Caroline Waller on behalf of Fairfield Estate (Lady Gass)
"We act on behalf of the Fairfield Estate (owner Lady Gass) whose property immediately abuts the existing Hinkley Point nuclear complex. The Estate also includes land on which the proposed development is to take place. Whilst the Estate does not object to the principle of the development, it is concerned to ensure that the need for the development does not eclipse a careful consideration of the detail of the application to ensure that the layout of development is the most efficient use of land and most appropriate that can be achieved in this location and that all possible steps have been taken to minimise the impact of the development on this sensitive area. These representations are intended to be a brief summary of the objections of the Fairfield Estate. Further detail will be provided at the written representations stage and at subsequent hearings (as appropriate). The principal issues of concern to the Fairfield Estate are as follows: 1 Any powers granted pursuant to the DCO should be synchronised with any existing consents or permission and made subject to the same controls/conditions/restrictions and obligations. 2 The restoration of the site must be secured in the event that the DCO is granted and technically implemented but not proceeded with or the site left partially developed for a significant period of time 3 Given the significance of the Landscape and Visual Impacts which are likely to be caused by the proposed development, adequate landscape screening and mitigation must be secured both during the lengthy construction phase and during the operational phase of the development. 4 The prompt removal of any temporary structures or works must be secured and (if appropriate) the site of those structures or works must be reinstated to an appropriate standard (such reinstatement to be secured through obligation or requirement supported by financial security) 5 There must be controls on: 5.1 noise during construction and operation of the project or in relation to the dismantling/demolition of temporary structures/works and the reinstatement of the site 5.2 Dust 5.3 Lighting 6 The timely and effective decommissioning of the station at the end of its useful life must be secured 7 Maximising the use of sustainably located unused or under-used sites in Bridgwater to accommodate workers should be maximised and the numbers to be accommodated in the on-site Campus should be minimised with the number of workers to be accommodated on site to be limited to those necessary for emergency and security cover 8 Enforceable measures must be secured to minimise the impact of the development on the local road network including preventing traffic using the lanes which go through the hamlets of Burton and Shurton or the village of Stogursey and ensuring the early completion of the Cannington Bypass. 9 NNB Generation Company Limited ("NNB") should demonstrate that adequate strategies for the storage and management of Waste have been put in place. The long term storage of waste should not be left to the uncertainties of facilities potentially becoming available in the future. These issues are set out in more detail below. Site Preparation Works 1 General 1.1 The site preparation works (SPW) have been the subject of a specific planning application. The application has been considered in detail by the Local Planning Authority and the s.106 Agreement has been agreed (following a long period of careful negotiation). It is anticipated that the Local Planning Authority will have issued the planning permission for the SPW by the date that these representations are submitted. 1.2 When the DCO application was made, the SPW permission was anticipated but had not been granted. Now that the SPW permission has been (or shortly will be) issued, any powers granted should be synchronised with any existing permissions or consents and made subject to the same controls, conditions, requirements or obligations.. Failure to do so would result in confusion. For example, it may be unclear whether the Order or Permission has been implemented and, therefore, to which the conditions, requirements or obligation the development will be subject. 1.3 Further, it is in the public interest to allow the democratically made decision of the Local Planning Authority to stand. There must be a strong and compelling justification in order to depart from what has been decided and agreed in the context of the planning application. 2 Landscape and Visual Impact 2.1 The site preparation works (SPW) comprise fencing and large scale earthworks to form level construction platforms and haul roads on the north western side of the HPC development site in an elevated location where they will be prominent in relation to adjoining land within Fairfield Estate. 2.2 The adjacent area is high quality landscape. It was evaluated by Natural England in 1986/7 as being of outstanding scenic, historic and scientific interest and extends into the Quantock Hills Area of Outstanding Natural Beauty. It contains several well used public rights of way (PRoW) including part of the long distance South West Coast Path. This landscape is of national significance and is referred to hereafter as the ‘heritage land’. 