF Energy’s proposed transport hierarchy: sea – rail – road. They note
the environmental factors, the cost and the confidence in delivery of the sea
option for it to now be dropped and this has been welcomed by many in the
parish. It is felt however that there could be much more use made of the Beach
Landing Facility and further exploration of the sea option should be taken forward.They find the veiled references to the viability of
achieving a rail strategy in time concerning too but would support this over
road. If road remains the only strategy
at the DCO stage then the very maximum mitigation
schemes must be offered including a 4 village by pass on top of all the schemes
detailed in Stage 3.
7.2 Leiston-cum-Sizewell Town Council support
the maximum by rail option and are happy with the choice of the Green Route. A
small temporary (and backup) railhead just east of Eastlands
Industrial Estate is only acceptable during the early construction phase and
whilst the Green Route is being built although it is noted EDF wish to use the
existing railhead for this phase. The existing railhead is not suitable, even
with an extension and should be discounted. It will be easy to establish one in
the LEEIE and
this should be firmed up. For the
Railhead and Eastlands options train movements should
not be permitted between 2100 and 0700 hours due to the proximity of the line
(and railheads) to residential areas. This appears to be in the document
but it was felt it needed reinforcement. The Green Route, once completed, would
then avoid the double handling of freight and keep disruption to traffic in
Leiston (two level crossings closed numerous times a day) down significantly. There remains concern about the queuing
time and impact on residents, Sizewell B staff, Sizewell A staff and visitors,
caused by the level crossings. The site accesses to the LEEIE will also
seriously disrupt the Crown Farm area and traffic flow. Traffic
on Station Road, backed up in front of the Masterlord
Industrial Estate when gates closed is also of concern during this phase. All these
issues also affect the emergency services.
7.3
If the Green Route is decided upon then mitigation would have to be made for the
first two years for freight coming through Leiston until it was in use. It
would be totally unacceptable to have manned crossings anywhere on the route to
the LEEIE from Saxmundham so automatic barriers would have to be installed,
before day one, at King George Avenue, Station Road and the other crossings
affected. When the Green Route is constructed, again, there needs to be
automatic barriers on Buckleswood Road and Abbey Road. It is not acceptable
to block Buckleswood Road or
any other road or to divert other public rights of way for purposes of this
construction. (A bridge must be as
costly as an automated crossing in Buckleswood Road?). The Green Route should
be used to take traffic off Lovers Lane and must be the preferred route for all
the construction companies to avoid loading and unloading twice. The Buckleswood
Road closure would also have an unacceptable impact on local businesses.
7.4 There is serious legacy potential for a
station to be built alongside the siding on LEEIE toward the end of
construction for future passenger use. (This would require a small car park)
7.5
The traffic flows from the models
indicate the biggest impact on Leiston will be on Waterloo Avenue (Saxmundham
Road). This is a difficult road to navigate and has been subject to a TRO to
get it as free flowing as it currently is whilst still maintaining essential on
street parking. It is a very uneven and pockmarked surface and is very noisy
for residents on that road. A smooth noise treated surface would be required to
ease this loss of amenity. A similar treatment should be given to the road from
Knodishall right down Haylings Road, Park Hill and Station Road as this route
will also have heavy use.
7.6 A clear picture of what is expected to
happen in King Georges Avenue is still missing! This was stated in our Stage 2 response. The detail and proposed mitigation
for this important route is required as soon as possible and definitely before
Stage 4/DCO. This is especially pertinent during the initial two years and
Leiston Town Council need to discuss this further with EDF Energy as soon as
possible to ensure baselines and predictions are understood. It is obvious that
a large proportion of the traffic that EDF Energy predict will use Station Road
will actually use King Georges Avenue and bleed from the other predictions will
also occur.
7.7 The more specific detail now attached to
the Land East of Eastland’s Industrial Estate (LEEIE) gives rise for serious
concern with the positioning of the topsoil stockpile and other issues
regarding the caravan site and the site entrances. Option 2, for the rail
siding to be situated North of King Georges Avenue, is the only sensible one
and this would have LTC support until the green route materialises. With the
historic and severe flooding problems experienced at the end of Valley Road by
Archway Cottages however, it is felt that increasing the height of the land
immediately to the South of this with the potential for increased run off from
the soil stockpile would unacceptably exacerbate that situation. A complete and
comprehensive surface water scheme must be presented at Stage 4. This would
also include all the details on how sewage is dealt with on the site.
7.8 The eastern end of Valley Road that runs
beside the LEEIE (locally named Kemps Hill) should be considered carefully for
upgrade and investment as clear legacy mitigation. This road will be the main
route into town for the 600 residents of the caravan site for which it is
clearly unsuitable in its present form, especially after dark. The two options
would be to pedestrianise it (In accordance with the Neighbourhood Plan) or to
widen it and include a footway/cycleway and more passing places. Each option
would need discrete lighting. The latter would allow large vehicles down to the
sewage treatment plant
from Lovers Lane and allow residents to safely use this road as a
more forgiving carriageway. As a very
poor alternative, a cycleway could be constructed behind the hedgerow on the Aldhurst Mitigation Site to allow residents to enjoy the
current amenity they have to join up with the (new) bridleway and cycleway from
Sandy Lane as another option to the footway/cycleway above. This could be used
by the workforce and be a safer option than walking in the dark in the middle
of the carriageway. This would be the absolute minimum mitigation for this
option as, whatever is decreed, caravanners will take this route. A review of the
type of lighting required on this stretch of road (or footway) should obviously
be taken in relation to the adjacent wildlife area.
