Suffolk Wildlife Trust fears that Sizewell C’s development could lead to a wide variety of adverse impacts, from bats and reptiles being affected to water levels being changed in sensitive habitats and coastal processes being disrupted.
And a recurring theme in its response to EDF Energy’s Stage One Consultation is that more ecological surveys and assessments need to be carried out beyond those so far undertaken on several aspects of the proposals, such as the rail link options and borrow pits created during construction work. Some of the surveys related to an earlier proposed footprint for the development which was smaller than that currently proposed, it says. “We therefore consider that many of the surveys so far undertaken are geographically limited and do not adequately reflect the proposed permanent and temporary development site. It is imperative that the scope of the existing survey work is reviewed and that further surveys are undertaken where gaps in the data are found.”
Insufficient evidence had so far been gathered, for example, on how the current proposal would affect bat populations and there were fears that the impact on them would be “very high”. A “wide range” of bat species had been recorded on the “wider landscape of the Sizewell C site” with foraging and roosting areas, and there were “particularly notable” roosting sites for barbastelle bats. There was also “a very high possibility” of maternity sites for several species, including barbastelle and Natterer’s bats.
The main development site supported “exceptional populations” of adder and slow worm and “good populations” of common lizard and grass snake. For these, a “comprehensive mitigation strategy will be required, but this needs to go further than simply the identification of suitable receptor sites.”
The trust was also concerned that deep excavation and “dewatering” required for construction “will lead to an impact upon groundwater levels and hydrologically sensitive habitats.”
Fears over the impact on marine ecology, the existing coastline and coastal processes are also expressed.
Of the workers’ campus options, the trust says all three “have the potential to result in significant environmental impacts, particularly through increased lighting levels and the disposal of foul water drainage.”
It adds: “Irrespective of which option is eventually selected it should be ensured that the scheme is designed so as to ensure that adverse impacts are minimised to the point where they can be considered insignificant.”
A spokesman for EDF said: “The Sizewell C New Nuclear Build team were pleased to provide an update on the project at the community forum in April.
“During this meeting the team explained that the focus of work this year will be around completing a detailed analysis of nearly 1300 responses received at Stage 1 consultation and progressing some of the essential studies for the project. Each issue raised is being considered and recorded and will be used to help EDF Energy develop detailed proposals which will be subject to a further stage of consultation.
“The Sizewell C team will continue to engage with consultees, including organisations such as Suffolk Wildlife Trust, in between the stages of consultation.”
Fears for species and biodiversity
County wildlife experts have compiled a catalogue of concerns over the serious impact the proposed Sizewell C nuclear power plant would have on biodiversity in a sensitive, treasured and internationally-acclaimed area of the Suffolk coast.
Scarce and protected species and important habitats would be put at risk by the massive, years-long construction programme planned by EDF Energy – and part of a Site of Special Scientific Interest (SSSI) would be lost for ever, they fear.
The warnings come in a detailed document drawn up by experts at the Suffolk Wildlife Trust who say there are “shortfalls” in ecological surveys so far carried out on behalf of the energy giant.
They are calling for a host of more detailed surveys to be carried out on many aspects of the construction’s ecological impacts, both within the vast proposed development site and beyond.
They want to ensure the maximum amount of mitigation is carried out and are calling for a new like-for-like habitat to be created in compensation for the loss of the SSSI – but on a scale far larger than the area that will be destroyed.
A formal, painstakingly prepared trust response to EDF Energy’s Stage One Consultation, the firm’s “Initial Proposals and Options for Sizewell C”, has been submitted by the wildlife charity. It is the result of an extensive trust team effort, with major input from several staff members, particularly conservation planner James Meyer, although it is formally submitted by the charity’s senior conservation adviser and consultancy manager Dr Simone Bullion.
It is forthright and forensic in its approach but trust officers are also keen to stress their willingness to work with EDF Energy to secure the best possible outcome for the area’s wealth of wildlife and its renowned biodiversity.
The trust response says: “This stretch of coastline and its associated habitats are located in a wild and relatively undisturbed part of Suffolk. This project is particularly notable for the sheer size of the scheme within an ecologically important landscape.
“We estimate that the main development site will occupy 305 hectares, of which 50 hectares is the power station itself and this figure excludes other proposals such as the campus and offsite infrastructure. Development of this scale in such a sensitive location will have major impacts upon biodiversity. It is therefore essential that the Sizewell C proposal is viewed as unique and this approach must underpin all stages of the consultation process. If consented, the project must not only address biodiversity losses, but also deliver a significant package of ecological benefits to ensure that the project is an environmental exemplar.”
Although a “significant amount” of survey work had been carried out to evaluate the ecological value of the main development site, the trust says there are still “shortfalls in the evidence base which need addressing.”
In addition, “there is very little information provided on how these ecological issues will be avoided, mitigated or compensated.”
One of the major issues highlighted by the trust is the impact of the development on the Sizewell Marshes SSSI. Although EDF Energy’s consultation document indicated that 6.4 hectares would be “disturbed” and 4.6 hectares “removed permanently” an illustration in the document indicated that the “full 6.4 hectares would be lost or irrevocably damaged.” The trust says: “We are concerned that there is no justification for the case for two nuclear reactors and the consequently larger land-take and environmental damage.”
It adds: “Furthermore, no details have been provided on how this loss will be compensated for, such as the size and location of replacement habitat. As a minimum, we consider that any new habitat should be part of the same ecological network of the area, fulfil the same conservation objectives and also be at least three times the size of the area lost.
“In addition, new habitat needs to be created in advance of any losses, fully funded in perpetuity and a comprehensive long-term monitoring programme will be required to assess the success of the habitat creation scheme. If the monitoring indicates that the biodiversity objectives have not been met fully, then this issue must be addressed by a contingency built into the compensatory package.”
Trust chief executive Julian Roughton told the EADT the charity had established a “good working relationship” with EDF Energy during its management, on behalf of the firm, of the Sizewell Marshes SSSI, part of the designated Sizewell Levels and Associated Marshes County Wildlife Site and part of the Southern Minsmere Levels County Wildlife Site. It was keen to continue the close relationship and would work with EDF Energy to secure the “best possible outcome for Suffolk’s wildlife” but it needed to maintain its “credibility” and independence and it held “genuine concerns” over the Sizewell C proposals as they currently stood.
EDF Energy said: “The Sizewell C New Nuclear Build team were pleased to provide an update on the project at the community forum in April. During this meeting the team explained that the focus of work this year will be around completing a detailed analysis of nearly 1,300 responses received at Stage One Consultation and progressing some of the essential studies for the project.
“Each issue raised is being considered and recorded and will be used to help EDF Energy develop detailed proposals which will be subject to a further stage of consultation.
“The Sizewell C team will continue to engage with consultees, including organisations such as Suffolk Wildlife Trust, in between the stages of consultation.”
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