2.3 The SPW may represent the only opportunity to implement landscaping measures to mitigate the adverse impacts of the development until such time as the development has been completed (i.e. during the lengthy construction phase). Should the IPC reconsider the SPW, the landscape mitigation proposed for the construction phase of the development should be improved. 2.4 NNB propose to mitigate adverse impacts on views from the heritage land during the SPW with a temporary bund of varying height which will not screen views effectively leaving the construction activities visible from extensive areas of Fairfield Estate and the surrounding landscape. NNB’s proposed planting using predominantly small deciduous stock (80-100cm high) would not provide effective screening for several years in this coastal location. 2.5 The Landscape Strategy (LS) notes substantial quantities of excavated material will become and remain available during the Site Preparation Works. This material could be used to increase the height of the bund to at least 3.0m high in relation to the platforms and haul roads. A bund of this height would screen lower level construction activities. 2.6 The bund is temporary only (i.e. remaining during the construction phases only) and is not intended to mitigate adverse visual impacts arising from the HPC development. 2.7 Despite the fact that the SPW will have a major adverse impact on views, local landscape character, landscape quality, tranquillity and distinctiveness, the screening and mitigation proposed by NNB during the construction phases of the development (including the SPW) is inadequate at best. 3 Reinstatement and s.106 Agreement 3.1 The s.106 Agreement relating to the SPW has been carefully negotiated by the Councils, NNB and the Estate. The s.106 Agreement provides, inter alia, for safeguards to ensure the reinstatement of the site in the event that the DCO is granted but not proceeded with so as to limit the duration of the adverse impacts which would result from a partially developed site. 3.2 These safeguards are an important material consideration. NNB has not provided a convincing justification as to why the provisions of the s.106 Agreement should be avoided. Temporary Jetty – Works TJ1,2,3&0 4 General Comments 4.1 As with the SPW, it is confusing for this element of the development to be subject to two parallel planning processes aimed at achieving the same result (see para 1 above). 4.2 The Estate made its case fully in relation to the temporary jetty during the course of the recent three week Inquiry which was convened to consider (inter alia) an application for a Harbour Empowerment Order for the construction and operation of the same. The Estate's principal concerns related to landscape and visual impact (including the scale, siting and appearance of the on-shore infrastructure and lack of effective landscape mitigation), impact on cliff stability, and the lack of adequate safeguards to secure the reinstatement of the site. The same considerations apply to proposed Works TJ1, TJ2, TJ3 and TJ0. 5 Securing the removal of the jetty and on-shore infrastructure 5.1 Work TJ0 provides for the removal of the temporary jetty. However, the timing of the removal of the jetty is not secured thus leaving the removal of the jetty at the discretion of NNB. The removal of the jetty should be secured on the face of the Order (which should also contain requirements to ensure the impacts of removal are mitigated adequately). 6 Landscape and Visual Impact 6.1 The Temporary Jetty includes proposals for large scale onshore infrastructure, notably ~20.0m high (~40m AOD) sand shed and silos, aggregates stockpiles, lighting, and a perimeter haul road that would be highly visible in an elevated location next to the heritage land. The infrastructure would be constructed prior to commencement of the HPC development and would be operational throughout its construction for not less than 10.5 years in total. Throughout this time there would be long term major adverse visual and landscape impacts from the Temporary Jetty on the adjoining heritage land and those who use and enjoy it. 6.2 Although the Estate continues to discuss with the Applicant additional mitigation for the Temporary Jetty, including screening within the north west boundary of the HPC development and the siting and design of the infrastructure, no measures are proposed to screen the development other than the SPW bund which, as noted above, would not mitigate adverse visual and landscape impacts caused by the development sufficiently. 