7.9 If the rail option comes forward the loop from Wickham Market to Melton is
welcomed and is essential to ensure the East Suffolk Line (now finally on an
hourly service) is not disrupted in any way by freight (like the Felixstowe
line). This would, otherwise, be unacceptable to all commuters and travellers
who rely on this line. In fact, for little extra cost, doubling the track
between Saxmundham and Woodbridge (on the old track bed) would provide an
important legacy and give EDF Energy more options. A thorough assessment of the impact of long, slow
moving, diesel goods trains on the wider East Suffolk and Liverpool Street line
is essential to ensure that no conflict evolves with the Felixstowe container
traffic and that no passenger service is affected. This was not evident from
the documentation. The studies into the impact of noise, vibration, air quality
and disruption to adjacent properties is noted and welcomed. At this stage
Leiston is protected from these impacts during the anti-social hours and this
must be retained in your policy. The night time movement to the parking area
near Saxmundham still affects properties elsewhere though.
7.10 Abbey
Lane will continue to be an increasingly heavily used rat run. It is
unsuitable for the level of traffic it currently receives and ways of improving it or managing it must be investigated and
implemented. There is no mention of traffic volume impacts
on Abbey Lane in the
presented documentation, either in the Transport Strategy where other lesser
comments have been acknowledged or in the Traffic Modelling section where no
relevant location for study is identified. Leiston Town Council, again,
requests that this be addressed in any future documentation. This could be
the subject of focussed discussions/consultations with EDF Energy along with
the town centre.
7.11 The Household Waste Site on Lovers Lane is a great community asset and an
essential one for this whole area. As a priority, before the traffic
flows increase along Lovers Lane the minimum improvements offered, in
partnership with SCC, must be made to the site to make it safer to use for
everyone’s sake. This should however be escalated
to include a perimeter road around the site to be put in on EDF land so
vehicles enter the site some distance after leaving Lovers Lane – this would
give plenty of space to queue off road when the bins are being serviced (HGV
entrance still from Lovers Lane). If the current situation prevails, even with
the proposed layby, there will be severe congestion and real road safety issues
at this point (as is already the case). The County Council would need to
relicense the site and they could possibly increase the capacity of the site at
the same time.
7.12 Serious consideration should be given to imposing a permanent
40mph speed limit for the length of Lovers Lane due to the large volume of
traffic, the proposed crossings, the site entrances and the other National
Infrastructure Projects coinciding with the project on the C228.
7.13 The maximum by sea route sounded the best
option in theory but is now discounted. The effect of the Beach Landing Facility though, assuming the sea option is not
reinstated, must be studied by the EA and MMO to ease the worries of how this
affects the coastal process. There is concern about the permanence of the Beach
Landing Facility and its potential to become an unwanted groyne.
A comprehensive and transparent scientific observation and analytical package
should be put in place for the years to come to measure any possible effects. The
landscaping and soil levels either side of the hardstanding from North Mound to
the sea will need constant monitoring and maintenance to ensure they do not
detract from the visual amenity or become an obstacle. LTC propose and request that this is
covered in a statement of common ground between LTC and EDF Energy.
7.14 It
is the Town Council’s firm opinion that a roundabout should be installed at
Crown Farm Corner at the top of King Georges Avenue. This would allow Sizewell
A and B workers and residents (from the town) to get onto the C228 easier and
more safely once that road becomes busier.
Workers
7.15 At Stage 2 EDF Energy estimated a “central
case” workforce of around 5,600 workers.
EDF Energy estimated that approximately 2000 of those will be home-based
workers, and 3,600 will be non-home-based workers. On completion of the build
there will be continued peaks and troughs with three reactors undergoing
rolling outages. Stage 3 confirms this and gives more detail on the estimations
based on experience at Hinkley plus a stress test for many more workers than
expected to ensure current plans are adequate.
7.16 Leiston-cum-Sizewell Town Council is concerned
about the potential ‘informal’ car parking that may take place in and around
Leiston and Sizewell. There is a genuine
fear that some workers may opt to drive closer to work instead of using the
‘park and ride’ system. There appears to be an intention to “register” workers
and hold details of their car numbers which is supported and welcomed and may
help eliminate the worse problems. There is also the prospect of houses in
multiple occupation where the number of vehicles will exceed the on street parking capacity in the town. In this instance it
is requested that EDF Energy consider whether the workers could leave their
cars on site and use the bus service to and from work as appropriate.
Buses
7.17 The idea of park-and-ride is a positive one,
which should in theory remove some potential private vehicle traffic from the
roads surrounding Leiston and Sizewell.
7.18 There will however be a lot of bus movements
per day, which is likely to create a constant flow of buses to accommodate the
varied shift patterns. EDF Energy
believes that spreading the workforce shift patterns throughout the day will
avoid network peaks albeit there will be a constant stream of buses on the
B1122 amongst the HGVs if no link road is built.
