The RSPB has put out a short, very careful press statement and a much longer and, we think, very important statement. The focus of concern is natural water availability and levels, coastal erosion on Minsmere’s frontage and direct disturbance for bird habitats, mentioning marsh harriers, and species of waders and waterfowl. The last line is that the Stage 2 information provided about coastal defences and coastal structures by EDF is “not detailed enough” to give confidence “that damage will not occur to Minsmere’s coastline”.
Their long response - 13 pages - concludes, like the local councils and SWT and others, that the level of information provided by EDF is not sufficient to judge impacts, that mitigation measures are not identified for assessment, that there is no commitment to best environmental standards or full considerations under Habitat regulations. Further, that the SSSI damage, and its increase in size, and the compensation project at Aldhurst Farm are of great concern, in part because of disturbance from the main site layout, transport and the off-site developments. It ends with string of concerns about tourist accomodation and “changes to character” on the Minsmere reserve. It is all cautiously worded, but it is comprehensive and targeted, awaiting the EDFE Evidence Plan (for the Environment Report), demanding full details of assessments on plan features and clearly disappointed.
The response makes clear that the RSPB nationally are not supporters of new nuclear power. Their opposition to government nuclear policy at the time of the original policy debate was not successful, so they argue that the battle to defend Minsmere must now take place within the terms of the planning process and regulatory standards. So, like the Suffolk Wildlife Trust, they are now probing the precise meanings of the duties of the national planning body in relation to the “mitigation hierarchy” of “avoidance, mitigation and compensation” and whether this applies to single issues in the project or the whole project etc. They also indicate that any damage to an SSSI needs to be seen as a challenge the whole category of SSSIs across the UK, so that it is not just local issue. There is overall a meticulous targeting of environmental impacts, and rejection of EDF’s offer to do only what is “practical”. They say this does not meet regulatory requirements.
Suffolk Wildlife Trust have got off the fence after four years of the most minimal public concern and assumption that the project’s nature issues can be dealt with. This is certainly how many people have seen their stance to date. Now, despite their closeness to EDF, they have produced a good, lengthy and professional response. Lots of worries, well worth a read. They follows RSPB concerns, and express overall “serious disappointment” at Stage 2. They appear to be questioning whether the mitigation hierarchy is a simple sequence, or whether each stage has to be be proven by assessment in its own right. What this means is that EDF offering compensation for damage to SSSI’s and other protected sites may not be a proper - lawful? - response. Proof that there is no alternative site design or other project solution has to be demonstrated first. Also, like the RSPB, they question EDF’s notion that mitigation measures can be avoided because they are not “practical”. Both the RSPB and SWT now seem to be saying between the lines that the project is not possible at this site without unacceptable damage to nature. It is not flag waving, but it is a very serious position to take up within the terms of the planning process.
The AONB next. Well, having agreed a big “landscape criteria” document with EDF just before the Stage 2 consultation, they nevertheless - and very obviously - feel put out that the AONB’s interests don’t get much status or respect in the EDF report. Worth a read too. Both the RSPB and SWT note that national regulations require the defence of AONB status in general as well as at Sizewell. This view echoes the arguments above about the SSSI’s status. Clearly these three bodies fear a domino effect if EDF aren’t held to high account here and now.
The Anglian angle? The East Anglian Daily Times occasionally does a useful job reporting nature and environment developments, devotes a lot space to the culture of nature, but in the main backs EDFE and avoids the policies and politics of the Sizewell threat. However, their recent editorial calls for “transparency and talking” recognising that something is stirring. But it won’t step out of line. We further quote “the prize (of Sizewell C) is too great to let slip away”. And “our local economy will be grateful for generations”. That begs lots and lots - if not all of the questions. So yes, lots more transparency and reporting including on the downsides, and hopefully also “talking”. And listening too. And publishing more letters opposed to Sizewell C on grounds that carry some weight of argument as well as principled positions. Transparency and talking are all part of proper public debate, so watch the Anglian carefully. Meanwhile it should be noted that EDF does not engage in debate, as a matter of policy. Only presentation, and well, very unsatisfactory consultation.
TASC (Together Against Sizewell C) are opponents of the Sizewell C project. Their evidence is very well informed about the range of local impacts, especially on the Leiston area and focussed on those which violate nature protection and amenity regulations. They cover the full range of EDF Options issues. TASC have successfully established the idea that Suffolk is not “suitable” for this project, a reflection of the formal planning criteria which are supposed to operate.
Friends of the Earth Suffolk have produced cogent evidence with a particular stress on shore line flooding and water level issues threatening wildlife and habitats. They are principled opponents of nuclear technology, have been doing water level and coastline research and pursuing nature protection issues, arguing that the vast “mosaic” of nature habitats affected face catastrophe.
TEAGS, representing villages and residents around the prescribed B1122 access road to Sizewell from the A12 have sent in a professional and detailed response. Their press release expressed strong and prolonged anxiety, and “slamm(ed) EDF for ignoring local concerns”, and “expressed profound dismay”. While having local concerns and not being opposed to the nuclear project as such, they have broadened their concerns to the social effect of the worker campus and the threat to Minsmere. Their evidence reflects a common theme of concern that EDF have not completed assessments or justified positions or released information. Most importantly for them, EDF have no mitigation strategy of any significance for the huge traffic impact during the construction period, and seem to have downgraded the B1122 impact. Nor is there any credible solution to the double road junction problem at Yoxford. TEAGS continue to cooperate with the B1122 Group and the Minsmere Levels Stakeholder Group and mounted an impressive exhibition.
The B1122 Group continue to campaign for the D2 road idea, coming off the A12 below Saxmunden and going across country direct to Leiston and Sizewell. This is not a widely supported idea, is firmly rejected by EDF, and regarded as unrealistic by the two Councils. It would not resolve the four villages problem on the A12.
SAGE will be looking at Yoxford’s response, after their lively meeting addressed by SCC Councillor Guy McGregor who produced the joint Council’s report. Wickham Market, with a Park & Ride on the A12 and their cross Suffolk access roads, are angry at the forecasts of a huge volume of traffic which they have had to dig out of the EDF report. CANE, the Campaign Against Nuclear Energy, a long-standing local group, have also submitted a response. The Minsmere Levels Stakeholder Group’s views are being sought too. The SAGE response is already on our website.