6.3 The operation of the Temporary Jetty infrastructure and construction of the HPC development are inextricably linked causing major adverse interactive impacts of long term duration. Therefore adequate mitigation is essential in advance of the construction and operation of the Temporary Jetty to reduce major adverse landscape and visual impacts on the adjoining high quality landscape and those who use and enjoy it. 7 Cliff Stability 7.1 The cliff is a dynamic and unstable coastal environment (6m retreat predicted in 10 years) and in a ‘metastable’ condition (close to collapse at any time). Construction use and demolition activities could adversely impact upon current stability by accelerating rock fall and cliff retreat and resulting in the loss of existing loose material from the existing cliff, through vibration by heavy plant and piling/drilling equipment. During the operational phase, the conveyor belt and roadway (utilised to transport many thousands of tonnes of aggregate) could result in the development of vibration with cyclic loading from loaded trucks. It is, therefore, necessary to include adequate controls to protect the cliff from accelerated retreat. No such controls exist in the draft restrictions. 8 Requirements and Obligations 8.1 The draft DCO contains just two requirements relating to the construction or operation of the temporary jetty. For example, there are no requirements relating to the method of construction, the hours of working, the generation of noise, vibration, dust or light. These requirements are inadequate to control the construction, operation, use and dismantling of the Temporary Jetty and the associated on-shore infrastructure. 8.2 The bilateral agreement entered into by NNB and the Council in respect of the temporary jetty contained reinstatement covenants to mirror those agreed in connection with the SPW to prevent the Site from remaining partially developed for an unlimited period of time. 8.3 We would reiterate that any powers granted pursuant to the DCO should be synchronised with existing consents and made subject to the same controls (see paragraph 1). Hinkley Point C Power Station – Work 1A 9 Ensuring Completion of the Development 9.1 There are no provisions in the DCO which provide for its expiration. Accordingly, NNB would be at liberty, should it so wish, to implement the DCO and then to leave the site in a partially developed state for an unlimited period of time whilst maintaining the validity of the consent. Such a situation is foreseeable in a number of situations (for example in the event that the financial incentives available to NNB are not as anticipated or in the event of a more significant change such as a U-turn in national policy (such as that seen in Germany)). 9.2 Leaving the site in a partially developed state for any period of time will have significant adverse impacts. This is particularly the case given the insufficiency of the proposed landscape mitigation and screening proposed prior to the completion of the development. 9.3 Further, the impact of HPC is justified by the urgent need for new nuclear power stations. Should the above situation occur (i.e. partial development of the site) the consent system will have failed in its objectives to deliver new nuclear power stations but the significant adverse impacts will have nonetheless been allowed. Provision must be made on the face of the Order to prevent this occurrence. For example, the Estate seeks provisions to secure the reinstatement of the site by NNB in the event that the site has remained partially developed with no progress being made for a significant period of time or if there is no likelihood of the development being progressed or the development has not been completed by a certain date (2025 has been previously agreed by NNB). Financial security should be given to secure reinstatement in these circumstances. In addition, the Estate considers that the reinstatement of the Site should be guaranteed by an appropriate public body in the event of default by NNB. 10 Decommissioning of Hinkley Point C 10.1 HPC will have a finite working life. As demonstrated by the continued presence of HPA, it is important to ensure that responsibility for actual decommissioning has been properly secured for future generations. 10.2 Whilst we appreciate that decommissioning is dealt with pursuant to the Energy Act 2008, at this stage the detail of the proposals for decommissioning HPC is unclear and will remain unclear until NNB submits its funded decommissioning programme. It is entirely appropriate for the planning system to be concerned not just with the decommissioning of Hinkley Point C but also the fully validated restoration of the site. 10.3 It is understood from our discussions with the Office of the Energy Minister that decommissioning will be funded by the payment of sums of money into a fund on yearly basis. However, it is entirely unclear how this approach will secure and fully fund decommissioning or restoration in the event that the station is only partially developed or is only operative for a few years. 10.4 Full and timely decommissioning must, therefore, be considered and secured at this stage. 10.5 NNB indicate that land will be temporarily required for the plant’s decommissioning. Their proposal fails to identify to what extent further areas outside of the station would be required to support that decommissioning. The Estate is not prepared to make any additional land available for this purpose. In addition NNB fail to clarify what is meant by appropriate restoration after completion of decommissioning. 