7.19 It is a fact that buses frequently hold up
traffic and cause congestion. This is
likely to increase congestion on the surrounding road networks, which will have
an impact on residents, businesses, and visitors to Leiston and Sizewell, and
how they get about their daily business.
Air quality monitoring along with noise and vibration monitoring at
pinch points and residential areas along the B1122 must be installed if no link
road is built.
Heavy Goods Vehicles (HGVs)
7.20 Assuming a road led strategy, EDF Energy has
estimated that at the peak of construction there could be up to 200 extra
HGV/bus movements through Knodishall (and onward down Park Hill) and 1,450
extra a day along a Theberton by-pass/link road. The Light Goods Vehicles not
operating under the postal consolidation facility protocols however (350) may
well choose the A1094 which will impact Leiston enormously. The system described to us which will be
applied to all vehicles over 3.5 tons sounds workable and is strongly
supported. HGV’s moving outside the contractual requirements to exit and access
the site must be dealt with. It is essential that the return trips (empty)
should also be regulated.
7.21 As with the issue of buses, HGVs will cause congestion
to the surrounding road networks which will have a knock-on effect to the
residents and businesses of Leiston and Sizewell. Air quality monitoring along
with noise and vibration monitoring at pinch points and residential areas along
the B1122 and in Yoxford must be installed.
7.22 All the junction improvements including
Friday Street and Yoxford are fully supported,
insisted upon and must be completed before the commencement of the project.
Traffic delays due to the construction would be longer and more frustrating for
our commuters should they overrun into the beginning of the construction phase
due to the increased traffic this would bring just exacerbating the problem. The link road is absolutely essential to a
road led strategy and, again, must be completed before commencement of the
project. It is the Council’s view that
this link road is also needed for the rail option as the level of HGV traffic
on the B1122 will continue to be overly excessive.
Noise, Vibration, Dust and Air Quality
7.23 Potential environmental impact is considerable and widespread everywhere you look.
Coastal process, noise, air pollution/quality, flood risk, groundwater
extraction, traffic and of course, disruption and loss of amenity for all the
local residents (to name a few).
7.24 The issue of noise, air quality (including
dust) and vibration in relation to local communities is of significant
importance. It is unclear how operations
at the LEEIE will affect local residents but it is
assumed that the noise and light pollution, in particular, will be significant
and would affect residents up to 1km away. The EIA will be very comprehensive, large and
difficult to understand in all likelihood and the fear is that the
Non-technical summary will be too simple. EDF Energy are requested to
produce something in the middle which details how they will be mitigating and
monitoring all the expected threats to the environment. This should include
air quality monitors at junctions and rail crossings which send an alarm at
certain levels, (for instance), automatically triggering pre-determined actions
designed to ameliorate the threat. A base line must be established at
all the expected trouble spots before construction begins and the limits
agreed.
Overall Traffic Assessment
7.25 It is considered that the steady stream of
additional traffic throughout the days, weeks, months, and years during the
construction of Sizewell C and beyond is going to have a noticeable and
significant impact on Leiston and Sizewell and on residents who commute from
the town.
7.26 Leiston-cum-Sizewell Town Council would
prefer that no Sizewell C traffic passes through Knodishall or Leiston and are
very concerned at the impact on the town centre during the first phase when
access to the site will be through Sizewell B and Sizewell A. They understand
the freedom local workers will have to choose their routing though so it is
very disappointing that our request at stage 2 for EDF to fund a study on all aspects of
traffic movement around and through Leiston has not been done. There is a
serious need for control measures, signage and enforcement to ensure the
correct routes are used and that the town centre does not suffer unduly. Leiston-cum-Sizewell
Town Council also requested that they be involved in these discussions from the
outset as local knowledge (and current issues) are well known. No
approach has been made at all and, again, this is very disappointing.
Dialogue would have at least assured the Town Council that every available
mitigation had been considered and assessed for feasibility. It is
understood that the EDF Transport Team will be looking at this issue after
Stage 3 and LTC would like to be involved in this please. Protocols and
inducements should also be worked out to encourage avoidance of the town centre.
7.27 In
summary, the additional HGVs and buses on the B1122 if no link road built (rail
option), the potential for ‘informal car parking’ in the town, the control of
traffic through Leiston overall and the town centre in particular along with
the noise and light pollution from LEEIE are of particular concern to
Leiston-cum-Sizewell Town Council.
8.0 EDF ENERGY
OPTIONS
8.1 Leiston-cum-Sizewell Town Council has the
following comments to make on the choice of options since the Stage 2
consultation.
Accommodation
8.2 Leiston-cum-Sizewell Town Council still welcomes
the option to incorporate a practical and well-run accommodation complex within
walking distance of the construction site. This will reduce car travel and bus
journeys. The intention to place the sports site in Leiston is also very
welcome. The new road, cycleway and bridleway arrangements look manageable and
safe and provide good connectivity for Leiston residents who take recreation
across the Sandlings beyond Eastbridge.
Other suggestions for enhancements to this PROW scheme are made above, in
particular, a crossing south of Kenton Hills entrance and a permissive path
under the adjusted causeway.