10.6 As noted below, Hinkley Point A (HPA) is in the course of being decommissioned by the NDA and Hinkley Point B (HPB) is coming to the end of its useful life. It is, therefore, at least foreseeable that land will become available for use. There should be an obligation to use the previously developed land in preference to Greenfield land to facilitate decommissioning Hinkley Point C. 10.7 These matters should be clarified and secured before the DCO is granted. 11 Efficient Use of Land 11.1 Insufficient efforts have been made to secure the use of land which is or may become surplus comprised in the Hinkley Point A and B Stations. 11.2 There is a national policy imperative to ensure that new development makes the best use of previously developed land. HPA is currently controlled by the NDA, a body whose remit is to secure the decommissioning and clean up sites to enable the reuse of land. HPB is nearing the end of its useful life and is owned and controlled by a company in the same group as NNB. 11.3 In the case of HPC, it does not appear that sufficient effort has been made by NNB or the relevant bodies to sustainably utilise land that is currently occupied by buildings comprising HPA and HPB. 11.4 Not all of the land comprised in HPA requires nuclear decommissioning. Further areas of hard-standing could be used for compound/parking and the storage of costly plant and equipment etc in areas deemed secure. 11.5 At the very least, we would expect the application documents to fully set out the stage reached by NNB in its negotiations in respect of the use of land or indeed buildings at HPA and/or HPB that is available or may become available in the future. An open and independently verifiable assessment should have been made of the land that is or could become surplus and which could be utilised in the construction, operation or decommissioning of HPC. 11.6 The ES fails to fully consider the overall environmental impacts that will occur at the time of the decommissioning of HPA/B and the currently operational HPB. The IPC’s scoping opinion (April ’10; Section 3.44) also highlights the issue. Following recent case law (March 2011) demolition activity can also constitute a “project” under 85/337/EEC and the EU’s guidelines also address these “Impact Interactions”. 11.7 NNB propose a shared use of some off-site features that will also, for example, be used for the decommissioning of Hinkley A and the operational phase of Hinkley B. These include the local road network and the Combwich “roll-on-roll-off” facility. Shared-use of these features underpin the need to address these further off-site environmental issues tabled under 11.6. 12 Landscape and Visual Impact 12.1 The Estate considers that NNB has not complied with relevant national, regional and local planning policy by failing to provide reasonable mitigation to moderate adverse impacts during the construction phases of the Project on the landscape of the heritage land which is valued at national level for its outstanding scenic and historic interest or on the surrounding landscape in general. 12.2 Serious discrepancies exist between the definitions of temporary (i.e. construction) impacts in the Environmental Impact Assessment (EIA) Approach and Methodology for the assessment as a whole and for the landscape and visual impact assessment (LVIA). It is accepted that more extreme adverse landscape and visual impacts will arise during construction due to the nature of the activities involved compared to those at operation, and that mitigation may not be so essential because of their temporary nature. The EIA methodology uses timescales normally applied to large scale construction projects and categorises short term impacts as less than one year; medium term as one to five years; and long term as greater than five years. By contrast the LVIA describes short term as up to five years; medium term as between five and fifteen years; and long term as fifteen or more years. The overall construction period for HPC is abnormally long and is programmed to last at least 14.5 years so falls within the EIA and commonly accepted category of long term duration; the LVIA defines the duration as medium term. The LVIA definitions are subjective and call into question the robustness of the assessment of adverse construction impacts. The nature of all adverse landscape and visual impacts relating to Fairfield Estate have been incorrectly assessed as being of medium– instead of long-term duration during construction. Consequently the need to mitigate significant adverse impacts has not been appreciated and the measures proposed are inadequate. 12.3 The Environmental Statement (ES) does not consider fully the adverse landscape and visual impacts that would arise from construction of HPC in relation to the heritage land to the west where several large scale “temporary” buildings and structures will be visually prominent in addition to the Temporary Jetty infrastructure. 