8.3 Sports provision. The proposed off site pitches
and MUGA at Alde Valley Academy and Leisure Centre must be floodlit to
ensure they are useable all year round. It is requested that a further 3G pitch
also be laid at the Leiston Town Athletics Association (LTAA) in Victory Road
(home of Leiston FC) at the same time as a community legacy for the Leiston
Town youth teams – this would be extremely beneficial and much appreciated. It
would allow the numerous youth teams to all take advantage of an improved
training facility – the current field has to be restricted in periods of bad
weather whereas a 3G pitch would allow access all year round.
8.4 As
Sizewell A is Government owned under the Nuclear Decommissioning Authority, EDF
Energy is encouraged to engage with the regulatory authorities to investigate
using as much of the A site as possible for relocation of Sizewell B facilities
rather than desecrating Coronation Wood and the Pill Box field. These
relocation decisions and plans should not be approved or, as a minimum, have a
planning condition, that they not be allowed until the DCO obtains consent if
they do not use Sizewell A land.
8.5 It is
the firm recommendation of Leiston Town Council that the Visitors Centre not be
relocated to Coronation Wood but that it be sited in the town centre as a
tourist attraction much more accessible and visible than on the licensed site.
This would allow much better access as security would not be an issue and any
tours could set off from here, again, with security already concluded. It would
also reduce the number of vehicles going to the site as visitors could be
transported by minibus.
8.6 There will be impacts on Leiston’s
infrastructure as a result of the proposed accommodation campus, which needs to
be carefully considered. The off-duty
workforce will have access to private vehicles and will undoubtedly visit
Leiston for a variety of different reasons.
Currently, Leiston will have difficulty in physically absorbing the
demands of Sizewell’s off-duty workforce, particularly parking. Therefore, the
impacts on Leiston must be fully assessed and understood, a shuttle bus running on a sensible agreed schedule would be useful in
alleviating the parking issue. Enhancements to the current parking facilities,
working in partnership, would also be welcome to mitigate this. (See Annex B)
Park and Ride
8.7 Leiston-cum-Sizewell Town Council supports
both sites chosen for Park and Ride albeit the Wickham market one has some
issues with traffic from the west. This would be the case if the Park and Ride
were further north along the A12 in any case.
There is
legacy potential for the Darsham site to continue to
be used by local people as a free car park for commuting after construction and
this is welcomed. Perhaps some slots
could be allocated for this purpose from day one. At Wickham Market the slip
road onto the A12 just before the reduction to single carriageway will make for
hazardous situations occurring and a solution to this should be sought.
8.8 The Leiston-cum-Sizewell Town Council are
adamant there should be no additional traffic through Leiston if at all
possible. Ways of trying to reduce the predicted journeys through the town must
be investigated and the Town Council would wish to meet EDF Energy before the
DCO to examine local traffic management more forensically– this would cover the
other aspects of Lovers Lane, Abbey Lane and the C228.
8.9 A ‘vehicle number plate recognition’
system must be part of any solution (and we believe this has been promised) and
would be a way to monitor additional traffic in the town over the predicted
levels EDF Energy currently suggests. This would then enable corrective
policies to be put in place to counter the problem through the Community
Construction Consultative Committee (name to be confirmed).
Transport Improvements
8.10 Leiston-cum-Sizewell Town Council has been
considering the options for highway improvements that are currently being put
forward by EDF Energy at this Stage 3 consultation.
8.11 It is noted that any potential transport
improvements must properly consider the emergency services, so that any
potential impacts are understood. The Town Council would therefore support any
responses made by these organisations.
8.12 The B1122 is a vital transport route into the
Sizewell site, and it is considered that it will need some considerable
improvements to be able to continue to serve the nuclear power station well
into the future. The
Leiston-cum-Sizewell Town Council therefore fully supports the roundabout at Yoxford and the Theberton by-pass
proposals as a minimum and a legacy. The
link road option is a minimum for the road led strategy and should also be
included in the rail led strategy as there will still be unacceptable levels of
HGV, bus and car movements along the B1122 during construction under this
option.
8.13 Country lanes and Public Rights of Way that
are affected by any improvements, be it the link road or the Theberton bypass,
must be kept open and accessible. The documentation gives concern that some of
these might be closed off. The existing network must remain useable.
8.13 The link road, should it prove successful,
would be a further legacy if it was retained after construction but there are
concerns about it ultimately then becoming a catalyst for housing growth in the
countryside once the site has settled into the operation phase.
8.14 At Farnham the two-village bypass is welcomed as it creates a safer
junction with Friday Street. This part of the consultation should depend
entirely on the views of the residents affected though and the Farnham
resident’s views must be given primacy in the final decision. However, with
the potential impact of additional movements through the villages of Marlesford and Little Glenham, a four village option is a
minimum for a road led strategy to mitigate the environmental impact at these
locations and the increase in noise during unsociable hours. Every avenue must
be explored to get this option funded as soon as possible. Other incipient NIPs
should contribute accordingly.
8.15 The small adjustments and improvements to the
various junctions are all welcomed.
8.16 A similar exercise must now be done on the
local roads around Leiston to ensure an overarching signage scheme is prepared
to guide traffic clearly to their proposed destinations. This has to include
relevant “do not follow Sat Nav” signs! The Town Council, again, would like to
be involved in this.