12.4 Construction and restoration will last approximately 14.5 years during which time working will take place over prolonged working hours and will have a major adverse impact on views and the tranquillity of the adjoining heritage land. 12.5 No measures other than the SPW bund on the northwest boundary of HPC are proposed to mitigate adverse landscape and visual impacts on the heritage land or surrounding landscape. The proposed bund would not be effective and the Estate considers NNB could undertake further measures in relation to the design of the bund and “temporary” buildings to reduce adverse landscape and visual impacts. 12.6 Adequate mitigation during the construction phases of the Project should be secured by way of a planning obligation or Requirement. 12.7 The ES and LS do not demonstrate through visual analysis that the restored landform and associated woodland planting on the western boundary of HPC would achieve the level of screening claimed, or that sufficient quantities of material would be available to construct the landform. Several discrepancies exist between visualisations in the ES, LS and the HPC Development Design and Access Statement (HPC DAS). Further information to clarify the inconsistencies between the visualisations and to demonstrate the effectiveness of the screening landform and planting will be effective from the heritage land must be provided to enable the IPC and members of the public to fully understand and consider the impact of the development. 12.8 The ES and LS do not describe how the construction site will be restored or managed in the long term to ensure successful establishment of agricultural land and woodland planting. This information should also be provided and, if acceptable, secured by way of obligation or Requirement. 12.9 Overhead electricity transmission lines are prominent in the visualisations provided in the ES, LS and HPC DAS. The lines add to the visual clutter on the site and exacerbate its visual impact. Whilst it is noted the proposals for the transmission lines are indicative and subject to a separate DCO application, in so far as the transmission lines are within the scope of the DCO, they should be installed underground so as to minimise visual impact from the heritage land and the wider surrounding landscape. 12.10 The ES and LS state (incorrectly) that off-site mitigation planting proposals have been prepared by the Estate in consultation with NNB to screen the construction works. The off-site planting has been voluntarily carried out by Estate and is intended to protect the Estate’s heritage assets in a wider context when HPC is in operation, and indirectly benefit the public, where mitigation could not be achieved within the HPC site; it is not intended to contribute to NNB’s planning responsibilities. This planting will not (and is not intended to) mitigate adverse impacts arising from any construction activities. Further, the planting is on land outside the control of NNB and outside the scope of the DCO application and cannot, therefore, be subject to any Requirements or Obligations. 13 Design and Appearance 13.1 The Estate does not agree with NNB’s claim that the extent of screening provided at restoration will leave only ‘an uncluttered view of the nuclear reactor domes, turbine halls and pylons… that would visually integrate with the coastal landscape’. From the information provided it is likely that several low level buildings will be visible creating an extensive industrialised landscape when viewed from the heritage land. 14 Impact on Amenity Noise & Vibration 14.1 The construction of the Project will generate considerable noise and vibration. The proposed requirements to address and encourage the minimisation of noise are insufficient and the physical mitigation proposed (such as bunding) is unlikely to be effective to screen or reduce noise. 14.2 There are no Requirements relating to noise levels generated during the operational phase of the Project. It is entirely inappropriate for the generation of noise to be entirely unrestricted in this respect particularly given that clause 7 of the draft DCO provides a defence against statutory nuisance claims thus leaving those affected by the noise without a remedy. 14.3 There are no restrictions or controls on the generation of vibration. Controls on vibration are important in terms of impact on nearby residential occupiers and also from the point of view of the integrity of the cliff. Such controls should be included in the Requirements. Lighting 14.4 Lighting is an issue of great concern for the Estate that, if not adequately controlled, could have a significant adverse impact on the landscape, wildlife and on residents and visitors to this remote rural area. 14.5 For the construction phase, responsibility for lighting will largely fall upon contractors who are to be required to comply with the NNB lighting strategy. That strategy is open to the contractor’s interpretation and fails to outline any NNB policy on lighting. It also fails to identify how disputes will be resolved, particularly between contractors, and how enforcement and investigations will be addressed towards resolution. 