8.17 The Town Council are unhappy with the current
siting of the helipad and feel that there must be a more suitable site which
does not disturb the Broom Covert wildlife area more than necessary.
9.0 CONSTRUCTION
PHASES
9.1 Leiston
Town Council is very concerned about the proposed operations during Phase 1 of
the construction. The increased useage of the C228
will cause disruption and congestion along the only access to SZB and SZA and will
make cycling and walking uncomfortable or even undesirable. The entrance to the
proposed site from the B1122 should therefore be a priority, followed by the
Access Road and the SSSI crossing. The commencement of works to the foreshore
should not be undertaken until these are in place and other operations where
spoil has to be removed should also wait until this access is complete. The
adverse and severe effects of using the entrance to Sizewell B for anything
other than works to help accommodate this must be avoided. Every effort should
also be made for the wider transport infrastructure links and signage to be in
place before Phase 1 commences. It is appreciated that the timeframes for this
may well mean they overlap but this will hinder EDF work and the local
population to an irritating and unfortunate degree. Please continue to note the
demand for there to be no access to the frontage of the site from Sizewell Village.
10.0 EVIDENCE
10.1 These representations have largely
concentrated on localised amenity impacts and traffic impacts that will be
associated with the proposed development of Sizewell C.
10.2 It is unclear and difficult to understand
just how much impact the soil removal and borrow pits will make on the visual
impact of the site. It is expected that the County Council will comment more
fully on this as well as the Environment Agency as, with minimal understanding
of the environmental consequences, Leiston Town Council would support any
concerns raised by these agencies.
10.3 The Environmental Agency must be very clear
that the proposals will not in any way affect the natural flow of the Leiston
River or the operation of the Minsmere Sluice (including interfering with the
coastal process via the emerging BLF proposals). There should also be an
undertaking from EDF Energy to pledge resources into ensuring that the outflow
from the Leiston Water Treatment Plant will always be maintained to its current
level so that no back up or flood problems occur in the future as well as
becoming responsible for the sluice and outlet there as any coastal process
which affects these will undoubtedly be due to the works at SZC.
10.4 The overall land-take of the laydown site has
reduced marginally from stage 2. With
the experience of Sizewell B, Leiston-cum-Sizewell Town Council would suggest
that some temporary uses will last longer than the 10 years envisaged, some closer
to 20 years. Further information on the
temporary uses is therefore also requested with a clear timetable for
decommissioning. It is also difficult to envisage where the new line is to the
east of the site without accurate mapping. It does look as though the whole project
is beginning to encroach unacceptably beyond this onto the beach. In line with
the frontage of Sizewell B must be the minimum encroachment. The height of the
defences has also pushed them eastward at the bottom. These will be fenced for
many years to come to allow regrowth so a footpath close to the top of the
defences could be incorporated into the design to allow for sea level rise and
weather scouring across “the recreational corridor” to the bottom of them.
10.5 Leiston Town Council understand EDF Energy
are in discussions with Essex and Suffolk Water and that there are no problems
in them delivering enough potable water. The EA and The Local Flood Authority
will be responding and liaising with EDF Energy on the use of water and run off
etc. and Leiston Town Council would support their recommendations on these
aspects. Issues of drainage and run-off
highlighted by the Minsmere Levels Stakeholder Group (of which the Town Council
is a prominent member) must also be addressed.
11.0 CONSULTATION PROCESS
11.1 This further stage of consultation was
necessary and welcome. It added a lot of detail and firmed up some of the
options to allow more critical assessment. Before
moving onto Stage 4 however the Town Council would welcome additional talks
with EDF Energy to discuss the responses from this stage and to also be
included in any discussions as they set out their preferred direction of travel
to address them. Any workshops or discussions with East Suffolk District
Council (ESDC) and SCC should, as a courtesy at this stage, now include an
invitation for Leiston to have a representative present. This request was
ignored at Stage 2 and it is dispiriting and frustrating that no attempt was
made to engage with members on virtually any of the issues requested in the
last two years.
12.0 CONCLUSIONS
12.1 Leiston-cum-Sizewell Town Council cannot
support the proposals for a further nuclear power station at Sizewell until the
impact on amenities, environment and traffic are resolved satisfactorily in
relation to Leiston and Sizewell. It is looking increasingly probable however
that the use of this limited site is too
ambitious and would ultimately be wholly detrimental to the surrounding area.
Is the negative impact greater than the benefits the project brings? There is low unemployment in the immediate
area so short term jobs at the construction site will be at the expense of long term sustainable jobs in the tourist industry which
will be severely affected. There will be new unsightly pylons in the AONB. The
affects on the Coastal path are unquantifiable at this stage but will be
severe. The socio-economic uplift to the area and businesses will be
substantial and welcome. Training and skills could be of benefit if liaisons
are established in the town and, trying to look past construction, EDF Energy’s
proven stewardship of the countryside has been beneficial to the area after Sizewell
B.
12.2 Impacts on the beach, public rights of way,
and areas of local, regional and international importance from a heritage and
environmental perspective, must all continue to be fully and appropriately
considered. The current suggestions are
the minimum and must continue to be part of the proposals.
12.3 Issues associated with previous developments
at Sizewell, including the loss and restrictions on public rights of way, and
anti-social issues associated with such large scale
development, must all be correctly addressed.
12.4
There is a worrying lack of detail,
particularly in areas that affect the centre of Leiston, especially the traffic
bleed from the major routes. The traffic and increased population in Leiston
Town Centre, especially during the early construction, will significantly affect
residents and the community. A comprehensive package to investigate, manage and
alleviate this must be agreed with Leiston Town Council.
12.5 It should be noted that there will be spent
nuclear fuel stored on this site for the lifetime of the station (and probably
beyond). This is a long term blight on the Parish of
Leiston-cum-Sizewell.
12.6 The maximum transport infrastructure options
need to be provided to alleviate the east Suffolk road network as much as
possible. The lead in and first two years of the construction phase will leave
infrastructure that will have to serve a growing population in this area for years
to come. Getting it right first time and
to a high standard will be of clear benefit to everyone.
12.7 Overall, it is considered that, with the
appropriate mitigation set out here, the options supported in this response are
the best for Leiston-cum-Sizewell and should continue to be refined and
negotiated with this Council to allow a fruitful and beneficial partnership to
go forward for the years ahead if Sizewell C gains Secretary of State approval.
APPENDIX
A
Leiston-cum-Sizewell Town Council – Immediate and Long-Term Community Requirements.
It is believed that this project is of
such a scale and is of such national significance that the normal criteria for
Section 106 considerations is not sufficient to compensate the Parish of
Leiston-cum-Sizewell for hosting and accommodating the vast majority of the
disruption and inconvenience that will accompany the build. The long-term
legacy of an access road across the AONB, a large prominent industrial complex
on the heritage coast, also in the AONB, plus the plans to store spent fuel in
the Parish for an indefinite period are also factors that need mitigation
through various immediate compensatory measures and a long-term community fund.
The Town Council appreciate that the
legal framework for such matters will be through the Principal Councils but would request that strong support be
shown by EDF Energy for Leiston-cum-Sizewell’s aspiration for a certain
percentage of any long-term community fund to be protected and earmarked for
post code IP16 in which the whole of the works will sit. The Town Council
is willing to administer any local fund should that be considered a better
alternative and is comfortable with, and constituted for, a legal agreement to
do so.
Appendix B covers the town centre and
the issues of traffic and community facilities required for the construction.
This sets out an approach that EDF Energy may find more appropriate, localised
and holistic to help them deal with many of the Town Centre issues being
identified.
The other, more specific, items on the
wider scheme that require mitigation measures which would help alleviate the
impact of Sizewell C and meet resident’s needs are summarised below.
Required Mitigation Measure/Community Benefit |
Why it is required? |
|
|
Include a crossing for
cyclists/walkers on Lovers Lane 50m south of entrance to Kenton Hills. |
The proposed cycleways around the
Aldehurst Farm Habitat site need a link to the Kenton Hills Walk away from
the Laboratory corner which would be unsafe. |
Enhance existing cycle path along
C228. See paragraph 9.1 |
The new cycle path proposals (for
Stage 3) are welcome and essential along the B1122 and Lovers Lane. The current cycle path to Sizewell needs
refurbishment and strengthening as it will be an essential facility during
the first two years when the C228 takes all the construction traffic. |
Improvements to Valley Road (East) aka
Kemps Hill. See paragraph 7.8 |
When the caravan Park and
laydown/temporary railhead north of Crown Lodge are constructed this section
of Valley Road needs to be either two way or have a dedicated
cycleway/footway put in alongside the existing narrow track for pedestrian
safety. This would be a very useful
legacy project that would benefit the town enormously and allow EDF workers
to walk safely to town. If, widened and upgraded it would allow HGV tankers access
from Lovers Lane to the sewage treatment plant (as a further legacy). |
Highway low noise resurfacing from
Highbury Cottages to White Horse Corner and through Knodishall all the way to
Kings Road in Leiston. See paragraph 7.5 |
Mitigation for the huge increase in
private and white van traffic expected through these two entry routes,
especially during the first two years. The noise from the poor surfacing at
the moment is annoying and further increase in traffic would make it very uncomfortable,
especially at night. |
Strengthen the beach track that the
Nuclear Constabulary use from Sizewell Gap to Sizewell C site. Current issue. |
This will protect the dunes etc. from
further erosion and is work that currently needs done. The police will be
more vigilant during construction one presumes and use it more so a small
investment now would be very useful. (Notwithstanding a written agreement
that this will not be used for Sizewell C work of any sort.) |
Engage with the Leiston Works Railway.