14.6 NNB note that construction difficulties do not allow exact illumination requirements to be precisely defined and that light levels may be exceeded at times. Any such exceedances must be objectively justified as being necessary (rather than convenient) and limited in area and duration. Such exceedances must be part of an approvals process, with implementation monitored independently. 14.7 Task lighting is identified by NNB as a requirement for the construction. As above, such lighting needs to be adequately justified and controlled and monitored independently. Task lighting does not extend in the ES to lighting provided by and/or emanating from vehicles. Such lighting should also be controlled. 14.8 NNB are to develop a computer model to analyse lighting use and luminaire positioning. The use of a recognised model, or one that is validated for intended use, is essential. This is imperative since the mitigation proposed via a contractor’s interpretation and the use of bunds is unlikely to be effective to screen or reduce light spill. Dust 14.9 Emphasis has been placed by NNB on a longer term solution to dust mitigation via the landscaping work and construction of a bund. Greater application to controlling dust and PM10 during the early construction phase has to be considered and implemented. The impact of dust is an important issue for the Estate as much of the surrounding land is arable farmland. Dust will have a significant adverse impact on crops and must be adequately controlled. 15 Transport 15.1 Key road links have been selected by NNB, who touch upon a process for transferring workers to and from Park and Ride facilities during the construction of HPC. Their statement is however silent on what measures are to be put in place to prevent routes being taken that utilise inappropriate lanes to the west and through the hamlets of Stogursey, Shurton, Burton etc. NNB must implement robust measures that prevent such movements of site-bound traffic and these measures (together with appropriate monitoring) must be secured by way of obligation or Requirement. 15.2 The construction traffic for the Project (particularly prior to the completion of the Temporary Jetty) will have a significant and prolonged adverse impact on the local road network. This impact will be particularly pronounced before the completion of the construction of the temporary jetty during which period all freight will have to arrive by road. It is, therefore, important to ensure the delivery of the Cannington bypass at the earliest possible stage of the development in order to alleviate the very severe impact on the residents of Cannington. 15.3 However, the construction of Cannington bypass and the HPC development are both due to start in Q1/2013. The bypass should be completed prior to the commencement of development of HPC so as to minimise the impact on local residents. In the event that the IPC is not minded to impose such a requirement, the delivery of the bypass must be linked to an effective limit on vehicular movements which cannot be exceeded until such time as the bypass has been delivered. 15.4 Construction of the bypass is to be during daytime hours (Mon-Sat) over 21 months. The Estate considers it appropriate for an earlier start to be made with greater use of seven day working to expedite completion. 15.5 Permanent traffic calming management measures within Cannington would also be introduced by NNB by the time the bypass is opened. These traffic management measures should be introduced in advance of the commencement of the overall construction programme. 15.6 NNB state that the Bridgwater bypass was neither needed nor appropriate because of a number of reasons concluded by the transport assessment. The Estate asserts that an insufficient investigation into the feasibility and necessity of a Bridgwater bypass has been made; particularly since the road network will be used jointly by the construction programme and for the decommissioning of Hinkley ‘A’ and ‘B’ and will continue to be used by existing users of the local road network including local residents, workers and holiday makers. 15.7 NNB assert that any rail passenger or freight link to the Hinkley ‘C’ site would need to operate via an existing rail head and that Williton and Bridgwater were taken forward for consideration. The Estate contends that an insufficient assessment concerning the potential movement of freight to and from an existing rail head in the vicinity of Bridgwater has been made. 16 Proposed storage and disposal of Nuclear waste including the logistics away from site 16.1 The Estate is aware that the IPC has no remit to assess management of radioactive wastes. Nevertheless, the Estate seeks assurances that it will have adequate opportunity to review and comment upon such arrangements during all phases of the project. Contaminated Land 16.2 Although characterisation of the ground has been undertaken, it is conceivable that radioactive contamination may be encountered during construction. No contingency measures have been identified if such contamination was encountered. 