Consider a future station. Ongoing
community engagement Provide
a 3G pitch at the LTAA in Victory Road to enhance and secure training
facilities for the numerous youth football teams that are parented by the
Leiston Footbal Club at this location. Para 8.3 |
Engagement with the industrial
heritage of the parish by becoming involved with the Leiston Works Railway
Project and looking at ways to possibly leave an impressive legacy from the
rail works proposed for the construction. A Passenger service could be
re-instated after construction with a station on LEEIE – useful for outages
with residual Park and Ride facilities left at Wickham perhaps. This would be
an ongoing item and something to investigate. The proposed off-site sports
facilities at Alde Valley Academy would, most probably, have to be reserved for SZC staff
and workers for the majority of the day. The provision of another facility at
the LTAA would allow young people to enjoy similar facilities at all times
and be able to train and play throughout the year. |
Support for a small ambulance station
at the Fire/Police station in King Georges Avenue. Para 5.3 |
To protect response times to IP16 once
construction and construction traffic increases congestion on routes to
Leiston. |
Establish/support a training and
skills centre in Leiston Para 5.5 |
In partnership with Suffolk New
College (on the Coast). An important legacy but much needed
for vocational training during the build to increase local skill base. |
EDF Fund a comprehensive and traffic
survey around Leiston |
There is no baseline which the inevitable
and unquantifiable (at this time) increase in traffic through the narrow and
restricted town centre of Leiston can be judged. A study needs to be done to
ensure this can be accommodated and ameliorated properly. |
Install evidential quality CCTV
(unmonitored) in town centre, on King George Avenue and on Valley Road. Community and worker safety. |
This is for the safety of residents
and workers alike. |
Replacement of the Dinsdale Road
Toilets with a modern facility that could remain open 24/7 (currently closed
at 6pm). See paragraph 6.4 |
Small but important item retained from
Stage 2. To help meet the needs of an increased resident, worker and visitor
population. This is the tourist and transport hub of the town and centre of
the night time economy. It would be essential for EDF workers as well as
residents. |
A permissive path be provided from
Kenton Hills to the beach under the access road/three span bridge as soon as
possible. See paragraph 6.2 |
The access to the Minsmere levels
along the beach will be ugly and difficult. The current access to the beach
from Goose Hills is a major asset and allows the RAMSAR, SSSI and AONB to be
fully enjoyed. |
Household Waste Site on Lovers Lane
realigned and enlarged See paragraph 7.11 |
Road Safety. A road around the current
site to allow traffic to queue off road is essential. A layby is not enough
and would not work well. |
Substantial walkway to be laid across
the shingle during initial beach works and for duration of construction. See paragraph 4.7 |
To allow less
steady residents to negotiate the Coast Path. |
A shuttle bus into town from the
campus and the implementation of a strict drug, alcohol and acceptable
behaviour policy. See paragraph 5.7 |
To alleviate anti-social behaviour and
to allow workers to enjoy the night time economy responsibly. |
Double railway track from Saxmundham
to Woodbridge Para 7.9 |
A better alternative to the proposed
passing loop and a major legacy. |
Leiston Town Council and other relevant
bodies form a “Construction Consultative Committee” with EDF Energy at the
outset of this project to meet regularly and have executive powers to help
the project run smoothly as issues are identified. Para 5.7 |
It was an essential body during the
SZB build and should be repeated for SZC. The Town Council played a major
role in forming its remit and determining its Agenda to quickly address any
issues affecting the local residents and visitors etc. |
APPENDIX B
LEISTON
TOWN CENTRE
IMPACTS
AND PREFERRED MITIGATION WITH REGARD
TO
SIZEWELL C PROPOSALS
Introduction
1.
There are several elements to the proposals presented at stage 3 of the
EDF Energy consultation for Sizewell C that give cause for concern. Appendix A
summarises the majority of mitigation measures sought for the wider parish area
but it was felt necessary to try and establish a more robust and far reaching
solution to the problems that will be faced in the town centre itself. The
initial paragraphs below are carried forward, repeated or summarised from the
main response to enable this Annex to be viewed separately.
2.
The most immediate is traffic and how cars and vans will access the
construction site and the Land East of Eastland’s Industrial Estate (LEEIE) in
the early years of construction.
3.
Concurrent with this is the expected popularity Leiston will have
amongst the workforce for shopping, recreation and entertainment.
4.
Both of these issues will have a major impact on residents and visitors
when measured against the current (2019) baseline.
5.
These immediate impacts will be felt over and above the other town
centre issues noted in our main response of
· Housing – young residents
seeking private rental accommodation. This is currently reasonably priced but
could become difficult to find and more expensive as workers find a base near
the site.
· On street parking pressure
from Houses in Multiple Occupation
· Town Centre parking – for
workers, residents and visitors alike will become problematic
· Labour market – will be
distorted
· Commuting – roadworks and
increased traffic will make this more difficult for residents working outside
Leiston
· Night time economy – albeit
this could be extended by shift patterns to daytime too. It is anticipated that
this will be much better than when Sizewell B was built but the increase in
numbers and the ease of perpetrating anti-social behaviour will make the town
centre less desirable for many residents and potential visitors.
6.
The number of workers, the perceived potential for antisocial behaviour
and the squeeze on parking will possibly affect the evening custom at the Film
Theatre although this could be offset by the number of workers who might take
advantage of this facility.
7.
Overall, Leiston-cum-Sizewell Town Council is very concerned about the
change of tempo, rurality and amenity that its 6,000 residents currently enjoy
in this genteel market town.
Evidence
8.
There are currently no studies that predict the number of extra journeys
that would transit to Sizewell C through the town centre. There are no
baselines in the presented documentation either. The traffic increase
experienced during an outage gives an indication of the gridlock that can be
expected to occur and the first thing that needs to be done is to gather
evidence of the current situation.
9.