16.3 Any ground contamination caused during site operations must be managed actively and the spread of contamination must not be allowed to impact adjacent lands, groundwater or the estuary. Processing and Storage of Solid Waste on Site 16.4 NNB has proposed the construction of only one Intermediate Level Waste (“ILW”) Interim Storage Facility (“ISF”). The Estate is concerned that multiple construction phases could take place in the future. NNB should demonstrate that only one ILWISF will house all of the ILW generated at site (from the operational phase through final site clearance). 16.5 Estimates of potential ILW decommissioning wastes are precise with no uncertainty ranges defined. If NNB is indeed going to construct a single ILWISF for the life of the site, what assurance can be given that the facility will be able to cope with the volumes of waste to be generated during both the operation and decommissioning? 16.6 NNB propose to store spent fuel on site in an Interim Spent Fuel Store (ISFS). There appears to be confusion regarding its design life. The Environmental Statement (ES) quotes 100 years and the Environmental Appraisal states 100 years “following the end of reactor life”. NNB is asked to confirm the design life. 16.7 NNB state that ILW will remain on site until power generation is complete; and that ILW will be transferred for off-site disposal once a Geological Disposal Facility (GDF) becomes available. NNB must be required to clarify its strategy for on-site management and final disposal of ILW (including security provisions). Consent should not be granted without a long term strategy for the final disposal of ILW which required the removal of ILW to off-site storage facilities at the earliest possible stage. Upper limits should be imposed on the length of time for which ILW can be stored on site. Controls should also be imposed to prevent the storage of waste from other facilities at Hinkley Point. 16.8 It is understood that NNB propose that very low level radioactive waste (VLLW) will be accumulated on site and then disposed of at appropriate licensed facilities. The Estate is concerned that poorly managed piles of VLLW will accumulate on site; leading to the possibility that contaminated dusts etc. would migrate off-site and contaminate adjacent land. NNB must be required to put in place robust and enforceable plans for the management of VLLW. Off-site Disposal of Solid Waste 16.9 NNB state that VLLW would be treated on site and then disposed of at authorized facilities. Such facilities are currently rare in the UK. NNB should be required to define the disposal location for VLLW, the transport mechanisms to be used (including security arrangements) and the frequency of VLLW shipments from Hinkley Point ‘C’ to the disposal site. 16.10 LLW will be transferred to the Low Level Waste Repository at Drigg for disposal. Transport mechanisms and the timing of shipments have again not been identified. The Estate is concerned that shipments of radioactive waste will disrupt the local community. NNB should be required to set out the relevant details regarding these wastes. Treatment and Discharge of Gaseous Waste 16.11 The Estate believes that there is ambiguity in NNB’s Planning submission. Early documents indicate that all radioactive gaseous effluent will be discharged via the main stack. Various additional stacks have, however, been identified. NNB should be required to confirm the location of all stacks that will be used for radioactive discharges and to confirm whether dispersion modelling has been based upon the use of multiple stacks or relies upon a point source discharge from the main stack. 16.12 The height of the main gaseous effluent discharge stack is unclear. NNB reports appear to range from 70m to 80 m. Since the height has an impact on the results of atmospheric dispersion modelling (as well as the overall visual impact), NNB should be required to confirm the design specification and that the air dispersion modelling ensures that the impact assessment reflects the final construction design. Off-site Disposal of Contaminated Oils 16.13 NNB states an intention to treat radioactively contaminated waste oil at licensed incinerators. The Estate is concerned that there are few incinerators licensed to accept such contaminated oils in the UK. It should be demonstrated that a suitable incinerator has been identified in line with the proximity principle adopted by the Environment Agency (EA). Processing of Liquid Effluent 16.14 Very little detail regarding the processing and discharge of liquid radioactive waste has been offered by NNB. It should be demonstrated that liquid radioactive waste discharges are being minimized and are aligned with Best Available Technique (BAT) required for the environmental permitting regime. 17 On Site Campus 17.1 Given the remote location of the site and the relative proximity of the sizeable town of Bridgwater, priority should be given to minimising the size of the campus and maximising the re-use of land within Bridgwater. 