It is clear, even over and above anecdotal submissions, that many
workers, coming from outside Leiston before the Park and Rides are established
will be tempted to avoid the trek down Abbey Road to Lovers Lane and will
choose to go straight through town. The bleed from the predicted journeys in
the presented documentation (for Waterloo Avenue and through Knodishall) will
be substantial too.
10. The town centre suffers
from narrow pavements and an inconvenient set up at the town centre crossroads
which increases waiting time at the traffic lights. The pavements around this
area are only just capable of being navigated by a push chair and wheelchair users are
particularly disadvantaged by the lack of width, exacerbated by the street
furniture needed for the pedestrian crossings.
11. An increase in traffic
through the centre will increase air and noise pollution and inconvenience
residents and tourists alike.
12. The High Street Car Park is
an essential facility for the Film Theatre and, being free after 6pm, is
invariably full each evening. The introduction of a 2 hour
enforceable car parking limit in the Co-op car park has not helped albeit one
can now, generally, find space there when the store is open to shop. There are
no other convenient car parks in the centre and the on street
parking is at capacity.
13. The Library has three
computer terminals for residents and visitors to use (and print from) and these
are all, generally, fully booked each day as job hunting and universal credit
(and other services) require internet access and submission these days. It is
hoped to be able to increase this for residents and visitors by moving premises
and increasing space and availability.
14. Ambulance response times
have been castigated by our MP and Leiston Town Council have, over many years,
lobbied and engaged with the ambulance to try and improve them for IP16. It is
the rural situation of the town and the distance from the A&E that,
combined, would require substantial investment in people and equipment to give
the necessary ability to confidently respond in time. The congestion on access
roads from Ipswich caused by Sizewell C will exacerbate this.
15. The tourism offer that
Leiston has, and is currently seeking to extend, revolves mainly around the
historical setting and the industrial heritage that has shaped its expansion.
Leiston Abbey will be less accessible with the congestion that area will see
during construction and it will be a challenge to attract visitors to the
centre to experience the tranquillity of the Old Post Office Square on Main
Street and the Long Shop Museum.
Proposals for mitigation and partnership
working
16. In our stage 2 response
Leiston Town Council lobbied for support for the proposed regeneration of
Leiston Town Centre as was then being drawn up in a Neighbourhood Plan. This is
now complete and has been adopted.
17. Since stage 2 great strides
have been made and a very fruitful partnership has been formed which operates
under the banner of Leiston Together.
This is a collaboration of the County, District and Town Council along with
the Leiston Community Land Trust, Leiston Business Association, the Alde Valley
Academy and Community Action Suffolk. It looks at various initiatives
but its main aim is the careful and appropriate regeneration of the vast
redundant land in the Town Centre behind Sizewell Road.
18. The main lead in this
venture is the Leiston Community Land Trust. Since stage 2 they have become a
constituted body with 130 members from the community, 7 of which are on the
board. Leiston Town Council has a representative on the board but encourages
the independent and entrepreneurial work the CLT are doing. Currently they are
in discussions with housing associations to establish a partner for housing
aspect of the project.
19. The District Council has
purchased a large section of land needed for the project and the CLT, working
with Suffolk Libraries and Leiston Town Council are working with them to help
develop the civic element of the project. This would be to open an area for a
small market and town square, build civic offices and a library around this (as
well as other commercial aspects)
20. The elements that would
help mitigate Sizewell C impacts are
· Increase size and provision
of the library for residents and workers benefit through relocation as part of
the town centre project
· Possible relocation of the
job centre from an industrial estate on the outskirts back into the town centre
next to the Library for ease of use (much more use expected once construction
starts)
· Relocation of the Town
Council offices incorporated into a modern, community friendly hub
· Possible relocation of
Citizens Advice to be more central position and integrated with the hub
· 24 hour toilet provision and a much
needed increase in parking provision
· Traffic management
commensurate with the predicted use
21. The regeneration needs to
consider various options for town centre realignment and traffic control which
would allow the centre to be more pedestrian friendly, discourage through
journeys, attract visitors for dwell time and increase parking. All these
options could form part of the structural, economic and environmental
regeneration plan currently taking shape.
22. To achieve a coherent,
vibrant and attractive town centre, partnership working
and substantial funding will be required.
23. The District Council have
the land, the CLT are working on the housing aspects of the scheme with Leiston
Together and are also looking at how to seed the civic project in conjunction
with this.
24. It is considered by Leiston
Town Council that a financial commitment from EDF Energy toward this project
and any highway improvements would be considered a major socio-economic
mitigation for the cumulative effects in Leiston that will be felt over the coming
years. They would also like to see EDF Energy seek to become a partner in
Leiston Together on this basis to take part in the regeneration and be a
stakeholder in Leiston for the years to come.
Conclusion
25.
Separate from the specific and material mitigation requests at Annex A
it is strongly recommended that EDF Energy invest a proportion of their
proposed Community Fund in the Leiston CLT. EDF Energy representation on the
board would be most welcome to reinforce the relationship between Leiston and it’s closest significant and long term
neighbour and would give it an oversight of its investment. This would help
support the town centre’s ongoing management and regeneration and provide a
major contribution to the mitigation and compensation needed to alleviate the
effects of this long term project on the town.