17.2 Bridgwater has the capacity to assimilate, without difficulty, the of workforce numbers proposed to be accommodated on site. The town offers a number of opportunities for the redevelopment of unused or underused previously developed sites with close proximity of local services and to leave a positive legacy when construction of HPC has been completed. Locating the workforce within Bridgwater will also provide an economic boost to the town. 17.3 Accordingly, from an environmental, economic and social point of view, the most sustainable option is to house workers, in so far as possible, within Bridgwater. 17.4 Further the introduction of a relatively large, semi itinerant, predominantly male population into an isolated location can have an unfortunate impact on local people (as was experienced during the construction of HPB). 17.5 The Estate does not object to a small number of workers being accommodated on site in so far as is necessary to provide essential security or emergency cover. However, the proposed on-site campus remains of a size that is excessive for this purpose. 17.6 Noise from campus is not adequately controlled. There are no Requirements in the draft DCO limiting noise levels. In addition there is insufficient information as to how the campus “Code of Conduct” will be enforced, supervised and consequences addressed and observations monitored. 17.7 The bund design proposed by NNB is unlikely to be of sufficient height to screen noise or views of the campus; especially given that the accommodation units are expected to be of an unspecified height equivalent to 3-storeys. The height of the buildings must be set at this stage to enable an informed consideration of the likely visual and noise impact of the campus. 17.8 For the main construction zones, it is understood that tertiary treated sewage will be discharged to the foreshore. NNB propose that treated sanitary effluent from the campus will be discharged into the stream referred to by NNB as ‘Holford stream’. The Estate contest the need for this, given the availability of the sea outfall. 17.9 NNB state that there is to be no direct pedestrian or road access from the campus to the village of Shurton. They add that measures will prevent shortcuts to Shurton and Stogursey. However NNB also refer to an infrequently used emergency access point (gated and locked) and are silent on the gate design and whether pedestrian access might be feasible. This emergency access must be kept for emergencies only. 17.10 Routine security issues are only touched upon by NNB. Whilst the Estate notes that these will be addressed through DECC, they are concerned that security aspects deemed lower priority by DECC but important locally, may be overlooked. 18 Cliff Stability and Sea Wall 18.1 The draft DCO does not appear to contain any Requirements relating to the stability of the cliff in relation to the main Project. The cliff is an important geological structure and needs to be adequately protected. 18.2 We note that a sea wall is proposed at the eastern end of the Estate (western part of the HPC Development) with rock armour extending onto the foreshore. Adequate safeguards and good construction management protocols (EMP’s and CEMP’s) should be put in pace for all construction works on the foreshore and in the vicinity of the cliff line. 18.3 As part of the decommissioning phase, NNB do not propose to remove the sea wall. Their proposal fails to identify who will be responsible for maintaining the sea wall left in legacy after site decommissioning. 18.4 If not maintained, the sea wall is likely to have an impact on the cliff face in particular at the wall edge where there may be risk of scouring and erosion behind the sea wall. Any such impacts need to be adequately controlled. 19 Habitats 19.1 Himalayan Balsam is identified by NNB as an “Invasive Species” (found around Bum Brook) that requires measures to prevent it spreading. The Estate is concerned that no contingency measures have been identified in the event that that this species or other invasive plant is encountered during mainly the construction phase. The concern extends to understanding what awareness training will be put in place for contractors to identify such species that may only have a seasonal appearance. 19.2 The so called Holford Stream and Bum Brook are both identified as flowing into and being important to Wick Moor SSSI/SPA. Emphasis has been placed by NNB on preventing pollution to the incoming water but no consideration has been made about understanding the composition of the incoming water which may also be key to receptors and seasonal. 20 Requirements and Obligations 20.1 The Estate considers that the Requirements, as drafted by NNB, are insufficient and fail to adequately deal with the issues raised above. 20.2 The Estate shares the views of the Councils that the sums offered by NNB are insufficient to mitigate the impact of the project on the local area. 21 Draft DCO and Development Consent Obligations 21.1 The Estate reserves its right to comment on the detailed drafting of the Development Consent Order and Development Consent Obligations and on any new matters that may come to light at the written representations stage."